Table of Contents

PRIVACY POLICY

Last Updated: May 1, 2025


This Privacy Policy is designed to help you understand how FlirtaGPT Ltd (collectively with any subsidiaries, called “Company,” “we,” “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.


1. SCOPE

2. CHANGES TO OUR PRIVACY POLICY

3. PERSONAL INFORMATION WE COLLECT

4. HOW WE USE YOUR PERSONAL INFORMATION

5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

6. YOUR PRIVACY CHOICES AND RIGHTS

7. GOVERNING LAW

8. CONTACT US


1. SCOPE

This Privacy Policy applies to personal information processed by us, through our websites, mobile applications, games that we operate, and any other services or interfaces owned or controlled by Company that link to this Privacy Policy (each a “Service” and together, the “Services”). For additional details regarding your use of the Platform and your legal obligations, please also review our Terms of Use available at https://flirtagpt.ai/terms.


2. CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. We encourage you to periodically review this privacy statement to learn how Company is protecting your information. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.


3. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Your Communications with Us. We may collect personal information, such as email address, phone number or mailing address when you request information about our Services, apply for a job or otherwise communicate with us.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services such as:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your browser or device information, location information (including approximate location derived from IP address). We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

Cookies and Other Technologies. We use cookies and similar tracking technologies to collect and use personal information about you, including to serve interest-based advertising. We also utilize analytics providers such as Google Analytics and others to better understand how our Services are used and to enhance user experience. These third-party providers may collect data such as your IP address, usage patterns, and device identifiers, in accordance with their own privacy policies. You can manage your cookie preferences through your browser settings or via any cookie management tools we provide.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications.

C. Information Collected from Other Sources

Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.


4. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and services, as described below.

If your personal information is subject to the General Data Protection Regulation or UK General Data Protection Regulation, our processing of your personal information will be under one of the following lawful bases:

Performance of a Contract. We may process your personal information to carry out our contract with you or to take steps at your request prior to entering into a contract. For further details, see Section 4(A).

Legitimate Interest. We may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms. For a detailed list of our legitimate interests, see Sections 4(B).

Compliance with Legal Obligations. We may process your personal information to comply with our legal obligations as detailed in Section 4(B).

Consent. In some cases, we may also rely on your consent to process your personal information for a specific purpose as detailed in Section 4(C).

A. Processing Necessary for Us to Provide Our Services

We process your personal information to perform our contract with you and provide you with our Services including by:

Managing your information;

Providing access to certain areas, functionalities, and features of our Services;

Answering requests for customer or technical support

and Communicating with you about your activities on our Services, and policy changes.

B. Administrative Purposes

We use your personal information for our legitimate interests, such as:

Conducting network and information security, and fraud prevention;

Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

Measuring interest and engagement in our Services;

improving, upgrading or enhancing our Services;

developing new products and Services;

Ensuring internal quality control and safety;

Authenticating and verifying individual identities;

Debugging to identify and repair errors with our Services;

Auditing relating to interactions, transfers and other compliance activities;

Sharing information with third parties as needed to provide the Services;

Enforcing our agreements and policies;

and Other uses as required to comply with our legal obligations, applicable laws, regulations, regulators and authorities.

C. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information and for which you provide your consent.

D. Other Purposes

We also use your information for other purposes as permitted by applicable law.

De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, information about how you use the Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.


5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

Other Users of the Services and Parties You Transact With. Some of your personal information may be visible to other users of the Services (e.g., information featured on generally accessible parts of the contracts or on a user profile). In addition, to complete transfers via the Services, we will need to share some of your personal information with the party that you are transacting with.

Third Party Websites and Applications. You may choose to share personal information or interact with third-party websites and/or third-party applications, including, but not limited to, third-party electronic wallet extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely read each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that we do not control, and we are not responsible for the third-party websites’ or the third-party applications’ processing of your personal information.

Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, customer service, and related services.

Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.

Affiliates. We may share your personal information with members of our corporate family.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to:

comply with law enforcement or national security requests and legal process, such as a court order or subpoena;

protect your, our, or others’ rights, property, or safety;

enforce our policies or contracts;

collect amounts owed to us;

or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, to the extent permitted by law.


6. YOUR PRIVACY CHOICES AND RIGHTS

The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights. In accordance with applicable law, you may have


7. GOVERNING LAW

Governing Law This Privacy Policy shall be governed by and construed in accordance with the laws of Saint Lucia, without regard to its conflict of law provisions. Any disputes arising from this Privacy Policy will be subject to the exclusive jurisdiction of the courts located in Saint Lucia.


8. CONTACT US

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at [email protected].