Last Updated: November 2025Egger AI Studio ("we," "us," or "our") operates the FlirtyIQ mobile application (the "App"). We are committed to protecting your privacy and complying with applicable data protection laws, including:- General Data Protection Regulation (GDPR) - European Union & United Kingdom
- California Consumer Privacy Act (CCPA) & California Privacy Rights Act (CPRA) - USA
- Federal Act on Data Protection (FADP) - Switzerland
- Personal Information Protection and Electronic Documents Act (PIPEDA) - Canada
- Privacy Act 1988 - AustraliaThis Privacy Policy explains what information we collect, how we use it, with whom we share it, and your rights regarding your personal data.🏢 Data Controller InformationEgger AI StudioEmail: [email protected]Location: Route de la Pierre 20B, 1024 Ecublens, SwitzerlandEU Representative: If required under GDPR Article 27, we will appoint an EU representative. Currently, as we do not systematically target EU users, this may not be required. EU users may contact us directly at the above email address.1️⃣ Information We Collect## A. Information You Provide Directly- Chat Content & Analysis Inputs: Text, conversation screenshots, or other content you upload for AI-powered analysis
- Account Information: Optional username, email address (if you choose to create an account or contact support)
- Support Communications: Messages, feedback, or inquiries you send to our support team## B. Information Collected Automatically- Device Information: Device model, operating system (iOS/Android), OS version, app version, language settings
- Usage Analytics: Features used, session duration, interaction patterns, error logs, crash reports
- Subscription Status: Active subscription tier (Free vs. Magnetic +), renewal statusWe do NOT collect: Precise geolocation, advertising IDs (IDFA/GAID), biometric data, or contact lists.## C. Payment InformationPayments are processed entirely by Apple App Store or Google Play Store. We do not collect, store, or process credit card numbers, bank account details, or other payment credentials.We receive only non-sensitive transaction receipts (subscription confirmation, renewal status, cancellation notifications) necessary for account management.2️⃣ How We Use Your InformationWe use your information for the following purposes, with corresponding legal bases under GDPR:- Provide AI Analysis Services: Process your inputs to generate flirt analysis and suggestions (Legal Basis: Contract Performance)
- Improve App Functionality: Analyze usage patterns, fix bugs, enhance features (Legal Basis: Legitimate Interest)
- Manage Subscriptions: Process payments, handle renewals, verify subscription status (Legal Basis: Contract Performance)
- Security & Fraud Prevention: Detect and prevent misuse, abuse, or unauthorized access (Legal Basis: Legitimate Interest)
- Customer Support: Respond to your inquiries and resolve issues (Legal Basis: Contract Performance)
- Legal Compliance: Comply with applicable laws, regulations, court orders (Legal Basis: Legal Obligation)
- Optional Communications: Send product updates, feature announcements (only with your explicit consent - Legal Basis: Consent)We do NOT sell, rent, or trade your personal data for marketing purposes.3️⃣ AI Processing & Third-Party ProvidersAI Service Provider: We use OpenAI (ChatGPT API / GPT-4) to power the AI analysis features in FlirtyIQ. OpenAI's servers are located in the United States.Data Processing: When you submit content for analysis:- Your input is securely transmitted to our AI provider's servers
- The AI generates analysis and returns results to your device
- Neither we nor our AI provider store your chat content permanently
- Inputs are processed temporarily only to generate responsesNo Training on Your Data: Your personal content is NOT used to train AI models unless you explicitly opt-in to a research program (which we do not currently offer).Automated Content Filtering: We may use automated filters to detect abusive, harmful, or illegal content to protect service integrity and comply with legal obligations.Third-Party Privacy Policies: For more information on how OpenAI handles data, please review their privacy policy at https://openai.com/policies/privacy-policy. Note: OpenAI's data retention policies state that API data is retained for 30 days for abuse monitoring, then deleted (unless you opt into longer retention for model improvements, which we do NOT do on your behalf).4️⃣ Data Storage & Retention## 🔒 Local-First ArchitectureFlirtyIQ is designed with privacy by default. We do NOT operate a central server that stores your conversations or personal data.- Local Storage: All conversation history, AI analysis results, and preferences are stored locally on your device using secure local storage (encrypted where supported by the operating system)
- No Cloud Backup: We do not automatically back up your data to cloud servers
- User Control: You have full control over your data. You can delete all locally stored data at any time via Settings → Delete My Data
- Temporary API Calls: Only temporary API requests are made to our AI provider during active use - no chat content is retained by us or the provider after processing## Retention Periods- User-Generated Content: Stored locally on your device indefinitely until you delete it
- Subscription Data: Retained for the duration of your subscription plus 3 years for accounting and legal compliance
- Support Communications: Retained for up to 2 years or as long as necessary to resolve your issue
- Analytics Data: We do not collect analytics data as the App operates entirely locally## ⚠️ User Responsibility for Local DataImportant: Because FlirtyIQ stores all data locally on your device, YOU are responsible for managing and backing up your data.Data Loss Scenarios - You may lose your data if:- You delete the App without backing up your data
- You change devices (upgrade phone, switch from iOS to Android, etc.)
- You restore your device to factory settings
- Your device is lost, stolen, or damaged
- You log out or delete your account (if applicable)No Cloud Backup: We do NOT provide cloud backup or sync services. Once data is deleted from your device, it cannot be recovered by us.Disclaimer: Egger AI Studio is NOT responsible for any data loss resulting from device changes, app deletion, device failure, or user actions. You use the App's local storage at your own risk.5️⃣ Data Sharing & DisclosureWe do NOT sell your personal data. We share information only in the following limited circumstances:- AI Service Providers: To process your analysis requests (temporary, no permanent storage)
- Payment Processors: Apple App Store / Google Play Store for billing and subscription management
- Analytics & Infrastructure: Anonymous usage data shared with analytics providers (e.g., Firebase Analytics, Sentry for crash reporting)
- Legal Obligations: If required by law, court order, subpoena, or to protect our legal rights and safety
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity (you will be notified)6️⃣ International Data TransfersFlirtyIQ is operated from Switzerland. Your data may be processed in:- Switzerland (adequate protection under GDPR)
- United States (for AI processing)
- Other jurisdictions where our service providers operateSafeguards: When transferring data outside the EEA/UK/Switzerland, we use appropriate safeguards including:- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions (e.g., Switzerland, Canada under PIPEDA)
- Encryption in transit (TLS 1.2+)7️⃣ Your Privacy RightsDepending on your location, you may have the following rights:## GDPR Rights (EU/UK/Switzerland)- Right to Access: Request a copy of your personal data
- Right to Rectification: Correct inaccurate or incomplete data
- Right to Erasure ("Right to be Forgotten"): Delete your data in certain circumstances
- Right to Data Portability: Receive your data in a structured, commonly used format
- Right to Restriction of Processing: Limit how we use your data in certain situations
- Right to Object: Object to processing based on legitimate interests
- Right to Lodge a Complaint: File a complaint with your local data protection authority (e.g., CNIL in France, ICO in UK, FDPIC in Switzerland)## CCPA/CPRA Rights (California)- Right to Know what personal information is collected, used, shared, or sold
- Right to Delete personal information
- Right to Opt-Out of Sale (we do not sell data)
- Right to Non-Discrimination for exercising your rights## How to Exercise Your RightsTo exercise any of these rights, please contact us at: [email protected]We will respond to your request within:- 30 days (GDPR/FADP)
- 45 days (CCPA/CPRA), extendable to 90 days if necessaryVerification: To protect your privacy, we may request additional information to verify your identity before processing your request.8️⃣ Data SecurityWe implement industry-standard security measures to protect your data, including:- Encryption in Transit: TLS 1.2+ for all data transmitted between your device and our servers
- Encryption at Rest: Local data encrypted where supported by device OS (iOS Keychain, Android Keystore)
- Code Signing: App integrity verified through Apple/Google signing
- Access Controls: Restricted access to systems and data on a need-to-know basis
- Regular Security Audits: Periodic reviews and vulnerability assessmentsData Breach Notification: In the unlikely event of a data breach affecting your personal data, we will notify you and relevant authorities within 72 hours as required by GDPR.Limitations: While we take reasonable precautions, no method of transmission or storage is 100% secure. You use the App at your own risk.9️⃣ Children's PrivacyAge Requirement: FlirtyIQ is NOT intended for users under 18 years of age (or the legal age of majority in your jurisdiction, whichever is higher).We do NOT knowingly collect personal information from children under:- 16 years (GDPR requirement)
- 13 years (COPPA - USA)
- 18 years (our Terms of Use requirement)If we become aware that we have inadvertently collected information from a child, we will delete it immediately. If you believe a child has provided us with personal information, please contact us at [email protected].🔟 Cookies & Tracking TechnologiesNo Cookies: FlirtyIQ does not use cookies as it is a native mobile application.No Third-Party Tracking: We do NOT use third-party analytics SDKs, crash reporting tools, or any external tracking technologies.Local Storage Only: All data is stored locally on your device using secure device-level storage (iOS Keychain, Android Keystore). This data is NOT transmitted to external servers except for temporary AI processing requests.No Advertising IDs: We do not collect or use advertising identifiers (IDFA on iOS, GAID on Android).1️⃣1️⃣ Third-Party Services & LinksFlirtyIQ may contain links to third-party websites, services, or resources. We are not responsible for the privacy practices or content of these third parties.We recommend reviewing the privacy policies of any third-party services you access through the App.1️⃣2️⃣ Changes to This Privacy PolicyWe may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or App features.Notification of Changes:- Material changes will be communicated via in-app notification or email
- The "Last Updated" date at the top of this policy will be revised
- Continued use of the App after changes constitutes acceptanceIf you do not agree to the updated policy, please stop using the App and delete your account.1️⃣3️⃣ Contact Us & File ComplaintsIf you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:Egger AI StudioEmail: [email protected]Response Time: Within 7 business days for general inquiries, 30 days for GDPR requestsData Protection Authorities: You have the right to lodge a complaint with your local data protection authority:- EU/EEA: Contact your national data protection authority (list: https://edpb.europa.eu)
- UK: Information Commissioner's Office (ICO) - https://ico.org.uk
- Switzerland: Federal Data Protection and Information Commissioner (FDPIC) - https://www.edoeb.admin.ch
- California: California Attorney General - https://oag.ca.gov/privacy© 2025 Egger AI Studio — All Rights ReservedThis Privacy Policy is effective as of November 2025