Privacy Policy

Please Read Information Below

Our Privacy Policy explains what information we collect, how we use and share it, and the choices you have, including how to manage your privacy settings, access the information we have about you, and deleting your account.

This Privacy Policy applies to all of our Services unless specified otherwise.

Please also read Phlashback’s Terms of Service ("Terms"), which describes the terms under which you use our Services.

Information We Collect

Phlashback must receive or collect some information to operate, provide, improve, understand, customise, support, and market our Services, including when you install, access, or use our Services.

Information You Provide

Your Account Information. You provide your full name and email address to create a Phlashback account.

Customer Support. You may provide us with information related to your use of our Services and how to contact you so we can provide you customer support. For example, you may send us an email with information relating to our app performance or other issues.

Automatically collected information

Device Information. We collect device information when you log in to use our Services. This includes a device identifier.

Third-Party Information

We do not send or receive information about you from other users and businesses

How We Use Information

We use the information we have to operate, provide, improve, understand, customise, support, and market our Services.

Our Services. We use the information we have to operate and provide our Services, including providing customer support, and improving, fixing, and customising our Services. We understand how people use our Services and analyse and use the information we have to evaluate and improve our Services, research, develop, and test new services and features, and conduct troubleshooting activities. We also use your information to respond to you when you contact us.

Measurement, Analytics, And Other Business Services. We help businesses who use Phlashback to measure the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.

Information You And We Share

You can share your information and images as you use our Services. We do not share your information.

Your account information is not shared with any third party

Assignment, Change Of Control, And Transfer

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

How The General Data Protection Regulation Applies To Our European Region Users

Our Legal Bases For Processing Information

    We collect and use the information we have as described above:
  • as necessary to fulfill our Terms;
  • consistent with your consent, which you can revoke at any time;
  • as necessary to comply with our legal obligations;
  • occasionally to protect your vital interests, or those of others;
  • as necessary in the public interest; and
  • as necessary for our (or others') legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data. Learn more

How You Exercise Your Rights

Under the General Data Protection Regulation or other applicable local laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can access or port your information using our My Data feature. You can access tools to rectify, update, and erase your information directly in-app as described in the Managing and Deleting Your Information section. If we process your information based on our legitimate interests, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. You can also object to our processing of your information and learn more about your options for restricting the way we use your information by going here. Where we use your information for direct marketing for our own Services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications, or by using our "Block" feature.

Managing And Deleting Your Information

We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.

If you would like to manage, change or delete your information, we allow you to do that through the following:

  • Deleting Your Phlashback Account. You may delete your Phlashback account at any time using our delete my account feature. When you delete your Phlashback account, all information about you are deleted from our servers as well as any information we no longer need to operate and provide our Services.

Law And Protection

We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, Phlashback, or others, including to prevent death or imminent bodily harm.

Updates To Our Policy

We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before you choose to continue using our Services.

Contact Information

If You Are In The European Region The Data Protection Officer for Phlashback can be contacted here.

If you have questions about our Privacy Policy, please contact us or write us here:

Phlashback
Rowan House
Hill End Lane
St. Albans
Hertfordshire
AL4 0RA
United Kingdom

You have the right to lodge a complaint with Phlashback, The UK Data Protection Commissioner, or your local supervisory authority.

How We Process Your Information

Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we've explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data under the General Data Protection Regulation (the "GDPR"). To exercise your rights, see our Privacy Policy under How You Exercise Your Rights.

For all people who have legal capacity to enter into an enforceable contract, we process data as necessary to perform our contracts with you (the Terms of Service, the "Terms"). We describe the contractual services for which this data processing is necessary in Our Services section of the Terms and in the additional informational resources accessible from our Terms. The core data uses necessary to provide our contractual services are:

  • To provide, improve, customise, and support our Services as described in "Our Services";
  • To promote safety and security;
  • To transfer, transmit, store, or process your data outside the EEA, including to within the United States and other countries; and
  • To communicate with you, for example, on Service-related issues.

These uses are explained in more detail in our Privacy Policy, under How We Use Information. We'll use the data we have to provide these services; if you choose not to provide certain data, the quality of your experience using Phlashback may be impacted.

When we process data you provide to us as necessary to perform our contracts with you, you have the right to port it under the GDPR. To exercise your rights, visit the “My account” section. The other legal bases we rely on in certain instances when processing your data are:

Your Consent:

  • For collecting and using information you allow us to receive through the device-based settings when you enable them (such as access to your camera, or photos), so we can provide the features and services described when you enable the settings.


When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time and to port that data you provide to us, under the GDPR. To exercise your rights, visit your device-based settings, your in app-based settings like your in-app location control, and the How You Exercise Your Rights section of the Privacy Policy.

Our legitimate interests or the legitimate interests of a third party, where not outweighed by your interests or fundamental rights and freedoms ("legitimate interests"):

For people under the age of majority (under 18, in most EU countries) who have a limited ability to enter into an enforceable contract only, we may be unable to process personal data on the grounds of contractual necessity. Nevertheless, when such a person uses our Services, it is in our legitimate interests:
  • To provide, improve, customise, and support our Services as described in Our Services;
  • To promote safety and security; and
  • To communicate with you, for example, on Service-related issues.


  • The legitimate interests we rely on for this processing are:
    • To create, provide, support, and maintain innovative Services and features;
    • To secure our platform and network, verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, and keep our Services free of harmful or inappropriate content, and investigate suspicious activity or violations of our terms or policies and to protect the safety of people under the age of majority, including to prevent exploitation or other harms to which such individuals may be particularly vulnerable.


    For all people, including those under the age of majority:
    • For providing measurement, analytics, and other business services where we are processing data as a controller. The legitimate interests we rely on for this processing are:
    • To provide accurate and reliable reporting to businesses and other partners, to ensure accurate pricing and statistics on performance, and to demonstrate the value our partners realise using our Services; and
    • In the interests of businesses and other partners to help them understand their customers and improve their businesses, validate our pricing models, and evaluate the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
    • For providing marketing communications to you. The legitimate interests we rely on for this processing are:
    • To share information with others including law enforcement and to respond to legal requests. The legitimate interests we rely on for this processing are:
    • To prevent and address fraud, unauthorised use of the Phlashback app, violations of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
    • To secure systems and fight spam, threats, abuse, or infringement activities and promote safety and security across the Phlashback platform.


    You have the right to object to, and seek restriction of, such processing; to exercise your rights, visit How You Exercise Your Rights section of the Privacy Policy.

    We will consider several factors when assessing an objection including: our users' reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

    If you are under the age of majority in your country and have a limited ability to enter an enforceable contract, we will take particular account of the fact that you are below the age of majority and adjust our assessment of our legitimate interests and the balancing of your interests and rights accordingly.

    Compliance with a legal obligation:

    • For processing data when the law requires it, including, for example, if there is a valid legal request for certain data.

    Tasks carried out in the public interest:

    • For undertaking research and to promote safety and security, as described in more detail in our Privacy Policy under How We Use Information, where this is necessary in the public interest as laid down by European Union law or Member State law to which we are subject.


    When we process your data as necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our processing. To exercise your rights, go to How You Exercise Your Rights section of the Privacy Policy. In evaluating an objection, we'll evaluate several factors, including: reasonable user expectations; the benefits and risks to you and third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

    Intellectual Property Policy: Your Copyrights and Trademarks

    Phlashback is committed to helping people and organisations protect their intellectual property rights. Our users agree to our Terms of Service ("Terms") by installing, accessing, or using our apps, services, features, software, or website (together, "Services"). Our Terms do not allow our users to violate someone else's intellectual property rights when using our Services, including their copyrights and trademarks.

    As explained in more detail in our Privacy Policy, we do not retain our users' photos in the ordinary course of providing our Services. We do, however, host our users' account information, including our users' full name, email address and device id, if they decide to include them as part of their account information.

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