Privacy Policy

1. Introduction and Scope

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.

2. Categories of Information We Process

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.

2.1 Conversational Content You Submit

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.

2.2 Automatically Collected Technical and Usage Data

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.

2.3 Subscription and Purchase Records

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.

3. Special Handling of Chat and AI Inference Content

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.

4. Purposes of Processing

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.

5. Sharing, Disclosure and Third-Party Services

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.

5.1 AI Inference Providers

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.

5.2 Cloud and Hosting Infrastructure

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.

5.3 Payment Channel

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.

5.4 Analytics and Advertising SDKs

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.

5.5 Legal Compliance and Safety

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.

5.6 Business Reorganization

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.

5.7 External Links

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.

6. International Data Transfers

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.

7. Data Retention and Security

7.1 Retention Period

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.

7.2 Security Measures

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.

8. Generative AI Notice and Content Safety

8.1 About AI-Generated Replies

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.

8.2 What You Must Not Submit or Request

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.

8.3 Moderation and Enforcement

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).

9. Your Privacy Rights and Choices

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.

10. Children’s Privacy

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.

11. Updates to This Policy

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.

12. Contact Us

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.