Privacy Policy

1. Data Controller

The entity responsible for processing your personal data is:

2. Data We Collect

We collect only the data necessary to operate the FLARE app. The following categories of data may be processed:

2.1 Account Data

2.2 User-Generated Content

• Photos you submit to trends and battles. These are stored on our servers and shown publicly within the app.
• Votes (Flares) you cast on other users' photos.

2.3 Location Data

FLARE uses location in three clearly separated ways. We collect location only while the app is open (When In Use permission); we do not track your location in the background. You can switch location access off in your iOS Settings at any time.

• Your approximate location is used to assign you to a city, region and country (for local rankings) and to show local content. While the app is open, it is refreshed from time to time (when you moved about 500 m or after about 30 minutes). We store only your last known location with your account. Other users cannot see it in your profile or in lists.
• The location of a photo. The location of a photo is part of how FLARE works. When you upload a photo, the position at the moment of the upload is saved once with that photo (without it, a photo cannot be uploaded; you can still browse and vote). Your accepted friends see the exact upload location on the map and can push the photo there. All other users see the photo on the map only at an approximate location (rounded to a grid of about 1 km), never the exact spot, and they cannot push it. The location is not shown in public lists or in rankings, and it is never your live position. When you delete a photo or your account, its location is erased.
• Local push. A friend who is near a photo’s upload location (within about 1 km) can push it. To check this, the app sends the friend’s current position once when pushing; we compare it with the photo’s location, store it only to prevent abuse and delete it when the photo or the account is deleted. The owner of the photo sees that a friend pushed it, but not where that friend was.

2.4 Device & Technical Data

• Device type and operating system version
• App version
• Crash logs and error reports (for debugging purposes only)
• IP address (logged temporarily for security rate-limiting)

2.5 Usage Data

• Battles viewed and votes cast (aggregated for ranking algorithms)
• Trends you browse or participate in
• Session activity for app functionality and abuse prevention

2.6 Purchase Data

If you purchase a Premium subscription, transaction receipts are processed via Apple App Store / Google Play and validated server-side through RevenueCat. We do not store full payment card details. Your subscription status is stored.

2.7 Advertising Data (optional)

If you consent to ad tracking via Apple's App Tracking Transparency (ATT) prompt, Google AdMob may collect your Advertising Identifier (IDFA) for personalized ads. If you decline, you will still see ads, but they will not be personalized. See Section 5 for full details.

3. Purpose & Legal Basis

4. Third-Party Services

We use the following third-party services that may process your data:

We do not sell your personal data to any third party. Data shared with third parties is limited to what is strictly necessary for the stated purpose.

5. Advertising & Tracking (ATT)

FLARE is free to download and is supported by advertising via Google AdMob. On iOS 14.5+, Apple requires us to request your permission before accessing your device's Advertising Identifier (IDFA) for personalized ads. This is done via Apple's App Tracking Transparency (ATT) framework.

If you grant permission:

• AdMob may use your IDFA to show personalized, interest-based ads.
• Ad performance may be measured across apps and websites.

If you decline (or on Android where ATT is not applicable):

• You will still see ads, but they will be contextual and non-personalized.
• Your IDFA will not be used for ad targeting.

AdMob may still collect certain non-identifying information (e.g., general device type, approximate location at country level) for fraud prevention and aggregated reporting, regardless of your ATT choice. See Google's Privacy Policy for details.

6. Data Retention

You can request deletion of your account at any time from within the app (Profile → Settings → Delete Account) or by contacting flare@safer.network.

7. International Data Transfers

Our primary backend infrastructure is hosted in the EU. However, some third-party services (Google AdMob, RevenueCat) are based in the United States. Data transfers to these providers are governed by Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an adequate level of data protection.

8. Your Rights (GDPR)

As a data subject under the GDPR, you have the following rights. You can exercise any of these by contacting us at flare@safer.network:

• Right of access (Art. 15) — Request a copy of all personal data we hold about you.
• Right to rectification (Art. 16) — Request correction of inaccurate data.
• Right to erasure / "right to be forgotten" (Art. 17) — Request deletion of your data.
• Right to restriction of processing (Art. 18) — Request that we limit how we use your data.
• Right to data portability (Art. 20) — Receive your data in a structured, machine-readable format.
• Right to object (Art. 21) — Object to processing based on legitimate interests.
• Right to withdraw consent (Art. 7(3)) — Withdraw any consent you have given (e.g., ATT) at any time without affecting prior processing.

You also have the right to lodge a complaint with a supervisory authority. In Germany, the competent authority is:

9. Children's Privacy

FLARE is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has created an account, please contact us immediately at flare@safer.network and we will delete the account and associated data promptly.

Users between 13 and 16 years of age in the EU may require parental consent under applicable national laws.

10. Changes to this Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by displaying a notice in the app or by email. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of FLARE after changes constitutes acceptance of the updated policy.

11. Contact & Data Requests

For any privacy-related questions, data access requests, or account deletion requests: