Flip Privacy Policy

Last updated: 02/23/2024

This Privacy Policy (“Privacy Policy” or “Policy”) applies to the collection and use of personal information by Humans, Inc. d/b/a Flip (“Flip,” “Company”, or “we,” or “us,” or “our”). It describes the Company’s practices regarding the collection, use, disclosure, and sale of personal information when you visit and interact with us, our application (the “Application”) or our website (collectively, the “Sites”) to access our services (the “Services”). By accessing the Sites, you agree to our collection and use of personal data as described herein and agree to our Terms of Use.

For purposes of this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

Opt out

By opting out here, we will not “share” or “sell” your information and you will be opted out of “targeted advertising” as defined under certain privacy laws. Please note that you won’t be able to change this preference. Your choice here is unrelated to the mechanisms by which you can opt out of emails from us, which are described in our Privacy Policy.

Notice at Collection: Personal Information We Collect

We collect the following categories of Personal Information:

• Personal identifiers: Name, billing and mailing addresses, email address, telephone numbers, IP address, mobile ad ID, account username and password, social media platform usernames/handles, date of birth, gender, your contacts and their contact information (if you choose to provide us with access), and identifying information you may voluntarily provide to use through our Live Support or other customer service platforms.
• Commercial information: Records of products purchased or considered; consuming histories or tendencies; records of videos viewed and engagement with those videos (comments, likes, dislikes) and products that appear on them; comments, reviews, likes and dislikes and purchases associated with videos you post; beauty preferences (hair type, skin type and tone, skin concerns) provided.
• Internet or other electronic activity information: Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites (including flip videos on the Site) and our advertisements.
• Professional information: Name of the company or entity that you represent, title and position information.
• Audio and visual information: Recordings of customer service calls, your voice and image as they appear on videos uploaded to the platform, photographs you post.
• Inferences drawn from any of the Personal Information identified above.

We have collected the same categories of personal information in the 12 months preceding the date of this Policy.

Notice at Collection - Purposes for Collection of Personal Information

We collect the categories of Personal Information identified for the following purposes:

Notice at Collection: Categories of Personal Information We Sell or Share for Targeted Advertising

We work with AppLovin, an advertising platform, to deliver advertisements on the FLIP mobile application and we sell / share for cross-context behavioral or targeted advertising the following categories of personal information with them:

• Personal identifiers: names, email addresses, phone numbers, mailing addresses, usernames, IP address, mobile advertising IDs
• Commercial information: records of products purchased or considered; consuming histories or tendencies; records of videos viewed and engagement with those videos (comments, likes, dislikes) and products that appear on them
• Internet or other electronic activity information: device and browser type, browsing and search history on our Sites, and information regarding your interaction with our Sites (including flip videos on the Site) and our advertisements

For more information about AppLovin’s collection and use of personal information we provide to it with it, visit https://www.applovin.com/privacy/.

For more information about the use of cookies and other tracking technologies, see the section “Our Use of Cookies and Analytics” below.

To opt out of such sales and sharing of personal information, click [here].

We do not sell or share for cross-context behavioral advertising any other categories of personal information.

Opt-out Preference Signals / Do Not Track

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control (“GPC”) signal [for users in California and Colorado]. If you are logged into your account when you visit our website with the Global Privacy Control signal enabled, we will recognize your opt-out selection with respect to all personal information we collect about you, including through our mobile application. If you are not logged in when you visit the website, we will only recognize your opt-out preference on the browser and device that transmits the signal. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

We do not recognize the “do not track” or “DNT” signal that was introduced in the early 2010s and not broadly adopted.

Notice at Collection: Retention Periods

We retain the categories of personal information we collect for the length of time necessary to provide our Services and to comply with legal obligations or to protect our legal rights.

Sources From Which We Collect Personal Information

We collect personal information directly from users of our Services, visitors to our website, users who may share your contact information with us, App Lovin, and representatives of entities with which we do business or may do business.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.

No Profiling to Facilitate Decisions with Legal or Other Significant Effects

We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects, such as the provision or denial of financial or lending services, housing, insurance, or access to essential goods or services.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of personal information we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information to the categories of third parties identified above to process payments, fulfill and ship orders, and to operate our IT systems and secure our systems.

Additional Information About How We May Disclose Personal Information and Purposes for Disclosures

We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Cookies and Google Analytics

We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our Sites. Tracking technologies are small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our Sites. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with our Services.

We may also allow third parties to use third party cookies, web beacons, and other storage technologies to collect or receive information about how you interact with our Sites and elsewhere on the Internet and use that information to provide analytics and other measurements services, and to deliver and target advertisements tailored to you.

You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

Third Party Websites and Applications

Our Sites may contain links to other third-party websites, applications or social media platforms, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites, applications or platforms. Accordingly, we recommend that you review the privacy policies posted on any website, application or social media platform that you may access through our Sites.

International Residents

Personal information collected from you, including via our Sites, will be transferred to the United States where the Sites are hosted. You hereby consent to the transfer of your personal information to the United States as described in this Privacy Policy. Please do not use the Sites if you do not agree to the transfer and processing of your personal information in the United States, which may not provide the same level of protection for your data as your home country.

Minors

Our Sites are not directed to minors under the age of 13 and are not to be used by minors under 16 years old. If you are under age 16, please do not access our Sites or download the Application (or delete it if you have downloaded it) and do not provide any personal information to us.

Changes to the Privacy Policy

We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Sites notification that the Policy has been updated and by updating the date of the Policy.

Accessibility

We work to make our Sites accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at legal@flip.shop.

How To Contact Us

If you have any general questions regarding the Sites or Services, please contact us at: privacy@flipfit.com.

U.S. State Data Privacy Rights

Residents of certain U.S. states may have rights regarding their personal information under state law, as set forth below.

In those states that provide such rights, please note that before responding substantively to requests to access, know, delete, or correct, we will take steps to verify your identity. If we cannot do so through your account, we may ask you for two pieces of personal information to assist in verification of your identity. If we are unable to verify your identity with the degree of certainty required, we may not be able to respond to the request. We will notify you to explain the basis of the denial.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.

If you exercise your data subject rights pursuant to applicable law, we will continue to treat you fairly and you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”) and other laws grant California residents the following rights with respect to their personal information we collect and process about them:

Right To Know

To request the following information from us with respect to their personal information we have collected since January 1, 2022:

• Specific pieces of personal information we have collected about you;
• Categories of personal information we have collected about you;
• Categories of sources from which such personal information was collected;
• Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
• Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling your personal information.

Right To Delete

The right to request deletion of the personal information we have collected from them, subject to exceptions under the law.

Right to Correct

The right to ask that we correct inaccuracies in their personal information, taking into account the nature of personal data and purposes of processing such information.

Right to Opt Out of Sale/Sharing

The right to request that we stop selling their personal information or sharing it with third parties for the purpose of cross-context behavioral advertising.

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the personal information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. To make a request, please contact us at privacy@flip.shop.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, delete or correct your personal information, or to ask a question, contact us at privacy@flip.shop. For such requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can direct us not to sell your personal information or share it for purposes of cross-context behavioral advertising [here]. For such requests, we will comply no later than 15 business days after receipt of your request.

Authorized Agents

You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:

• Requests to Know, Delete or Correct Personal Information: If the agent submits a request, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
• Requests to Opt Out: If the agent submits a request to opt out of the sale of your personal information or the sharing of your personal information for purposes of cross-context behavioral marketing, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

COLORADO PRIVACY RIGHTS

The Colorado Privacy Act (“CPA”) grants Colorado residents the following rights with respect to their personal information we collect and process about them:.

• Right to Know: The right to confirm whether or not we are processing their personal information and to access such data
• Right to a Copy: The right to a portable copy of the personal information we have collected from them
• Right to Delete: The right to request deletion of their personal information that we have collected about them and to have such information deleted, subject to certain exceptions
• Right to Correct: The right to ask that we correct inaccuracies in their personal information, taking into account the nature of personal data and purposes of processing such information
• Right to Opt Out of Targeted Advertising: The right to ask us to stop processing their personal information for targeted advertising
• Right to Opt Out of the Sale of Personal Information: The right to ask us to stop selling their personal information

Please note that for purpose of this section of this Policy, we consider “personal information” to have the same meaning as “personal data” as defined under the CPA.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, request a copy of, delete or correct your personal information, or to ask a question, contact us at privacy@flip.shop. We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can opt out of the sale of your personal information or the use of your personal information for targeted advertising [here].

When We Do Not Act on a Request – Appeal Process

In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.

Additionally, you have the right to appeal our decision by contacting us at privacy@flip.shop within 30 days after your receipt of our decision. Please provide us with your Flip username and/or email associated with your Flip account. We will respond to your appeal within 45 days of our receipt of the request, unless we need additional time to do so (up to 60 additional days), in which case we will notify you.

Authorized Agents

You may designate an agent to submit an opt-out request on your behalf. If you would like to designate an agent to act on your behalf, we will ask them to provide proof of their authorization.

Authorized agents can submit a request to opt out of targeted advertising by contacting us at privacy@flip.shop.

TEXAS PRIVACY RIGHTS

As of March 1, 2024, the Texas Data Privacy and Security Act (“TDPSA”) will grant Texas residents the following rights with respect to their personal information we collect:

• Right to Know: The right to confirm whether we are processing their personal information and to access the data.
• Right to a Copy: The right to a portable copy of the personal information we have collected from them, if the information is available in a digital format.
• Right to Delete: The right to request deletion of their personal information that we have collected about them, subject to certain exceptions.
• Right to Correct: The right to ask that we correct inaccuracies in their personal information, taking into account the nature of personal data and purposes of processing such information.
• Right to Opt Out of Targeted Advertising: To the extent we use their personal information to engage in targeted advertising, the right to ask us to stop processing their personal information for such purposes.
• Right to Opt Out of Sale: To the extent we sell their personal information, the right to ask us to stop doing so.

Please note that for purpose of this section of this Policy, we consider “personal information” to have the same meaning as “personal data” as defined under the TDPSA.

Exercising Your Rights and How We Will Respond

On or after March 1, 2024, contact us at privacy@flip.shop to exercise the rights described above, with the exception of the right to opt out of the sale of or use of your personal information for targeted advertising (see below). We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can direct us not to process your personal information for purposes of targeted advertising [here].

When We Do Not Act on a Request – Appeal Process

In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.

Additionally, you have the right to appeal our decision by contacting us at privacy@flip.shop within 30 days after your receipt of our decision. Please provide us with your Flip username and/or email associated with your Flip account. We will respond to your appeal within 60 days of our receipt of the request.