Privacy Policy

1. Who we are

flaim is a mobile application (the App) operated by EQUIIS Technologies Switzerland AG, a company incorporated in Switzerland , whose registered office is at Technoparkstrasse 1, 8005, Zurich, Switzerland www.EQUIIS.com (flaim, we, us, our).
The App is designed to allow users of the App (user, you, your) to:
● send secure one to one text messages;
● secure one to many text messages;
● make secure one to one calls;
● two-way burning of messages; and
● make secure conference calls with up to fifteen people;
(the Services).

The extent of the Services available to you will depend on the country in which your mobile service provider is established.

This policy describes how we use your personal information.

Your trust in us

When you use flaim, you trust us with your information. There are many ways this information can help us make the Services better. We can make sure you only see offers/products in which you're likely to be interested. We can remember your details so it's easier for you to use the Service/App.

But we respect your privacy and we value the trust you've placed in us by sharing your information. This privacy policy sets out the way we use your information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled.

We have tried to keep this document as clear and direct as possible. However there are contact details at the end of this policy if you have any questions or if anything is unclear.

2. Your information

Data Collection and Usage

We will collect and use your personal information to allow to register / subscribe use the App and our Services and for purposes set out in more detail in this section.

Your information may be shared with some third parties including your mobile service provider.

What we collect

Information that you share with us when you use the Services and you set up the App. For example, we need to collect your name and telephone number to set up the App.  However, to make it easier for others to find you, we may also ask you to provide us with some additional information that will be publicly visible on the App, such as:
• Your profile picture;
• Your gender;
• Your date of birth;
• Your geographical location.
You will also provide us whatever information you send using the App  or our other Services.

1

Information about the way you use the Services and our App including:
• Whether you've opened electronic communications from us;
• Whether you've clicked on links in electronic communications from us;
• Whether you have viewed or clicked on any of the products advertised on the App;
• How you interact with the App;
• How you communicate with other users of the App;
• [Content information ]

2

Information when you communicate with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including:
• Your contact details (this may include your social media account if that's the way you communicate with us);
• The details of your communications with us;
• The details of our messages to you.

3

[Information provided as part of your use of the App including:
• [Your telephone number
• Your username;
• Your password;
• Your account settings;
• Your account preferences;
• Your email address;
•  Your device phonebook - with your permission

4

Information that we collect through your use of the App including:
• Device information  such as operating system, unique device identifiers, the mobile network system advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level and time zone.
• Information from device sensors, such as accelerometers, gyroscopes, compasses, microphones and headphone connection.
• Information about your wireless and mobile network connections, such as mobile phone number, service provider and signal strength;
• Hardware and browser settings;
• Date and time of requests;
• The requests you make;
• The pages you visit and search engine terms you use;
• IP address;
• With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points and other sensors, such as gyroscopes, accelerometers and compasses.

5

Information that we collect from third party partners which could include:
• [Other entities in our group];
• [Publicly available sources such as the electoral roll];
• [Other users of the App i.e. if another user allows us to access their device phonebook].
• [Advertisers who may let us know you installed a new app or game or share information with us regarding adverts you may have viewed.]

6

7

Information that we collect incidentally from other sources or public sources, including:
• [Information available in the media];
• [Information presented on our social media timelines];
• [Information collected by security systems].

We use this information, including to:
• [Maintain market awareness];
• [Build and maintain social media branding];
• [Provide security to our systems].

We use this information because:
• We have a legitimate business interest in maintaining a public profile and being in both traditional and social media;
• We have a legitimate business interest in providing security over our business.

We will keep this for:
• Information relating to media awareness and social media, for as long as the information is publicly available;
• Information collected incidentally by security systems we will keep this for as long as reasonable in accordance with [our security policy].

We use this information, including to:
• Provide the Services;
• Manage and administer our systems;
• Help us ensure that our customers are genuine and to prevent fraud;
• Personalise the Service;
• Statistical analysis and research into our users;
• Combine this information with other types of information mentioned above.
• To help target or measure the performance of adverts on the App. You can learn more about these types of adverts [here].

We use this information because:
• It is necessary to verify details to meet legal and regulatory requirements for identifying our users;
• It is necessary in the public interest that we can verify identities and prevent fraud;
• We have a legitimate business interest in receiving information from other entities in our group/[other users of the Apps] about shared users;
• We have a legitimate business interest in understanding our user base.

We will keep this for:
• Information relating anti-fraud measures, so long as you continue to use the Services and the App [and six years after,]   in case there are any issues.
• Information relating to statistical analysis, a reasonable length of time to help us better understand our user base over time. [This will not be longer than two years, but may be routinely refreshed.]

We use this information, including to:
• Provide the Services;
• Develop new services;
• Improve the Services and the App;
• Identify issues with the App and user's experience of it;
• Monitor the way the App is used.

We use this information because:
• We have a legitimate business interest in understanding how the App is accessed, how it is used and any problems users have with it [across multiple devices.]
• [security monitoring?]

We will keep this information for:
• A reasonable length of time that lets us understand how people use our website and any technical issues they have. [This will not be longer than three years.]

We use this information, including to:
• Provide the Services;
• Manage and administer our systems;
• Identify how you'd like to use your App;
• Connect you with other users of the App.

We use this information because:
• It is necessary to provide a user account;
• We have a legitimate business interest in enabling you to update your preferences and settings online;
• We have you consent to look for other users that you may know.

We will keep this information for:
• As long as you have [an account with us] / [continue to use the App]  and six years after, in case there are any issues.]

We use this information, including to:
• Answer any issues or concerns;
• Monitor user communications for quality and training purposes;
• Develop new services;
• Improve the Services and our App;
• Personalise the Services and the App;

We use this information because:
• We have a legitimate business interest in understanding user feedback and in responding to user communications in a consistent way.

We will keep this information for:
• So long as you continue to use the Services and the App [and six years after,]  in case there are any issues

We use this information, including to:
• Develop new services;
• Improve the Services and the functionality of the App;
• Identify products and marketing that may be of interest to you;
• Personalise the App and the Services based upon things you're interested in and how you use the Services;
• Statistical analysis and research.

We use this information because:
• We have a legitimate business  interest to improve the Service and our App and better understand how users use it.

We will keep this information for:
• A reasonable length of time that lets us understand how people use the Services and the impact of any changes we make to the Services or the App. [This will not be longer than three years.]

We use this information, including to :
• Provide the Services;
• Manage and administer the Services and the App;
• Help us ensure that our users are genuine and to prevent fraud;
• Send personalised offers;
• Help you connect with other App users.

We use this information because:
• It's necessary to perform the contract.
• [insert other purposes]

We will keep this information for:
• So long as you continue to use the Services and the App [and six years after,]  in case there are any issues.

How we use it

Why we use it

How long we keep it

1.
What we collect

Information that you share with us when you use the Services and you set up the App. For example, we need to collect your name and telephone number to set up the App.  However, to make it easier for others to find you, we may also ask you to provide us with some additional information that will be publicly visible on the App, such as:
• Your profile picture;
• Your gender;
• Your date of birth;
• Your geographical location.
You will also provide us whatever information you send using the App  or our other Services.

How we use it

We use this information, including to :
• Provide the Services;
• Manage and administer the Services and the App;
• Help us ensure that our users are genuine and to prevent fraud;
• Send personalised offers;
• Help you connect with other App users.

Why we use it

We use this information because:
• It's necessary to perform the contract.

How long we keep it

We will keep this information for:
• So long as you continue to use the Services and the App [and six years after,]  in case there are any issues.

2.
What we collect

Information about the way you use the Services and our App including:
• Whether you've opened electronic communications from us;
• Whether you've clicked on links in electronic communications from us;
• Whether you have viewed or clicked on any of the products advertised on the App;
• How you interact with the App;
• How you communicate with other users of the App.

How we use it

We use this information, including to:
• Develop new services;
• Improve the Services and the functionality of the App;
• Identify products and marketing that may be of interest to you;
• Personalise the App and the Services based upon things you're interested in and how you use the Services;
• Statistical analysis and research.

Why we use it

We use this information because:
• We have a legitimate business  interest to improve the Service and our App and better understand how users use it.

How long we keep it

We will keep this information for:
• A reasonable length of time that lets us understand how people use the Services and the impact of any changes we make to the Services or the App. [This will not be longer than three years.]

3.
What we collect

Information when you communicate with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including:
• Your contact details (this may include your social media account if that's the way you communicate with us);
• The details of your communications with us;
• The details of our messages to you.

How we use it

We use this information, including to:
• Answer any issues or concerns;
• Monitor user communications for quality and training purposes;
• Develop new services;
• Improve the Services and our App;
• Personalise the Services and the App.

Why we use it

We use this information because:
• We have a legitimate business interest in understanding user feedback and in responding to user communications in a consistent way.

How long we keep it

We will keep this information for:
• So long as you continue to use the Services and the App [and six years after,]  in case there are any issues.

4.
What we collect

Information provided as part of your use of the App including:
• Your telephone number
• Your username;
• Your password;
• Your account settings;
• Your account preferences;
• Your email address;
• Your device phonebook - with your permission

How we use it

We use this information, including to:
• Provide the Services;
• Manage and administer our systems;
• Identify how you'd like to use your App;
• Connect you with other users of the App.

Why we use it

We use this information because:
• It is necessary to provide a user account;
• We have a legitimate business interest in enabling you to update your preferences and settings online;
• We have you consent to look for other users that you may know.

How long we keep it

We will keep this information for:
• As long as you have [an account with us] / [continue to use the App]  and six years after, in case there are any issues.

5.
What we collect

Information that we collect through your use of the App including:
• Device information  such as operating system, unique device identifiers, the mobile network system advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level and time zone.
• Information from device sensors, such as accelerometers, gyroscopes, compasses, microphones and headphone connection.
• Information about your wireless and mobile network connections, such as mobile phone number, service provider and signal strength;
• Hardware and browser settings;
• Date and time of requests;
• The requests you make;
• The pages you visit and search engine terms you use;
• IP address;
• With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points and other sensors, such as gyroscopes, accelerometers and compasses.

How we use it

We use this information, including to:
• Provide the Services;
• Develop new services;
• Improve the Services and the App;
• Identify issues with the App and user's experience of it;
• Monitor the way the App is used.

Why we use it

We use this information because:
• We have a legitimate business interest in understanding how the App is accessed, how it is used and any problems users have with it [across multiple devices.]

How long we keep it

We will keep this information for:
• A reasonable length of time that lets us understand how people use our website and any technical issues they have. [This will not be longer than three years.]

6.
What we collect

Information that we collect from third party partners which could include:
• [Other entities in our group];
• [Publicly available sources such as the electoral roll];
• [Other users of the App i.e. if another user allows us to access their device phonebook].
• [Advertisers who may let us know you installed a new app or game or share information with us regarding adverts you may have viewed.]

How we use it

We use this information, including to:
• Provide the Services;
• Manage and administer our systems;
• Help us ensure that our customers are genuine and to prevent fraud;
• Personalise the Service;
• Statistical analysis and research into our users;
• Combine this information with other types of information mentioned above.
• To help target or measure the performance of adverts on the App.

Why we use it

We use this information because:
• It is necessary to verify details to meet legal and regulatory requirements for identifying our users;
• It is necessary in the public interest that we can verify identities and prevent fraud;
• We have a legitimate business interest in receiving information from other entities in our group/[other users of the Apps] about shared users;
• We have a legitimate business interest in understanding our user base.

How long we keep it

We will keep this for:
• Information relating anti-fraud measures, so long as you continue to use the Services and the App [and six years after,]   in case there are any issues.
• Information relating to statistical analysis, a reasonable length of time to help us better understand our user base over time. [This will not be longer than two years, but may be routinely refreshed.]

7.
What we collect

Information that we collect incidentally from other sources or public sources, including:
• [Information available in the media];
• [Information presented on our social media timelines];
• [Information collected by security systems].

How we use it

We use this information, including to:
• [Maintain market awareness];
• [Build and maintain social media branding];
• [Provide security to our systems].

Why we use it

We use this information because:
• We have a legitimate business interest in maintaining a public profile and being in both traditional and social media;
• We have a legitimate business interest in providing security over our business.

How long we keep it

We will keep this for:
• Information relating to media awareness and social media, for as long as the information is publicly available;
• Information collected incidentally by security systems we will keep this for as long as reasonable in accordance with [our security policy].