Privacy Policy

1. Our Commitment to Privacy
As we work with you to build better relationships, we are committed to protecting your privacy. For any personal data we collect as part of your journey with us, this Privacy Policy (“Policy”) explains why we collect the data, what we do with the data, and your rights and choices when it comes to your personal data. For the avoidance of doubt, references in this Policy to data, personal information, or information, are all references to personal data.
When you use our mobile application (“App”), access our website at flaresapp.com (“Website”), or interact and communicate with us via our online or social media channels, this Policy will apply to you. For this policy, we will refer to all these touchpoints with you as our services (“Services”).
So we can remain transparent about how we use your personal data, we will notify you when there are significant or material updates to this Policy. This Policy was last updated on April 11th, 2024.
2. Who is collecting your data
You know us as Flares, but as a legal entity we are Geex Arts LLC, a company registered in 30 North Gould Street, Sheridan, WY 82801 (“we”, “our”, “us”) and are the data controller. We decide what personal data is collected from you and how this data will be used.
Our Services may contain links to sites run by our experts and other websites such as Twitter, Facebook, and Instagram. These experts and third-party organisations will have their own privacy policies, which you should read carefully before providing any of your personal data to them, as we do not accept any responsibility or liability for them.
3. How we collect and use your personal data
Identity Information
When you use the App, we collect: your name and a unique user code we supply you with to allow you and your partner to pair your Apps; your device ID so that we are able to identify you as one of our users. We may also collect your email address to allow you to create an account with us.
Personal Information (username, profile photo, etc.)
You may decide to submit a cover photo, profile photo, username, couple anniversary date, and other relationship information in order to personalise your own profile.
We may use this data to improve the level of personalisation of the App and relevance of content for you and your partner. This information is not required in order to use the app.
Activity Information
When you use the App, we collect: your responses to our conversations so that we may share these answers and your progress with you, and your partner where you have chosen to pair your App; information about when you pair with your partner; your course and tip completion so that we may share your progress with you.
You may also choose to share photo or video content, for which you might give us permission to access your camera or photo album.
The responses, answers and photos that you provide to the App are seen by you (and your partner where you have paired your App). Flares may access your responses, answers and photos in an anonymised way for the limited purpose of analysing and understanding how to improve your experience via personalized conversation recommendations, analysis and advice, new features, greater guidance, and improved user-friendliness within the app.
Only after we have anonymised your activity information (so it can never be used to identify you or anyone else), we may use it in the research we engage in with our academic partners to further scientific understanding of how Flares can help relationships. We explain this more in our section on Sharing with our Academic Partners.
Demographic Information
We may present the option for you to provide demographic information so we can provide you with relevant recommendations and tailor the content we provide in the App. Where we do so, we collect personal data such as age, gender, preferences, interests, and lifestyle information.
If you chose to provide us with information for tailoring content in the App which may be considered special category data, such as your sexual orientation, race or ethnicity, or health information, we have done so on the basis of your consent, and you have agreed to it being processed in accordance with this Policy. You may withdraw your consent at any time by deleting your preferences or contacting us at the email address provided at the end of this Policy.
Only after we have anonymised your demographic information (so it can never be used to identify you or anyone else), we may use it in the research we engage in with our academic partners to further scientific understanding of how Flares can help relationships. We explain this more in our section on Sharing with our Academic Partners.
Usage Information
When you use the Services, we collect: your responses to surveys so that we may improve the Services we offer; information about the time you spend and the activities you engage with in the App in order to better understand your needs and preferences and improve the user journey and experience; your IP address in order to know your general location so that we can manage the security of our platforms; and your device ID and email address so that we may communicate with you (via email or push notifications) about the activities you undertake as part of Services.
Support Information
When you use the Services, we collect: your email address when you contact us for support so that we are able to respond to you; your device information so that we can understand and fix technical issues that may occur with our platforms, and other personal data you provide about yourself anytime you contact us for support or general queries.
Subscription and Registration Information
When you subscribe to Flares Premium or register for an account, we collect: the details of your applicable subscription, registration information associated with setting up your account which includes an email address and password. We use your registration information to set up your account and to allow you to backup and restore your activity information.
Marketing Information
When you use the Services, we collect your email address so that we can deliver offers and promotions that may be of interest to you. We may use personal data to market our own products and services, which includes sending you information about Flares updates and features, our newsletter, and discounts on Flares Premium. We may combine your data with data we receive from our advertising partners to send you personalised marketing communications based on criteria, including your interactions with our content, items you view in the app, or information you give us about yourself in your profile.
Technology Information
When you use our Services, we collect and store certain information via the use of technologies such as device identifiers, pixels and cookies. These technologies track information about you and enable us to: (i) remember you when using your computer or device so that we can personalise your user journey and (ii) advertise our Services to you and other relevant audiences. Where we require your consent for these activities, soliciting your consent will be included as part of the information provided in our cookie banner or notice that is displayed when you first access our Services or when we first engage in these activities.
4. Our lawful bases for the use of your personal data
Our references to “lawful bases” are explained below, and we set out the lawful bases for each category of information that we collect from you.
Performance of a Contract with you
When we refer to performance of a contract with you as a legal basis, we refer to those circumstances where we need to use your personal data to comply with our contractual obligations to deliver the services you have engaged us to provide.
Legitimate Interest
When we refer to legitimate interest as a legal basis, we refer to those interests we have in running our business, developing our products and services, delivering and improving our products and services, and ensuring an excellent customer experience in a way which may reasonably be expected and don’t infringe on your rights and freedoms.
Consent
If you provide information that may be classed as special or sensitive (e.g. health or sexual orientation) you consent to processing of that information in accordance with this Policy. You may withdraw your consent by deleting your content and contacting us at the address at the end of this Policy.
Identity Information
Legitimate interest
Personal Information (username, profile photo, etc.)
Legitimate interest
Consent
Activity Information
Legitimate interest
Consent
Demographic Information
Consent in relation to data about your sex life or sexual orientation
Usage Information
Legitimate interest
Support Information
Legitimate interest
Subscription and Registration Information
(a) Performance of a contract with you where you have paid for certain services and/or signed up for an account
(b) Legitimate interest
Marketing Information
Legitimate interest
Technology Information
Legitimate interest
5. Information sharing you control
When your App is paired
We do not share your personal data with your partner but provide you with the ability to initiate this sharing. When you pair your instance of the App with your partner’s instance of the App, you will be exercising your control to share your name and conversations with your partner. While your App is paired, all your conversations will be available for your partner to view until you choose to end the pairing or by deleting your account.

6. Sharing personal data with Service Providers and other Organisations
We never disclose your personal data to advertisers or other third parties for any compensation. However, we share the personal data we collect about you in order to provide our services in the ways described below.
Service Providers
We work with service providers that carry out certain functions on our behalf. These include, for example, companies that help us with network and technology services, payment processing, storing data, analysing data including via artificial intelligence and machine learning, managing mailing campaigns, running our support desk, and managing subscriptions. We only share the personal data necessary to enable our service providers to provide their services.
Sharing personal data with other Organisations
We may share personal data with other organisations in the following circumstances:
-- if the law or a public authority says we must share the personal data;
-- if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to our professional advisors); or
-- to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us.
7. Sharing with our Academic Partners
We partner with academic institutions such as universities to further scientific understanding of how Flares can help relationships. To do this, we generate anonymised information (so you or anyone else can never be identified) from your use of the App, and we share this information with our academic partners so they may analyse it and publish academic papers on how using Flares impacts relationships.
8. How we Protect Your Information and Where we Store it
Flares has physical, electronic, and procedural safeguards that comply with regulations to protect personal information about you. However, data transmissions over the internet cannot be guaranteed to be 100% secure. Consequently, Flares cannot ensure or warrant the security of information you provide over the internet to us.
The personal data we collect may be stored and processed on computers situated outside the United Kingdom or the European Economic Area ("EEA"). These countries may have data protection laws that are different from the laws of your country. If such a transfer or storage outside of the UK or EEA was to happen, this would only be done subject to the implementation of adequate contractual safeguards (e.g., the EU’s Standard Contractual Clauses).
Flares limits access to personal information about you to employees who Flares reasonably believes need to come into contact with that information, to provide products or the Service to you, or in order to do their jobs.
9. How long we use personal data for
Your personal data won’t be kept longer than is reasonably necessary, giving due regard to: initial purpose of collection; age of data; any legal/regulatory reason for us to keep it; and whether needed to protect you or us. We may retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. To determine the appropriate retention period for personal data we consider the amount, nature and sensitivity of personal data, potential risk of harm from unauthorised use or disclosure and the purposes for which we process and whether we can achieve these purposes by other means in addition to the applicable legal and regulatory requirements.
10. Your Data Protection Rights – UK and EEA residents
Below, we set out the rights you have under the UK / EU GDPR in relation to your personal data. Should you wish to exercise any of these rights, please write to us using the information provided under the “How to contact us” section of this Policy.
Subject Access Rights -- You have a right to see the personal data we hold about you and the circumstances of our processing activities.
Right to have inaccurate information corrected -- if you believe we hold inaccurate or missing information, please let us know and we will correct it.
Right to object to our use of your personal data -- We will consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it.
Right to object to direct marketing – where we engage in direct marketing activities (after getting your consent), if you make such an objection, we will stop using your personal data for direct marketing purposes.
Right to restrict our use of your personal data -- you can restrict our use of your personal data, if you have successfully made a general objection, you are challenging the accuracy of the personal data we hold, or we have used your personal data unlawfully -- but you do not want us to delete it.
Right to have your personal data deleted -- you can have us delete your personal data when: we no longer need to keep your personal data; you have successfully made a general objection; you have withdrawn your consent to us using your personal data (where we have relied on consent as the lawful basis for doing so); or we have unlawfully processed your personal data
Right to complain to the data protection regulator -- We’d like the chance to resolve any complaints you have, however you also have the right to complain to the data protection regulator in the UK or EEA country where you receive our product about our use of your personal data. In the UK, the data protection regulator is the ICO and their website is at https://ico.org.uk.
11. Children’s data
Flares does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, do not send any information about yourself to us, including your name, address, telephone numbers, or email address, unless you have your parent's or guardian's permission. Should we become aware that we are processing the personal data of any children, we will delete such personal data as soon as possible in accordance with applicable law.
12. International Privacy Laws
This Policy complements and does not replace applicable national data protection laws. Any applicable national data protection law will supersede this Policy where such law imposes stronger requirements and this Policy shall apply where there are no national data protection laws.
13. Advertising
We may partner with third party ad networks either to display advertising on our Website or Services or to manage our advertising on other sites. Our ad network partner may use cookies and web beacons to collect non-personally identifiable information about your activities on our Website or Services to provide you targeted advertising based upon your interests. To learn more about targeted advertising and advertising networks and about your ability to opt out of collection by certain third parties, please visit the opt-out pages of the Network Advertising Initiative, here, and the Digital Advertising Alliance, here. In addition, if you wish to opt-out of interest-based advertising click here (or, if located in the EU, click here).
Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
14. U.S. State Data Privacy
This section of our Policy contains information required by certain U.S. state data privacy laws. If you reside in California, Colorado, Connecticut, Utah, or Virginia, this section applies to you and supplements the rest of our Policy. Please refer to the state in which you reside to learn more about additional terms and rights that may apply to you.
California
The California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), requires us to provide California consumers with some additional information regarding how we collect, use, and disclose your personal information, and the rights available to California consumers under the CCPA. The terms used in this section have the same meaning as in the CCPA.
As described above in Section 3. How we collect and use your personal data, Flares may have collected the following categories of "personal information" (as that term is defined by the CCPA) about you through our Services within the last 12 months:

Identifiers, such as your name, email address, and username;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information and profile photo;
Commercial information, such as transaction information and purchase history;
Internet or network activity information, such as your browsing history and interactions with our Website;
Geolocation data, such as your approximate location based on your IP address;
Audio, electronic, visual, and similar information, such as video content you may have uploaded;
Your account log-in information i.e., username and password to access your account (if you have a Flares account); and
Inferences drawn from any of the above personal information to create a summary about you, for example your preferences and characteristics.

The sources from which we collect personal information are described in Section 3 of this Policy. The business and commercial purposes for which we collect this information are also described in Section 3. The categories of third parties to whom we disclose this information for a business purpose are described in Sections 6 and 7 of this Policy. The length of time for which we retain personal information is described above in Section 9 of this Policy.
Sales and Sharing of Personal Information
As described above in Section 6, Flares does not sell personal information as the term “sell” is traditionally understood (i.e., for money). However, like many websites and apps, our Services use cookies and other tracking technologies to provide you with a more personalized experience and to advertise our Services to you, if you choose to enable such cookies. The use of such cookies which disclose a California resident’s personal information (which includes IP addresses and cookie IDs) to third party service providers and advertisers may be considered a “sale” of personal information under the CCPA (given its broad definition of "sale"), or a "sharing" of personal information under the CCPA (which is defined as the disclosure of personal information for the purposes of cross-context behavioural advertising). You may opt out of such cookies at any time by adjusting your cookie choices in our cookie banner, or by clicking the "Your Privacy Choices" link in the footer of our Website.
We do not knowingly sell or share personal information of California residents who are under 16 years old.
California Privacy Rights
If you are a California resident, you may have the following rights under the CCPA, subject to certain limitations and exceptions under applicable law:

Know and Access: You have the right to request to know and access the following information covering the 12 months preceding your request:
- the categories of personal information we have collected about you;
- the categories of sources from which your personal information was collected;
- the business or commercial purposes for collecting personal information about you;
- the categories of third parties with whom the business discloses personal information about you; and
- the specific pieces of personal information we have collected about you.

You have the right to receive your personal information in a portable and commonly used format.

Correct: You have the right to request that we correct any of your personal information that we have collected from you that is inaccurate.
Delete: You have the right to request that we delete personal information that we have collected from you.
Opt-Out of Sales and Sharing: You have the right to request that a business not "sell" or "share" your personal information with a third party, as those terms are defined under the CCPA. As described above, Flares uses cookies and other tracking technologies to make available certain personal information to third parties to display personalized ads to you. To the extent that such practice constitutes a “sale” or “share” of personal information under the CCPA, you may opt-out of such “sale” or “share” at any time by using our cookie banner to adjust your cookie choices, or by clicking the ‘Cookie Policy’ link in the footer of our Website, and clicking the "Your Privacy Choices" link to adjust your cookie choices.
Limit the use and disclosure of sensitive personal information: Flares may collect certain "sensitive personal information,” as defined by the CCPA, from you if you choose to provide us with sensitive personal information such as your sexual orientation, race or ethnicity. However, Flares does not use or disclose such "sensitive personal information,” other than for the purposes described in Section 3. "How we collect and use your personal data" above, or as otherwise permitted under applicable law. As a result, we do not offer an ability to limit the use and disclosure of sensitive personal information.
Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights. We shall not discriminate against you for exercising any of your above rights.
You can exercise your right to stop email marketing messages from us at any time by contacting us at [email protected].

Colorado Privacy Rights
The Colorado Privacy Act ("CPA") and its implementing regulations define "consumer" as a Colorado resident who is acting in an individual or household context only, and does not include residents acting in a commercial or employment context. If you are a Colorado "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

Access: You have the right to request to confirm whether we are processing personal data about you and to access such personal data.
Data Portability: You have the right to obtain your personal data in a portable and readily usable format.
Correction: You have the right to request that we correct inaccuracies in the personal data we have collected about you, taking into account the nature of the personal data and the purposes of processing your personal data.
Deletion: You have the right to request to delete your personal data.
Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: As described in the section "Sales and Sharing of Personal Information" above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. However, we do process personal data for the purpose of displaying targeted advertisements, if you instruct us to do so. You have the right to opt out of the processing of personal data for targeted advertising purposes at any time by changing your cookies choices via our cookie banner or via the ‘Cookie Policy’ link in the footer of our website.
Appeal: You have the right to appeal a refusal to take action on your request. You may ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

Connecticut Privacy Rights
The Connecticut Data Privacy Act ("CtDPA") defines "consumer" as an individual who is a resident of Connecticut. If you are a Connecticut "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.
Data Portability: You have the right to obtain your personal data in a portable and readily usable format.
Correction: You have the right to request that we correct inaccuracies in your personal data.
Deletion: You have the right to request to delete the personal data provided by you or obtained about you.
Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: We do not sell personal data to third parties, or process personal data for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. As described in the section "Sales and Sharing of Personal Information" above, we do process personal data for the purpose of displaying targeted advertisements, if you instruct us to do so. You have the right to opt out of the processing of personal data for targeted advertising purposes at any time by changing your cookies choices via our cookie banner or via the ‘Cookie Policy’ link in the footer of our website.
Appeal: You have the right to appeal a refusal to take action on your request. You may ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

Utah Privacy Rights
The Utah Consumer Privacy Act ("UCPA") defines “consumer” as an individual who is a resident of Utah acting in an individual or household context only, and does not include residents acting in a commercial or employment context. If you are a Utah "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.
Data Portability: You have the right to obtain your personal data in a portable and readily usable format.
Deletion: You have the right to request to delete the personal data provided by you or obtained about you.
Opt-out of Data Processing for purposes of Targeted Advertising and Sales to Third Parties: We do not sell Personal Information to third parties. As described in the section "Sales and Sharing of Personal Information" above, we do process Personal Information for the purpose of displaying targeted advertisements, if you instruct us to do so. You have the right to opt out of the processing of personal data for targeted advertising purposes at any time by changing your cookies choices via our cookie banner or via the ‘Cookie Policy’ link in the footer of our website.

Virginia Privacy Rights
The Virginia Consumer Data Protection Act ("VCDPA") defines "consumer" as a Virginia resident who is acting in an individual or household context only and does not include residents acting in a commercial or employment context. If you are a Virginia "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.
Data Portability: You have the right to obtain your personal data in a portable and readily usable format.
Correction: You have the right to request that we correct inaccuracies in your personal data.
Deletion: You have the right to request to delete the personal data provided by you or obtained about you.
Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: As described in the section "Sales and Sharing of Personal Information" above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. However, we do process personal data for the purpose of displaying targeted advertisements, if you instruct us to do so. You have the right to opt out of the processing of personal data for targeted advertising purposes at any time by changing your cookies choices via our cookie banner or via the ‘Cookie Policy’ link in the footer of our website.
Appeal: You have the right to appeal a refusal to take action on your request. You may ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

Making Rights Requests
If you are a resident of one of the above U.S. states and would like to make a request to exercise one of the rights described above, please submit your rights request to [email protected]. To protect the personal data that we maintain, we may verify your identity when you make a request.
In certain states (such as California), an authorized agent may submit a rights request on your behalf. We may require an authorized agent to verify their authority to submit a request on your behalf, or we may require you to verify your own identity or confirm with us that you provided the agent with permission to submit the request. We will only use the information provided for verification to confirm the requestor’s identity or authority to make the request, and for our compliance records.
We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
15. How to contact us
If you have any questions about how we collect, store and use personal data or to exercise any of your rights set out above, please email us at [email protected].