Welcome to the Fluster Privacy Policy (“Policy”)! This explains how we collect, store, and protect your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.

Whilst you’re enjoying the Fluster mobile application (including the desktop version) (“App”), our websites and microsites (such as Fluster.co) or using our digital products and services (such as our competitions or surveys) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”).

The App and Sites are global, and your information will be sent to and used in the United States and the UK regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

The App and Sites are operated by the “Fluster.co” (also referred to in this policy as “we” or “us”) all of which are controllers of personal information collected and processed through the Fluster App and Sites.

Registration Information
When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

Login information for social media accounts that you connect to your Fluster Account (this could include, for example, your Facebook and Instagram accounts). For more information about this, see “Linking other Accounts to Fluster” in section 7 below.
Once you register, you will be able to review and change this information at any time just by logging in to Fluster (other than your date of birth and location (which, if you have given Fluster access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

A. Identifiers, such as name and location;
B. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
D. Commercial information, such as transaction information and purchase history;
E. Biometric information;
F. Internet or network activity information, such as browsing history and interactions with our Sites and App;
G. Geolocation data, such as mobile device location;
H. Audio, electronic, visual and similar information, such as photos and videos;
I. Professional or employment-related information, such as work history and prior employer;
J. Non-public education information; and
K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on Bumble.

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake Fluster accounts being created which can be used for malicious activities and cybercrime – they threaten the Fluster and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Fluster uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Fluster to contest the decision.

Please note that if your account is blocked for any reason, any account(s) that you have on other Fluster may also be blocked as part of our anti-spam and anti-fraud procedures.

If you have given Fluster access to your location in your device settings, when you use your cell, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Fluster access to your location, but wish to turn this off, you can do so by the following methods:
iPhone app — settings, privacy, location services, Fluster
Android — settings, location, Fluster, permissions, location

We may collect information about your device when you use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

We also collect data about your photos, such as which are the photos that users spend time on or which are the photos that have the best lighting, etc. We may use that data to rearrange your profile photos aiming to position them in a way that is favorable to you. You may opt-out of this feature through our app settings.

We may keep track of how you interact with links available on Fluster including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users. We will take steps to remove personally identifying information from such messages, prior to reviewing them. We will not share the content of User messages or information we derive from them with any third party.

From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact you to ask if you would be happy to feature in advertising for Fluster). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team.

If you contact our Customer Support team via our Feedback Page, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognize and remember you.

Our main goal is to ensure your experience on Fluster is an enjoyable one. In order to deliver an enjoyable experience to you, we may use your Registration and other information to:
offer you our services and features;
contact you with information about the App (e.g., updates and new features);
personalize the App/Sites and the content we deliver to you;
conduct research and analytics about how you use and interact with the App/Sites;
to test new technologies and processes designed to enhance and improve the App/Sites;
resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
to send you information about the promotions and offers we have available (e.g., specify the types of goods/services/offers to be provided via direct marketing) by direct marketing or other modes of communication - if you’ve signed up for our communications or otherwise told us it’s OK. We will not use your information in email direct marketing unless you give us your consent during the Account creating process or via Settings in the App (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and protect our Users and third parties from harm.

We have developed matching algorithms to predict your compatibility with other users and so we can show you people we think are a good match for you. Our matching algorithms use the following data about you to predict your compatibility with others and generate profile recommendations: the things you tell us about yourself in your profile; information about your activity in our apps; whether you are a photo verified user; and your device coordinates, which are necessary to understand your proximity to other members. The legal basis for processing profile and proximity information is that this is necessary for the provision of our contractual services to you pursuant to Article 6(1)(b) GDPR. Where we process information about your app activity, this is based on our legitimate interests pursuant to Article 6(1)(f) GDPR, and specifically our legitimate interest in generating more personalized and relevant recommendations for who you can match with in our App. If you have chosen to include sensitive information in your profile, such as information about your beliefs, the processing of this information is based on your voluntary and explicit consent.

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact Fluster to contest the decision.
If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time.

Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like” function), we are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that Bumble has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights.

We partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example: to exclude you from advertising campaigns aimed at finding new users, if you already have a Fluster account;
to show Fluster adverts to users who have visited the Fluster App/Sites but haven’t yet created a Fluster account;
to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
to include you in a ‘custom audience’ that will receive Fluster advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).
We share a limited amount of your personal data with these Marketing Services Providers, such as:
the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you)) your estimated location (based on your IP address) age and gender data about your visit to our Sites or App and action taken on those (for example if you downloaded our App, created an account with our App, or details of any purchases made on Site or in App) a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters - this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

We have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.
When using the Fluster App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.
Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself to your profile, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Fluster may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.
Your Fluster profile and other information you make available via the App, including certain information added to your profile through third party accounts may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use Fluster.
Fluster does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

At Fluster, we take all appropriate security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure: Please make sure you log out of your Account after use as you never know who may stumble onto your Account! Please don’t share the password you use to access your Fluster Account with anyone else! Change your password periodically. If you ever think someone has had access to your password or Account, please follow the steps set out here. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

For Users who are California residents, you have the following rights (in addition to those listed at section 10 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at support@fluster.com.
From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.

Privacy laws applicable in your country may give you the following rights: Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.
The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law. Please see “Profile Verification Information (Including Biometric Information)” to learn about our retention policy with respect to biometric information.
When your Account is deleted, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted. After 28 days, we begin the process of deleting your personal information from our systems, unless:
we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);
we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behavior that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).
Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

As Fluster evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Fluster.

Effective date
This Privacy Policy was last updated November 10th, 2023.