PRIVACY POLICY

1. INFORMATION WE COLLECT

• Account data: name, email address, password (hashed), profile photo
• Usage data: lessons completed, quiz results, learning streaks, session duration
• Device data: device type, OS, browser, IP address, unique device identifiers
• Payment data: processed by Paddle (our Merchant of Record). We do not store full card details.
• Communications: support messages, feedback, survey responses

2. HOW WE USE YOUR DATA

We use your data to: provide and improve the Service; personalize your learning experience; send transactional emails (receipts, password resets); send marketing communications (with your consent); comply with legal obligations; and prevent fraud and abuse.

3. LEGAL BASIS FOR PROCESSING (EEA/UK)

We process your data under the following legal bases: contract performance (to deliver the Service), legitimate interests (product improvement, security), consent (marketing communications), and legal obligation.

4. SHARING YOUR DATA

We do not sell your personal data. We may share data with: service providers (hosting, analytics, customer support tools) under data processing agreements; Paddle (payment processing); law enforcement when legally required; and in connection with a merger or acquisition (with prior notice).

5. INTERNATIONAL TRANSFERS

Flutterby operates globally. Your data may be transferred to and processed in countries outside your own, including Singapore and the United States. We use standard contractual clauses and other safeguards to protect cross-border transfers.

6. DATA RETENTION

We retain your data for as long as your account is active or as needed to provide the Service, comply with legal obligations, or resolve disputes. You may request deletion at any time.

7. YOUR RIGHTS

Depending on your location, you may have the right to: access, correct, or delete your data; restrict or object to processing; data portability; and withdraw consent. To exercise these rights, email privacy@flutterby.co. EEA/UK users may also lodge a complaint with their local data protection authority.

8. COOKIES

We use essential, analytics, and preference cookies. You can manage cookie preferences via our cookie banner. We honor Do Not Track signals.

9. SECURITY

We implement industry-standard security measures including encryption in transit (TLS) and at rest. No method of transmission over the internet is 100% secure.

10. UPDATES

We may update this policy periodically. We will notify you of material changes via email or prominent notice in the app.

11. CONTACT

Data controller: Flutterby Labs Private Limited
Privacy enquiries: privacy@flutterby.co