Privacy Policy
Flumi (the “App”, “we”, “us” or “our”) is an artificial-intelligence conversational assistant application. This Policy describes how we gather, handle, retain, disclose and safeguard information when you download, open or interact with the App and its related services (the “Services”). It also sets out the choices available to you and the rights you may exercise under applicable law.
Please read this Policy carefully before using the Services. By continuing to use Flumi, you confirm that you have reviewed and accepted the practices outlined below. Should you disagree with any part of this Policy, please stop using the Services.
This Policy applies only to the Flumi mobile application and the Services operated by us. It does not govern information collected independently by third-party websites, accounts or integrations that may be referenced inside the App.
We limit
processing to what is necessary to operate the conversational features you use.
Depending on the functions you choose, the information below may be processed.
This covers the messages you send in a chat, the topic or persona/character settings you configure, prompts you write to steer the reply, preferred language or tone, and any feedback attached to a conversation. These inputs are used to generate and return the AI response you request.
When the App runs, basic diagnostics are collected automatically: device model and operating system version, network type, IP address, approximate country or region inferred from the network, app version, language preference, time zone, session frequency and length, features or buttons touched, crash logs and performance metrics. Advertising identifiers (such as IDFA) are accessed only after you grant the required tracking permission on your device.
We maintain in-app purchase records, subscription status and billing cycle to validate entitlement. We never receive or store your credit card, debit card, bank account or other payment-instrument details; those are handled by the app store through its own secure payment system.
This section
describes the specific rules that apply to the text you send during a
conversation, because these materials are passed to an AI model in order to
produce a reply.
l Model inference: to generate the answer, your
current message and the recent context required for that turn are transmitted
over an encrypted connection to our contracted AI inference service providers,
who act only as processors under our instructions.
l No model training: your chat messages,
transcriptions and generated replies are not used to train, fine-tune or
otherwise improve any artificial-intelligence model. Our AI providers are
contractually prohibited from using such content for training, their own
product development, advertising or marketing.
l Scope of transmission: only the content needed
to complete the requested exchange is sent to the model; we do not forward
unrelated personal data from your device through the same channel.
We process the
categories in Section 2 only for the following purposes:
l Delivering the Services: returning AI replies,
maintaining conversation history on the basis you choose, and linking your
subscription or purchases to the anonymous identifier;
l Operating and stabilizing the App: monitoring
crashes, response times and feature performance, and fixing faults;
l Trust and safety: screening messages and replies
for prohibited material, handling user reports, and enforcing our Terms of
Service;
l Billing and entitlement: verifying subscription
status and purchase validity through the app store;
l Support: answering inquiries, diagnosing
problems and resolving complaints you raise;
l Service improvement: using aggregated,
de-identified statistics to understand which functions are useful;
l Advertising: presenting tailored advertising
only after you grant explicit permission under the applicable platform tracking
framework.
Should we
later wish to use your information for a purpose not covered above, we will
inform you in advance and seek your consent wherever the law so requires.
Flumi does not
trade or sell information that identifies you. Information is shared only under
the limited circumstances below, and recipients are bound by contract to
process it solely on our behalf.
The message
content and context required to answer your question are routed to vetted
large-language-model. These parties process content strictly to return the
requested reply and may not retain it for their own improvement or advertising.
Our
application backend, databases and diagnostic logs are hosted on
enterprise-grade secure cloud platforms selected through a security review.
Hosting providers operate under data-processing agreements that bar independent
use, secondary marketing or unrelated analytics of your data.
All
subscriptions and one-time purchases are processed through the Apple App
Store’s in-app purchase system. Billing matters are subject to the App Store’s
own privacy policy; we do not receive your bank card details.
We may
integrate lightweight third-party software development kits to measure
performance, detect abuse and support marketing. Each such SDK processes
information under its own privacy notice; the list of active SDKs may be
updated as the App evolves.
We may
disclose information when we reasonably believe disclosure is necessary to
comply with an applicable law, regulation, court order or valid governmental
request; to defend our legal rights or property; to protect the safety of
users, third parties or the public; or to detect and prevent fraud, abuse or
security incidents.
Should the
company undergo a merger, acquisition, financing, restructuring, disposal of
assets or insolvency, user information could be transferred along with the
transaction; the new holder must maintain protection standards that are at
least as strong as the commitments set out here.
The App may
contain links to services we do not own or control. These third parties operate
under their own privacy rules, for which we assume no responsibility; our
Policy does not extend to them, so you should read their notices before
disclosing any data.
Flumi is
operated on a global basis. Depending on where you live, information described
in this Policy may be transferred to, stored and processed on servers located
outside your country or region, including cloud data centers in other
jurisdictions.
Before such a
cross-border transfer, we put safeguards in line with applicable
data-protection rules in place—such as standard contractual clauses or
equivalent approved transfer mechanisms—to keep the protection level consistent
with the standard required where your data originates.
We keep
personal information only for as long as it is needed to deliver the Services
or to meet a legal obligation:
l Conversation content associated with your
installation instance is saved on your device or within our systems, and
persists until you delete the session;
l Report records and safety-related content may be
retained longer where necessary to investigate a report, enforce our rules or
comply with law;
l Technical and usage diagnostics are kept for a
limited, rotating period and then deleted or aggregated into non-identifiable
statistics.
After the
retention period expires, data is deleted or de-identified.
We use
administrative, technical and organizational measures appropriate to the
sensitivity of the information, including encryption of data in transit, strict
access control, internal logging and regular security reviews, to guard against
unauthorized access, disclosure, alteration or loss. Because no electronic
transmission or storage method can be guaranteed completely secure, we cannot
promise absolute safety; should a personal-data breach occur, we will act to
mitigate it and notify affected authorities or users where required by law.
Replies you
receive are generated automatically by artificial-intelligence models and may
be incomplete, outdated, biased or factually incorrect, even when they appear
confident. Flumi replies are not professional advice in fields such as medical
care, legal matters, finance, mental health or emergency response; please
consult a qualified professional before relying on any such answer. You are
responsible for evaluating whether to act on information obtained from the App.
You agree not
to provide, upload or request generation of content that:
l Shows non-consensual intimate imagery, or sexual
deepfakes of a real person produced without consent;
l Contains pornography or explicit sexual material
where prohibited by law;
l Promotes violence, terrorism, organized crime or
other illegal activity;
l Constitutes hate speech or harassment directed
at protected groups or individuals;
l Encourages self-harm, suicide or dangerous acts
that threaten life and health;
l Infringes copyright, trademark, privacy or other
lawful rights of a third party;
l Contains deceptive, fraudulent or malicious
material.
To preserve a
safe environment, we may run automated checks on submitted messages, prompts
and replies, and review user reports through our moderation team. Content that
violates this Policy or applicable law, together with the associated anonymous
identifier and report record, may be retained beyond the ordinary deletion
period while the matter is investigated. We may remove violating content,
suspend or restrict relevant features, or terminate access for serious or
repeated violations; where required by law, we report material involving the
sexual exploitation of minors to competent authorities (such as NCMEC in the
United States).
The rights
listed below depend on the law of the region in which you reside. Users based
in the EEA, the United Kingdom or Switzerland are protected under the GDPR, UK
GDPR and the revised Swiss FADP; residents of California may rely on rights
granted by CCPA/CPRA and other state legislation in force.
l Access: ask for the personal data we maintain on
your account and receive a copy.
l Correction: request that inaccurate or
incomplete information be fixed.
l Deletion: ask us to remove your personal
information where permitted by law.
l Withdraw consent: if a step relies on your
consent, you are free to revoke it at any moment; earlier processing completed
before that revocation stays lawful.
l Data portability: receive your data in a
structured, common, machine-readable format where applicable.
l Object or restrict: object to, or ask us to
restrict, certain processing in the circumstances allowed by law.
l Opt out of sale or cross-context advertising:
our current practices do not sell personal information or share it for
cross-context behavioral advertising as defined under CCPA/CPRA; should these
practices change, we will provide the corresponding opt-out mechanism.
Platform-level
choices:
l Tracking permission: under the iOS App Tracking
Transparency framework, we request your explicit permission before tracking
across apps and websites owned by others for advertising. You may change this
choice at any time in device Settings.
l Device permissions: you may enable or revoke
microphone, photo library, camera or notification access in your system
settings at any time; revocation only limits the related feature.
l In-app deletion: you can delete individual
conversations inside the App at any time.
To make use of
these rights, reach out through the contact information in Section 12. Before
answering we may confirm who you are; our reply follows the legal timeframe,
and you will not be treated differently for having exercised your rights.
The Services
are not aimed at users below 18 years of age (or the older threshold set by
certain regions), and we never collect minors' data intentionally. If you
reside in the EEA, the United Kingdom or Switzerland, the statutory age laid
down by your local data-protection law governs (16 years, except where local
law explicitly allows a lower threshold). Should we discover that an underage
user has submitted personal information, it will be removed without delay.
Parents or guardians who believe a child has sent us information may contact us
to have it deleted.
We may revise
this Policy as the Services, legal requirements or our practices evolve. For material changes that affect how
your information is processed, we will provide an in-app notice before the new
terms take effect. Your continued use after the revised Policy becomes
effective means you accept the updated version.
For any
questions, comments or demands related to this Policy or the way we handle
data, or to file a rights request, reach us at:
Email: [email protected]
A reply will
be sent to you within the timeframe laid down by the applicable law.