FLAI Privacy Policy

1. Introduction

We, FLAI Corporation (“FLAI,” “we,” “us,” or “our”), will collect information related to individuals (“Personal Data”) in providing our FLAI communication app (“FLAI App”) and all products, apps, services and websites related to the FLAI App (collectively, the “Services”). We consider the protection of Personal Data to be one of the most important management issues as a responsibility of an Internet content service company. We will act in compliance with the laws and regulations applicable in countries and regions where we are conducting business (such laws and regulations are hereinafter collectively referred to as the “Applicable Laws”), and will make efforts to properly protect Personal Data based on this Privacy Policy (this “Policy”).

This “Policy” explains what kind of Personal Data we will collect, and how we will use and share such Personal Data, and how you can manage your own Personal Data.

Before using the Services or submitting any Personal Information to FLAI, please review this Privacy Policy carefully. By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not access any of our App or otherwise use the Service.

2. Applicable scope of this Policy

This Policy applies to all Personal Data that is collected in relation to our Services regardless of the country or region where our Services are being used.

2.1. Target services and service provider

This Policy applies to all Personal Data that is collected in relation to our Services.

We may apply individual privacy policies or additional provisions to terms of use or this Policy (collectively, “Individual Policies”) to specific services. The Individual Policies explain what kind of Personal Data we will collect, and how we will use and share such Personal Data, for such specific services, and the other policies that are applicable to such specific services. If there is any inconsistency between the subject matter of the Individual Policies and this Policy, the Individual Policies shall prevail.

In connection with the application of this Policy, FLAI is the controller of the processing of Personal Data.

2.2. Applicable countries and regions

We will process Personal Data only to the extent permitted under the Applicable Laws according to this Policy and only within the scope described in this Policy.

3. Personal Data to be collected

We will collect the following Personal Data:

(a) Information that you provide to us such as your email address that you register at the time of creating an account, and profile information that you set at the time of using our Services.

(b) Information related to your status of use of our Services such as the text, sounds, music, images, videos and other contents that you post, and your access log.

(c) In cases where you create a FLAI account using an external SNS account, information collected from a third party such as the identifier of the external SNS account that we will collect from that third party.

(d) Information collected such as “Like”.

We will collect the following types of Personal Data in providing our Services. If you do not provide certain types of information such as your email address which needs to be registered for using our Services, you may not be able to use all or a part of our Services.

3.1. Personal Data to be provided by you

3.1.1. Information to be registered at the time of creating an account

Before you start using our Services, we may ask you to provide your contact information for creating a FLAI account (“Account”).

For example:

In order to create an Account, you need to register your email address.

Please note that we assign an internal identification code (“FLAI ID”) to each Account created by our users.

3.1.2. Information required for communication and transaction

We may ask you to provide information required for communicating with you and conducting transactions with you depending on the nature, and collect and store such information.

For example:

(a) In order for us to answer any requests or questions that you send to our customer support, we may ask you to provide information required for identifying and investigating the event or resolving the problem, such as your contact information including your email address, and details of the trouble that you have encountered.

(b) If you purchase a product or a service, you will be required to provide information for making the payment of such product or service. Since credit card settlements are processed by appropriate third-party payment agencies, we will not retain your credit card number or security code.

3.1.3. Profile and information related to your friend relationship

When you use our Services, we will collect the profile that you set, and information related to your friend relationship.

Profile information

Profile information includes information such as the icon image, display name, identification code (“FLAI ID”) that you set or disclose in order to connect to other users. A FLAI ID is an identification code to make it easier for your friends to find you in our Services, and your friends can find you through your FLAI ID. You may also choose not to allow other users to contact you using your FLAI ID.

3.2. Personal Data to be collected in connection with your use of our Services

3.2.1. Status of use of our Services

We automatically collect information related to when and how you used our Services. The collected information includes the status of use of various features such as the date and time that you activated features, additional services that were purchased, and contents and ads that were viewed or tapped.

Posts and reactions to posts

In distributing your posts to other users, the contents that you posted are sent via our server.

For example, standard contents such as emoji and non-standard contents such as text, sounds, music, images and videos that you post are all sent via our server. In addition, external information such as the recipient of the contents, data format, date and time of the posting, and other information on how you are interacting with your counterparty is also recorded in the server.

Furthermore, in distributing reactions or replies to the posts of other users, we collect and use information related to how you reacted to the posts of other users. This information includes the action that you took against the distribution by other users, and the time and date of such action, such as you clicked “Like” for the posts of users.

We may use a part of such information upon obtaining your additional consent for the provision and maintenance of services, development and improvement of services, prevention of unauthorized use, and provision of optimized contents including ads.

3.2.2. Location information

When we provide customized contents or ads to you, such as weather forecasts and local news near the areas where you are located, we may separately ask you to generally provide your location information. In the foregoing case, you may at any time choose not to provide your location information by your FLAI App settings.

Even when you do not accept sending your location information, we may estimate your approximate location from network information such as your IP address.

3.2.3. Apps, browsers, devices and network information

We will collect information related to the device, browser and the app that you are using (ad identifier for identifying the device/browser, Cookie ID and device type, OS, language/time zone setting, browser type, app version, etc.), and network information (telecommunications carrier’s name, IP address, etc.).

We may also associate the collected ad identifier with the Internal Identifier.

3.3. Personal Data collected from third parties

We may collect Personal Data from third parties including our group companies.

For example, we will collect Personal Data from third parties in the following cases.

3.3.1. Personal Data collected from group companies

We may collect your Personal Data from our group companies according to their terms or policies. For the privacy policy that is applicable to the individual services provided by our group companies, please confirm the same in the individual services.

3.3.2. Personal Data collected from business partners

We may collect your Personal Data from our business partners. There are cases where we collect Personal Data from a business partner operating its own service, and from a business partner operating a service that is linked to our Services. For example, when you create your Account using an external SNS account, we will collect the identifier of that external SNS account.

In addition, we may obtain information such as your identifier (Internal Identifier, ad identifier etc.), one-way encrypted (hashed) email address and telephone number, IP address, part of your device information (OS, etc.), your attribute information and your action history, including your purchase and browsing history, from our business partners, in order to use the same for both sending official account messages from our business partners and distributing ads, as well as measuring ad effectiveness, creating and providing statistical information and for other purposes.

3.4. Personal Data uploaded by other users

There may be cases where a certain user, in using our Services, uploads information containing Personal Data such as a photo that includes a third party other than that user, and we collect such information.

4. Purpose of use of Personal Data

We will use Personal Data for the following purposes:

(a) Provision and maintenance of services;

(b) Development and improvement of services and contents;

(d) Provision of contents optimized for you.

We use Personal Data to provide our Services to users, for utilization in research and development to provide safer and better services, and to provide services that are strongly linked to users, including ads. We will not process the Personal Data we obtain beyond the scope of the purposes of use, except to the extent that consent has been obtained from you or as permitted by the Applicable Laws. In addition, we will take appropriate measures to ensure that Personal Data is not used for any other purpose. The specific uses of Personal Data are as follows.

4.1. Provision and maintenance of services

We will use information required for providing services that you requested, answering your inquiries, and hosting promotional events.

For example, in the following cases, we will use Personal Data for the provision and maintenance of services.

(a) To verify your identity, through comparison with your registered information, when you log onto the FLAI App or succeed your Account in changing your device;

(b) To process invoices when a user purchases a product or uses a paid service;

(d) To notify you of important changes to our Services such as the revision of terms, planned discontinuation of services, or change of features.

4.2. Development and improvement of services and contents

We will use Personal Data for the development and improvement of our Services for providing better services, products and contents to users toward the future.

For example, in the following cases, we will use Personal Data for the development and improvement of services and contents:

(a) To improve our Services by creating statistics and models related to the use of our Services;

(b) To conduct surveys related to our services that we are currently providing, or may provide in the future.

4.3. Security and prevention of unauthorized use

We will use Personal Data and promote security measures and measures against unauthorized use to maintain an environment where our Services can be used at all times, and users can use our Services with a sense of security on a daily basis.

For example, in the following cases, we will use Personal Data for the security and prevention of unauthorized use:

(a) To confirm whether there is any breach of terms of use, any illegal act, unauthorized access or any other unauthorized use;

(b) To monitor and confirm the details of reports and illegal postings, etc., and to develop tools for preventing unauthorized use by ways such as analyzing the details of such reports and illegal postings, etc.; or

4.4. Provision of contents optimized for you

We will utilize Personal Data for providing recommended contents, including ads, to each user.

For example, in the following cases, we will use Personal Data for providing optimized contents to users:

(a) To measure the effectiveness of the distributed ad; or

(b) To display ads related to our business partner’s website that you accessed;

(c) To distribute ads to you by ways such as associating or combining information obtained from our business partners, such as your identifier (Internal Identifier, ad identifier, etc.) and email address, part of your device information (OS, etc.) and IP address, with your Personal Data that we possess;

(d) To measure the effectiveness of distributed ads by ways such as using your identifier (Internal Identifier, ad identifier, etc.), part of your device information (OS, etc.) and IP address, etc. obtained from our business partners; or

(e) To provide our business partners with statistical information prepared by ways such as associating or combining information obtained from our business partners, such as your identifier (Internal Identifier, ad identifier, etc.), hashed telephone number and email address, attribute information, and your action history, including your purchase and browsing history, with your Personal Data that we possess, such as your identifier (Internal Identifier, ad identifier, etc.) and email addresses, attribute information and your status of use of our Services, including your history of accessing ads.

In principle, we obtain your consent when we process your Personal Data. If, however, permitted under Applicable Laws, we may process your Personal Data with any of the following legal basis:

(a) processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

(b) processing is necessary for compliance with a legal obligation to which we are subject (e.g., when following the information disclosure orders based upon laws and regulations announced by government agencies);

(d) processing is necessary to investigate, prevent and take measures against illegal or suspected illegal acts;

(e) processing is necessary for the legitimate interests pursued by us or by a third party, except where such interests are overridden by your privacy related rights, interests, and freedom (including improvement of operations or systems, prevention of fraud, maintenance of security, marketing, and research performed by us); or

(f) processing is necessary for any purpose related to public benefits or creation of archives of historical documents, or any purpose related to surveys or statistics supported by proper security measures.

For example, when we process your Personal Data for the provision and maintenance of services, development and improvement of services, and security and prevention of unauthorized use, such processing may be pursuant to the legal basis of legitimate interests indicated in (e) above.

5. Provision of Personal Data

We will not provide, disclose or share Personal Data to or with third parties unless we have obtained your consent or such provision, disclosure or sharing of Personal Data is permitted under Applicable Laws.

We may transfer Personal Data to a third country without any data protection laws which are equivalent to those of the country or region where you live when we have obtained your consent or such transfer of Personal Data is permitted under Applicable Laws.

In principle, we will not provide Personal Data to third parties unless we have obtained your consent or such provision of Personal Data is permitted under Applicable Laws.

However, in the following cases, we may provide Personal Data to third parties.

The recipients of Personal Data that we provide include third parties such as our subcontractors, subsidiaries, and affiliates located in countries or regions other than where you are residing.

In providing Personal Data, we may transfer Personal Data to a third country without any data protection laws which are equivalent to those of the country or region where you live. In the foregoing case, we will adopt standard contractual clauses or other means pertaining to data protection approved in your country or region, and transfer Personal Data to a third country according to the requirements of Applicable Laws.

5.1. Public disclosure by users themselves

The profile information that you registered will be processed as public information.

Messages that you posted on public boards, and actions such as “Like”

to posts of other users will be made available to third parties.

The foregoing information may be copied, stored or spread by the recipient, and accessed by an unintended third-party recipient, due to the nature of digital data.

5.2. Vendors and service providers

To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.

5.3. Sharing of Personal Data among group companies

We may share, among our group companies, the Personal Data indicated in “3. Personal Data to be collected”. For example, in order to alleviate the trouble of creating an Account in the services provided by our group companies, our group companies may refer to the information registered with the FLAI App.

As the purpose of sharing Personal Data is the same as the purpose of use described in “4. Purpose of use of Personal Data”, for the purpose of use of the party with which the Personal Data was shared, “FLAI” shall be replaced with “our group company”, and “Services” shall be replaced with “services provided by our group company”.

5.4. Succession of business

If there is any transaction between companies pertaining to our business to which this Policy is applicable, such as acquisition, merger or change of business entity, Personal Data may also be transferred to the successor of the business to the extent permitted under Applicable Laws.

5.5. Provision of services and ad distribution through collaboration with other companies

In cases where you use the services of our business partner, we may provide, to that business partner, information to be used by the business partner for identifying you.

The processing of Personal Data by our business partner shall be pursuant to the terms or policies prescribed by each business partner.

5.6. Compliance and cooperation with public agencies

If we receive a request pursuant to legal proceedings such as a warrant, or if there is imminent danger to someone’s life or property such as a suicide threat or a bomb threat, we may disclose Personal Data to third parties including law enforcement agencies such as the police, or the court, pursuant to Applicable Laws.

6. Chat Privacy and Security

6.1. AI Messaging

FLAI prioritizes your data privacy and security. As the user, you maintain complete ownership of both your inputs and outputs, in accordance with relevant regulations. Your data is exclusively yours to utilize, with no sharing or utilization for model training. FLAI never stores your conversation log with AI. Your data remains stored locally until you decide to delete it. Furthermore, FLAI has robust security measures to safeguard your data. All data is encrypted using AES-256 while at rest and during transit with TLS 1.2+. We uphold stringent access controls to ensure that only authorized parties can access your information.

6.2. User Messaging

When engaging in a chat with another user, we employ end-to-end encryption to safeguard your conversations. The security measure guarantees that only you and the intended recipient can access and comprehend the content, with no accesss for intermediaries, including FLAI. Your messages are secured with a digital lock, and solely you and the recipient possess the exclusive key essential for unlocking and perusing them. This entire process occurs seamlessly, requiring no manual activation of specialized settings to fortify the security of your messages.

7. Safety control of Personal Data

We will take strict technical and organizational security measures in managing the collected Personal Data. In order to continue to improve our protection of Personal Data, we will review and bolster our internal rules and regulations in accordance with changes in laws and social norms.

Unless you request the deletion of your Account, in principle, we will retain most of your information. Once we receive your request to delete your Account, we will delete your information according to Applicable Laws and internal rules after retaining such information for a given period of time.

7.1. Security measures

We are taking strict technical and organizational security measures in managing the collected Personal Data for respecting and protecting your privacy and confidentiality of your Personal Data, and preventing unauthorized access to your Personal Data. These measures include safety control measures based on industry standards for preventing unauthorized access to Personal Data, and disclosure, unauthorized use, falsification or destruction of Personal Data.

For example, we are taking the following measures.

(a) Provision of encryption feature of messages.

(b) Strict access control based on a need-to-know basis.

(d) External authentication for objectively evaluating our security measures.

(e) R&D of new security technologies.

Furthermore, we will never provide any means for fraudulently accessing Personal Data to a third party.

However, because no method of electronic transmission or method of data storage is perfect or impenetrable, we cannot guarantee that your Personal Data will be absolutely safe from intrusion during transmission or while stored in our systems.

To help protect your privacy and confidentiality of your Personal Data, we also need your help. Please do not share your password with others, or use the same passwords you use for other services.

7.2. Storage location of Personal Data

In providing our Services, we may store your Personal Data outside the country or region where you reside. When that happens, we will take measures to ensure your Personal Data is transferred according to the applicable laws.

7.3. Storage period of Personal Data

FLAI collects and retains Personal Data to provide our Services according to your request, fulfill any of the applicable purposes of use described in this Policy, or to comply with Applicable Laws.

Unless you request the deletion of your Account, in principle, we will retain most of your Personal Data. Once your Account is deleted, we will process your Personal Data properly according to Applicable Laws and our internal rules after retaining such Personal Data for a given period of time for the following purposes:

(a) to reply to inquiries;

(b) to resolve disputes or collect fees;

(d) to comply with Applicable Laws.

Otherwise, we prescribe the storage period of Personal Data according to the following standards.

(a) We will not in any way use highly private information such as texts, sounds, music, images and videos data between users for any purpose other than the distribution of messages (including retransmission in the event of a communication failure or synchronization of messages from multiple devices) unless we have obtained your consent or such use is permitted under Applicable Laws. While we will retain the foregoing information for a minimum period, such information will subsequently be automatically deleted from our server.

(b) If you have expressly declared your intent to store your Personal Data, we may respect your intent and store your Personal Data for a long period.

(c) If a storage period is prescribed under Applicable Laws or the like, we will store Personal Data according to such storage period.

We may continue to retain Personal Data in a format in which individuals cannot be identified after the lapse of the storage period prescribed pursuant to Applicable Laws and our internal rules.

8. Your choices regarding Personal Data

You have rights regarding your Personal Data processed by us, such as the right to access your Personal Data and the right to correct your Personal Data, to the extent permitted under Applicable Laws.

We are exerting efforts to provide, in our Services, features which enable you to personally edit your profile, and set and manage the collection, use and sharing of your Personal Data.

To the extent permitted under Applicable Laws, regarding your Personal Data that we process, you have the right to access, the right to rectification, the right to erasure, the right to restriction of processing, the right to withdrawal of your consent, the right to data portability, the right to confirm if we process any Personal Data of yours, and the right to request a review of any automated decisions that may be made as a result of the processing.

In addition, to the extent permitted under Applicable Laws, you also have the right to object to the processing of your Personal Data that we process in certain cases.

We are exerting efforts to provide, in our Services, features which enable you to personally manage your Personal Data on the FLAI App, edit your profile, set the collection, use and sharing of your Personal Data, and set and manage your Personal Data including the scope of disclosure of posts, opt-out of ads, and deletion of your Account. Please periodically confirm that no old information or inaccurate information is remaining, and properly update your Personal Data.

Specifically, we provide the following features:

(a) Confirmation and change of public profile information.

(b) Setting and change of email address, deletion of email address.

(d) Whether to allow third parties to view your Personal Data retained by your friend.

If you no longer wish to use our Services or if you withdraw your consent to FLAI’s processing of your Personal Data which is necessary for us to provide our Services, you may choose to delete your entire Account. However, the withdrawal of your consent will not in any way affect the lawfulness of our processing of your Personal Data based on your consent that was given before the foregoing withdrawal.

9. Use of third-party modules and Cookies

We may use tags and modules, etc., including cookies and third-party SDK for fulfilling the purposes described in this Policy.

9.1. Third-party modules

We may install modules of a third-party software development kit (SDK) in our Services for the following purposes:

(a) to analyze the status of use of our Services; and

(b) to distribute ads on our behalf and measure the effectiveness thereof.

With regard to your Personal Data that is processed by a third-party through a module provided by such third party, the privacy policy of such third party will apply.

9.2. Cookie and other analytical tools

A cookie is a small text file that is stored on your computer when visiting a website. This text file stores information that can be read by the website operator when visiting the website again at a later date.

We may use cookies and similar web tracking technologies (web beacon, pixel etc.) for the following purposes:

(a) to store your login state, authenticate visitors, maintain sessions and take security measures;

(b) to store language settings and latest date and time of access, and improve user-friendliness;

(d) to distribute ads that are more interesting to you (*3); and

(e) to measure the effectiveness of ads.

You can control whether or not to accept cookies based on browser settings or by using other tools. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of the website or access all of its functions, which may limit your overall user experience.

9.3. Information related to use of Google Analytics

In order to improve our Services, we use Google Analytics to measure our Services such as our website. Google may set cookies or read existing cookies to collect data. At such time, information such as the URL of the page that you accessed and IP address will be automatically sent to Google. We may use such information to comprehend the status of use of our Services or use such information in our Services. For the processing of data by Google in Google Analytics, please read the service terms of use of Google Analytics and Google’s privacy policy.

9.4. Information related to use of True Depth API provided by Apple

FLAI may use Apple‘s TrueDepth camera to collect additional information from your device‘s camera in order to improve quality of camera and video call that we provide, or improve function such as effects. However, this information is processed in real time for delivering and improving these features only. This information is not saved on our servers or shared with any third parties.

10. Other important information

We may modify this Policy. The latest version of the Policy will always be posted on this site, and we encourage you to review the contents of the latest version of the Policy carefully.

When we make any material changes to this Policy, we will notify you through reasonable means.

Other than as referred to herein, we will be the data controller of Personal Data collected through our Services to which this Policy applies.

If you do not agree to any of the changes and you no longer wish to use our Services, you may choose to close your Account. Continuing to use our Services after a notice of changes has been notified to you or published on our Services constitutes your acceptance of the changes and consent to the modified version of this Policy. We will seek your consent when required under Applicable Laws.

11. Contact Us

If you have any questions, please feel free to contact us at service@flaiapp.com.

End

Date of last update: December 1, 2023