Last updated: September 19, 2023
Welcome to FlipFlop. This Privacy Policy applies to FlipFlop services (the “Platform”), which include FlipFlop apps, websites, software and related services accessed via any platform or device that link to this Privacy Policy. The Platform is provided and controlled by MAXX Creation Technology Co.,LTD., with its registered address at No. 27 E0E1E2, Street/Road No. 10E, Boeng Chhuk, Nirouth, Chbar Ampov, Phnom Penh, Cambodia (“FlipFlop”, “we” or “us”).
We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users, and other individuals in connection with our Platform. If you do not agree with this policy, you should not use the Platform
We may collect the following information about you:
We may receive the information described in this Privacy Policy from other sources, such as:
As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, personalise content you see on the Platform, promote the Platform, and customize your ad experience. We generally use the information we collect in the following ways:
We share your information with the following parties:
If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.
Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.
We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place and service providers that assist us in marketing the Platform.
We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement.
If you use the FlipFlop Lite version of FlipFlop, we share information with advertising networks to display personalised advertisements to you on the FlipFlop Lite app and elsewhere online. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.
We share your information with independent researchers to facilitate research that meets certain criteria.
We may also share your information with other members, subsidiaries, or affiliates of our corporate group, including to provide the Platform, to improve and optimise the Platform, to prevent illegal use and to support users.
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:
Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. Alternatively, you can change your profile to default private by changing your settings to 'Private Account' in “Manage my account” settings.
We may also disclose your information to third parties:
When you make a purchase through our shopping features, we share the information related to the transaction with the merchant, payment and transaction fulfillment providers, and other service providers. For example, we will share the order items, contact details and delivery information so your order can be processed. These entities may use the information shared in accordance with their privacy policies.
Your information may be stored on servers located outside the country where you live, such as in Singapore, Malaysia or the United States. We maintain major servers around the world to bring you our services globally and continuously.
You have rights and choices when it comes to your information. You may be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. You may submit a request to exercise your rights under applicable laws at https://www.flipflop.com/legal/report/privacy. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. Please also see the Supplemental Terms below on whether a local representative or local contact is available for your country.
You can access and edit most of your profile information by signing into FlipFlop. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your videos, send you messages, or post comments to your videos. Should you choose to do so, you may delete your entire account in Settings.
You may be able to refuse or disable Cookies by adjusting your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.
We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable measures to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.
We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.
We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.
We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.
The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the Platform, we keep this information for as long as you have an account. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove your profile and User Content from public view immediately, but may keep other information about you to process the violation.
FlipFlop is not directed at children under the age of 13. In certain cases this age may be higher due to local regulatory requirements, please see your local supplemental terms for more information. If you believe that there is a user who is below this minimum age, please contact us at https://www.flipflop.com/legal/report/privacy.
If you are a parent or guardian, our Guardian's Guide contains information and resources to help you understand the Platform and the tools and controls you can use.
We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy or providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.
If you have questions, comments, complaints or requests regarding this Privacy Policy, please contact us at: https://www.flipflop.com/legal/report/privacy
Please also see the supplemental terms below on whether a local representative or local contact is available for your country.
We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to make a complaint with a relevant data protection authority, where applicable.
In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.
If you are using our services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Your rights and options
We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos.
If you are using the Platform in Australia, the following additional terms shall apply.
Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How we share your information". Please see here for further information on the countries in which our corporate group entities which receive personal information from Australia are located.
If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:
We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).
Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form "Contact". If you have any questions about the processing of your personal data, we would like to clarify them.
DPO: If you wish to reach the FlipFlop’s Data Protection Officer, contact us at: https://www.flipflop.com/legal/report/DPO
Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment for at least 6 months, in order to comply with legal obligations.
Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
International Transfers. International data transfers are necessary for us to provide our services. If you are located in Brazil, we will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.
If you are using the Platform in Canada, the following additional terms apply.
Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.
Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send. You can also adjust your preferences regarding certain types of personalized advertising by using the Ads tools in Settings.
Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States, Malaysia, Singapore, and other foreign jurisdictions where we or our service providers are located. For information about the manner in which we or our service providers (including service providers outside Canada) process personal data, please contact us using the contact information set out below.
Contact. If you are a resident of Canada, you can contact our Privacy Office at https://www.flipflop.com/legal/report/Privacy-Office-Canada
If you are using our services in Egypt, the following additional terms apply.
If you are using our services in India, the Platform is provided and controlled by ByteDance (India) Technology Private Limited. FlipFlop is our brand for providing and promoting the services. When using these services from India, please accordingly read “FlipFlop”, “we” or “us” in this policy to refer to Bytedance (India) Technology India Private Limited.
If you are using our services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall apply.
Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:
If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.
Your Choices. You may withdraw your consent to FlipFlop's disclosure of personal data to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of FlipFlop features and functionality.
You may request FlipFlop to (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of FlipFlop’s features and functionality.
To exercise any of your rights, contact us at: https://www.flipflop.com/legal/report/privacy.
Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.
Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.
After you have terminated your use of our Platform and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.
If you are using our services in Israel, the following additional terms apply.
If you are using our services in Japan, please refer to our Japanese language Privacy Policy for further information on our compliance with the Telecommunications Business Act.
If you are using our services in Mexico, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
How we use your personal data.
Almost all purposes of processing stated in this section of the main Privacy Policy are necessary purposes. However, the following are secondary purposes:
The above purposes are not necessary for us to provide the Platform but allows us to provide you with a better experience. We offer you the possibility to take decisions regarding how we use and disclose your personal data. You can always limit the secondary purposes of personalised advertising by using the tools in Settings that allow you to limit certain functions.
We use both human and automated means to process your data.
How we share your personal data.
We may share your personal data to a third party for purposes other than processing on behalf of us. We will obtain your consent for such sharing as required by applicable laws.
By providing us with your personal data and using our Platform you agree to the transfers that require your consent. You can always revoke your consent and exercise your rights, as stated below.
Your Rights.
You have the following rights with respect to your personal data: access, rectification, cancellation, opposition, consent withdrawal, limitation to the use and disclosure of your data. You can exercise your rights by sending your request to https://www.flipflop.com/legal/report/privacy. To know more about the applicable requirements and procedure to exercise your rights, contact us to the mentioned email address. If you are under 18 years, you may exercise your rights through a parent or guardian. Your rights requests will be resolved as soon as possible according to the nature of your request.
Information relating to children.
You may review our parental consent section in the Terms of Service.
What are legal grounds for data processing. When we process your personal data, we rely on the grounds of your consent, performance of a contract, our legitimate interest and obligations to process personal data, or when we are so required by law.
By signing up and using the Platform, you consent to the processing of personal data in accordance with this Privacy Policy.
Where we store your personal data. Your personal data may be transferred from Russia to Singapore and stored in that location, outside of the country where you live.
Public profiles. We rely on your consent to public distribution of personal data, when your account settings are 'Public Profile'. You can change your profile to private by changing your settings to 'Private Account' in “Manage my account” settings.
If you are using our services in South Africa, the following additional terms apply.
You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged FlipFlop's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.
If you are using our services in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
If you are using our services in Turkiye, the following additional terms apply along with the contents of the foregoing Policy. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
Data Controller Representative. You may contact our data controller representative in Turkiye by email or mail to handle questions and complaints in connection with the processing of your personal data if you are in Turkiye.
ESİN ATTORNEY PARTNERSHIP
flipflop@esin.av.tr
AKAT MAHALLESİ GÜL SOKAK NO: 2/1 34335 BEŞİKTAŞ/İSTANBUL, TÜRKİYE
Methods of collection, processing purposes of, and legal bases for, processing your personal data. Please refer to our Privacy Policy (in Turkish) and its Addendum, for detailed information about personal data categories we process, our processing purposes and related legal bases for processing.
Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:
You may exercise your rights listed above by contacting us at: https://www.flipflop.com/legal/report/privacy.
The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.
Cookies. Please refer to our Turkish Privacy Policy for further information on our use of cookies on our website.
Amendments. The following sections of the Policy do not apply to individuals in Turkiye:
The following sentence at the end of the second paragraph of the introduction section: If you do not agree with this policy, please do not use this Platform.
Language. This policy is available in English and Turkish. If there is any inconsistency or different interpretation between the English and Turkish versions, the Turkish text shall prevail.
If you are using the Platform in the United Arab Emirates (“UAE”), the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
How we share your personal data
In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.
Governing law and dispute resolution
By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:
where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and
for all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.
If you are using our services in Vietnam, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
Methods of processing your personal data. We may process your personal data by manual or automated methods.
Data subject's rights and obligations. Subject to certain exceptions, you have statutory rights and obligations under applicable laws. In particular, you have the following statutory rights:
You may exercise these rights by contacting us through the details in the Contact section, and we will respond to your requests regardless of the location in which your data is stored.
You have the following statutory obligations:
Age, Parental and Guardian Consent. If you are below 16 years old or under guardianship:
If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Platform if you are not at least 16 years of age.