To request full or partial deletion of your account and any associated data, please contact us directly at support@gettrueflame.com.
When you access our service we automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the service and to measure ads.
For improving the product and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Snapchat, Facebook, Google, Hotjar, Amplitude, Firebase, Pinterest, Snapchat, TikTok. Therefore, some of the data is stored and processed on the servers of such third parties. This enables us to (1) analyze different interactions (what products our users have viewed); (2) serve ads (and show them only to a particular group of users, for example, only to subscribers).
Please read our Privacy Policy below to know more about what we do with data (Section 3) , what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at support@gettrueflame.com
PRIVACY POLICY
This Privacy Policy explains what personal data is collected when you use the True Flame application (the “App”), True Flame website located at https://gettrueflame.com/ (the “Website”), the services and products provided through it (together Website with the App, the “Service”), how such personal data will be processed.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or instructions on the Website; (c) delete the App from your devices; (d) leave the Website and not access or use it.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states of the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
TABLE OF CONTENTS
PERSONAL DATA CONTROLLER
CATEGORIES OF PERSONAL DATA WE COLLECT
FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
WITH WHOM WE SHARE YOUR PERSONAL DATA
HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
AGE LIMITATION
INTERNATIONAL DATA TRANSFERS
CHANGES TO THIS PRIVACY POLICY
FOR VIRGINIA RESIDENTS
CALIFORNIA PRIVACY RIGHTS
DATA RETENTION
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
CONTACT US
PERSONAL DATA CONTROLLER True Flame Stories will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT We collect data you give us voluntarily (for example, name or email address). We also collect data automatically (for example, your IP address).
DATA YOU GIVE USÂ
We may ask you to provide information about yourself when you register for and/or use the Service. This information includes: email address, name, gender, date of birth, place of birth, and time of birth. We may also ask you to provide the date of birth, place of birth, and time of birth of your partner.
Data we collect automatically:
Data about how you found us We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
Device and Location data We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
Usage data We record how you interact with our Service. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Service, how long you are in the Service, your purchase orders.
Advertising IDs We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
Cookies A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.
Meta Pixel We use Meta Pixel to collect data about your actions on our Service. This data may include which pages you visit, the time you spend on each page, and the actions you take. The data collected is used to measure the effectiveness of our advertising campaigns and to personalize the content and ads presented to you. The information collected through Meta Pixel is transmitted to Meta. Your browser establishes a direct connection with the Meta server as soon as you have agreed to the use of tracking technologies requiring your consent.The processing of this data by Meta takes place within the framework of Meta’s data policy. To opt-out from Meta’s interest-based ads follow these instructions from Meta: Adjust how ads on Facebook are shown to you based on your Activity information from ad partners | Facebook Help Center
FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.
To customize your experience We process your personal data, such as age, gender, date of birth, to adjust the content of the Service and provide content tailored to your personal preferences.
To provide you with customer support We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you emails about, for example, the performance of our Service, payment transactions, notices regarding our Terms and Conditions of Use, this Privacy Policy or other documents that we make available from time to time.
To communicate with you regarding your use of our Service We communicate with you, for example, by push notifications. These may include horoscope reminders, motivational messages or other information about the Service. As a result, you may, for example, receive a push notification every day at a particular time reminding you to check your horoscope. To opt out of receiving push notifications, you need to change the settings on your device. We can also communicate with you via email when you make a purchase on the Website. These may include emails with information about the Service. The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Services’ users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.
To research and analyze your use of the Service This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
To send you marketing communications We may show you advertisements on our Service, send you push notifications or emails for marketing purposes. To opt out of receiving push notifications from us, you need to change the settings on your device. To opt out of receiving marketing emails, you need to unsubscribe following instructions in the footer of the marketing emails.
To personalize our ads We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook’s feed. How to opt out or influence personalized advertising iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to have personalized ads) in the same section. Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here. In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser
To process your payments We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
To enforce our Terms and Conditions of Use and to prevent and combat fraud We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (applies only to EEA-based users) In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users. We process your personal data under the following legal bases:
to perform our contract with you; Under this legal basis we:
Provide our Service (in accordance with our Terms and Conditions of Use)
Customize your experience
Provide you with customer support
Communicate with you regarding your use of our Service
Process your payments
for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data; We rely on legitimate interests:
to communicate with you regarding your use of our Service This includes, for example, sending you email to notify you that we have released a new product or reminding to finish a purchase. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
to research and analyze your use of the Service Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
to send you marketing communications The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
to personalize our ads The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
to enforce our Terms and Conditions of Use and to prevent and combat fraud Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
to comply with legal obligations.
5. WITH WHOM WE SHARE YOUR PERSONAL DATA We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:
Service providers We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
cloud storage providers (Amazon)
data analytics providers (Facebook, Amplitude, Tableau, Google)
measurement partners
communication service providers (Zendesk)
marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat, TikTok, Twitter, Pinterest)
payment service providers (PayPal, Solid)
Law enforcement agencies and other public authorities We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS To be in control of your personal data, you have the following rights: Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website. Deleting your personal data. You can request erasure of your personal data as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof. Additional information for EEA-based users: If you are based in the EEA, you have the following rights in addition to the above: The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place. The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us as described below. To exercise any of your privacy rights, please send a request to support@gettrueflame.com
AGE LIMITATION We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
INTERNATIONAL DATA TRANSFERS We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
CHANGES TO THIS PRIVACY POLICY We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
FOR VIRGINIA RESIDENTS This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under Virginia Consumer Data Privacy Act (VCDPA).
Disclosures about the use of your personal data We may collect and use certain information about you, some of which may be personal data (such as your age, gender, date of birth, or other information which may be reasonably linked to you), in order to operate the Service and to maximize your experience. If you would like more information about the categories of your personal data we collect or the purposes for which we collect them, please read Section 2 and Section 3. To learn more about sharing your personal data with our business partners and other third parties, please read Section 5.
Data Rights Section 6 of our Privacy Policy describes the data rights we offer to all users and how to execute these rights. This includes the right to access, review, correct, update your data, obtain a portable copy of your data, or delete data related to your stored preferences and your use of the Service. Before completing your request, we may require some information sufficient to authenticate your identity. Additionally, VCDPA provides Virginia residents with these data rights:
Opt out of the Processing of your Personal Data for Targeted Advertising. In order to exercise your choice as a Virginia resident, please contact us at support@gettrueflame.com Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by contacting us at support@gettrueflame.com
Appeal a Case with regard to your request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us at support@gettrueflame.com to initiate an appeal of this decision. Please use the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
CALIFORNIA PRIVACY RIGHTS California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be personal information under the statute. To obtain this information from us, please send an email message to support@gettrueflame.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
DATA RETENTION We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED Except as otherwise stipulated in this Privacy Policy, this Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
CONTACT US You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@gettrueflame.com
