PERSONAL DATA PROTECTION
POLICY
Last update: 16 February 2024
This Privacy Policy concerns the processing of personal data (hereinafter "Personal Data") while you
are using the smartphone or tablet application "FRUITZ" (hereinafter the "Application") as published by
FLASHGAP, a French “société par actions simplifiée” with share capital of EUR 28 829.60 registered
under the number 805 232 352 at the Paris “Registre du Commerce et des Sociétés”, with
headquarters located at 5 rue du Pont aux Choux 75003 Paris and represented by its President, Julian
KABAB, (hereinafter "FLASHGAP"). FLASHGAP is operated by the “Bumble Group” (also referred to
in this policy as “we” or “us”) which includes Bumble Holding Limited, Badoo Trading Limited and
Bumble Trading LLC, all of which are controllers of personal information collected and processed
through the Application..
The Personal Data collected are processed by FLASHGAP, or on its behalf, under the conditions set
out below.
As a Data Controller, FLASHGAP undertakes to implement adequate measures to ensure the
protection, confidentiality and security of your Personal Data and to process and use such data in
compliance with all applicable laws and regulations, in particular European Union Regulation 2016/679
of 27 April 2016 (hereinafter the "GDPR") and French law n° 78-17 of 6 January 1978 known as the
"Loi informatique et libertés", and any other law or regulation that may be added to it or take its place .
The purpose of this Privacy Policy is to inform you of the way FLASHGAP processes the Personal
Data that you provide, and that FLASHGAP collects, while you are using the Application.
It applies to all use of the Application by individuals signed up to use the Application (hereinafter the
"Users"). For any services provided and operated by third parties, please refer to the privacy policies
of those service providers.
1. What Personal Data is processed by FLASHGAP?
Personal Data means any information relating to an identified or identifiable natural person (“Data
Subject”) who can be identified, directly or indirectly, in particular by reference to an identifier such as
a name, an identification number, location data, an online identifier or to one or more factors specific to
the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
FLASHGAP collects and processes your Personal Data when you use the Application, including:
● information that you provide directly to FLASHGAP;
● information that FLASHGAP collects automatically from you;
● information that FLASHGAP collects from third parties.
1.1. Data that you provide directly to FLASHGAP
When you sign up to the Application by SMS, certain information must be provided to FLASHGAP you
can use the Application.
Therefore, to create a User account on the Application by SMS, the following Personal Data are
mandatory:
● your phone number, when you register using that phone number;
● your first name;
● your date of birth;
● your gender;
● your search preferences relating to the type of meeting that you seek (with men, women, or
both), your expectations in terms of relationship and your current state of mind. You can change
this information at any time in the Application settings;
● at least one profile picture.
Some of this information identifies you. Once communicated, the following information will be visible to
other Users and made public on the Application:
● your photos;
● your first name;
● your age (derived from your date of birth);
● your gender;
● your biography, if you have filled it in;
● the "fruit" of your choice (cherry : for finding your other half; grape : for a glass of wine without a
headache; watermelon : for recurring cuddles without hitting a snag; peach : for a sinful desire);
and
● your geographic proximity with other Users.
In addition, the following data are required:
● geolocation: to allow FLASHGAP to suggest to you profiles of Users around you;
● content of text messages sent on the Application: to provide the services and functionalities in
accordance with the Terms and Conditions of Use of FLASHGAP;
● data related to the follow-up of reports and requests addressed to FLASHGAP's customer
service, to ensure the security of your Personal Data and to answer requests for assistance
formulated by Users while interacting on the Application.
Finally, to complete your profile, you may fill in the "my bio" field with additional information, for
example information on your interests, habits, hobbies, cultural tastes, lifestyle, professional situation,
etc.
This information is optional. You may decide whether to provide such information at your own
discretion.
However, FLASHGAP draws your attention to the fact that some of these data might be
qualified as sensitive. Data legally defined as "sensitive" under the GDPR include, in particular,
data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or
trade union membership, as well as data concerning health, sex life or sexual orientation
(hereinafter "Sensitive Data").
Profile Verification Information (Including Biometric Information)
For safety and security and to ensure you have the best possible user experience, we require
Users to verify their accounts and might ask for your phone number and, in some instances, we
might also ask that you carry out photo verification. We want to make sure you are not a robot!
And we also want to avoid fake Fruitz accounts being created which can be used for malicious
activities and cybercrime – they threaten the Fruitz network and spoil things for everyone. This
verification might be required by us for the prevention of fraud. You can also verify your photo
on a voluntary basis (to add the blue ‘verified’ badge to your profile).
For photo verification, we will scan each photo that you submit. The scan may include the use
of facial recognition technology so that we can compare the photo you submit to your profile
photos. We do not add the verification photos to your profile. We will keep your verification
photo to scan and compare it with other photos you upload in the future.Data that FLASHGAP
collects from third parties
When you sign up to the Application with or:
● your Google account, by clicking on the "connect with Google" button, FLASHGAP collects
from the latter: your first and last name, your date of birth, your email address and your gender.
● your Apple account, by clicking on the button "connect with Apple", FLASHGAP has access to
your name and your email address.
1.2. Data that FLASHGAP collects automatically from you
When you use the Application, FLASHGAP automatically collects the following data:
● Data related to your activity regarding the Application, such as the date that you signed up, your
connection history, your “connected” or “disconnected” status, your interactions with other
Users, your number of transactions, notifications received, your actions such as scrolling,
clicking, adding to cart, etc.
● IP address, application version, device version and model, mobile or device identifier,
connection history , the country in which you are located, language used, application crashes,
browser used, advertising identifiers such as IDFA and IDFV for Apple and GAID for Google
and the identification number of the iOS or Android operating system used.
● Bank transaction data: no banking data is collected or processed by FLASHGAP. These data
are exclusively collected and processed by the App Store or Play Store. Only the transaction
numbers, for their validation, and your purchase and subscription history are kept by
FLASHGAP. FLASHGAP will not keep any information related to the payment methods used.
2. Why does FLASHGAP process your Personal Data and what is the legal basis for the
processing?
2.1. To comply with FLASHGAP’s Terms and Conditions of Use of the Application and in
particular for:
● The creation and management of your User account, to verify your compliance with the Code of
Conduct and to validate your signing up to the Application;
● The management and storage of communications exchanged between Users, in particular
"likes" and "dislikes", to determine whether there is a match and, if not, to avoid displaying the
same profile twice;
● The management of subscriptions and paid services as subscribed;
● The sending of notifications relating to use of the Application.
The legal basis for this processing is the performance of a contract (Terms and Conditions of Use
and/or a paying subscription) to which you are a party.
2.2. To suggest profiles to you
We use different indications based on users’ profiles on our app (for example, how you swipe or
whether you match with someone). We use these indications to recommend the most relevant profiles
to everyone to maximise everyone’s chances of finding meaningful connections on our apps.
Our matching algorithms are based on a range of factors and use machine learning to rank profiles for
you to maximise your chance of finding compatible matches. We use the following data about you and
other users to predict your compatibility with others and generate profile recommendations:
● the information you provide us about yourself in your profile such as age, distance or gender so
we can show you people who are appropriate and are more likely to like you back;
● information about how you interact with our app to suggest to you people who are active and
available to meet new people; and
● your device coordinates, which are necessary to understand your proximity to other members.”
The legal basis for this processing is the performance of a contract (Terms and Conditions of Use to
which you are a party.
2.3. To ensure the security of your Personal Data and to respond to requests for assistance
from Users
To monitor or prevent Application security breaches by identifying and analysing fraudulent activity and
to provide assistance so that the Application may be used in good technical and operational
conditions.
The legal basis for this processing is the legitimate interest pursued by FLASHGAP of ensuring the
security of your Personal Data.
2.4. To manage FLASHGAP’s marketing operations
To promote our services and optimize our advertising operations, we conduct marketing campaigns
and allow selected partners, listed in point 5 below, to conduct campaigns on our behalf.
For this purpose, our partners may use cookies which require your consent. You can choose to refuse
or to consent to the use of cookies, when you sign up to the Application, via the cookie management
banner.
You can withdraw your consent at any time in the same cookie management banner, where you can
set and modify your choices. You may also object to this processing by: writing to us, by objecting to
the use of your data for these purposes in the Application’s settings, or by sending an email to
privacy@fruitz.io.
With your consent, we and our partners may process your Personal Data for the following purposes :
● to run advertising campaigns and increase our performance via real-time bidding. Processing
your Personal Data consists of data about your visit to our App and action taken on those (for
example if you downloaded our App, or created an account with our App, or details of any
purchases made on Site or in App), collection and enhancement of data related to your profile
(gender, age, country, interests, etc.), as well as other contextual data (site visited, date and
time, etc., ) ;
● to compile our statistical reports on User flows, to help us to analyse our traffic and to measure
the performance of our advertising.
● to recognize you as you use the Application and to tailor our services to the personal
information that you have entered and that we may access (age, gender, etc.) and, if applicable,
to your previous use of the Application.
In order to carry out this processing, our service providers have limited access to your information and
are required to protect your Personal Data and use it only for the purposes for which it was collected,
in accordance with this Privacy Policy.
The legal basis for the processing described above is your consent.
2.5 To detect or prevent fraudulent activities or activities contrary to FLASHGAP’s Terms and
Conditions of Use
● Automated analysis of profile data and activity on the Application to ensure the quality of the
User profiles and to detect false profiles, fraudulent behaviour or behaviour contrary to the
Terms and Conditions of Use and the Code of Conduct.
Automated analysis, within the limits of the technical means used, of Users' photos in order
to detect a face and to exclude false profiles from the Application and to prevent fraudulent
behaviour.
The legal basis for this processing is the legitimate interest pursued by FLASHGAP of preventing
fraudulent activity or compliance with a legal obligation to which FLASHGAP is subject
3. How long does FLASHGAP keep your data?
FLASHGAP keeps your Personal Data as long as necessary for the purposes for which they were
collected and processed and as long as your Application account exists, i.e.:
● For the duration of the User's use of his or her User account plus one (1) additional year. User
accounts will be erased after one (1) year of inactivity. A User account is considered to be
inactive when the Application, as downloaded onto the User’s device, has not established
contact with FLASHGAP’s servers and the User has not used the Application. Please see
“Profile Verification Information (Including Biometric Information)”, above, to learn about our
retention policy with respect to biometric information.
● When a User is banned from using the Application, he or she is informed via a push notification
and his or her User account becomes inactive. Information relating to banned accounts is kept
for one (1) year in FLASHGAP’s active database in order to compare it with information
provided during the creation of new accounts on the Application and to prevent, as far as
possible, any re-registration of excluded users. At the end of this period, the banned accounts
are archived and kept for a further one (1) year before being permanently deleted.
● When a User deletes his or her account or requests its deletion from FRUITZ customer service,
it is deleted from the Application. Thereafter, if the User does not use his or her User account for
one (1) year, his or her data will be permanently deleted 1 month after deactivation.
● Users’ Personal Data may be kept for a longer period of time in intermediate archiving, for the
period necessary in accordance with the legal or regulatory obligations of conservation or for
the purposes of the establishment, exercise or defence of a legal right.
FLASHGAP undertakes to make its best efforts to guarantee the optimal security of the stored data. It
is up to each User to take all appropriate measures to protect his or her own data.
4. Personal Data of children
The use of the Application is reserved exclusively for adults. In case of doubt, FLASHGAP reserves
the right to verify by any means that the User is over 18 years old.
5. To whom is your Personal Data intended and how is it shared?
FLASHGAP’s authorized managers process Users’ Personal Data for the purposes described above
and only process such data that are necessary for the execution of their assignments such as
providing assistance to Users or tracking their reports and requests.
The Application’s main functionality being the development of relationships with other Users, your data
is shared with those other Users.
FLASHGAP also shares some of your data with authenticated and trusted service providers and
partners in compliance with the Privacy Policy and who guarantee the security and confidentiality of
Users' Personal Data.
In particular with :
● social networks: connection via Google (https://policies.google.com/privacy?hl=en-US) and
connection with Apple (https://www.apple.com/privacy//)
● our marketing and analytics providers: Adjust GmbH, Saarbrücker Str. 37a. 10405 Berlin,
Germany (https://help.adjust.com/fr/marketer/data-protection ), Adikteev 29 rue des
Pyramides, 75001 Paris, France (https://www.adikteev.com/) Mixpanel One Front Street, 28th
floor, San Francisco, CA 94111 (https://mixpanel.com/legal/ privacy-policy/), Appsflyer Inc.,
100 First Plaza, 100 1st St, San Francisco, United States
(https://www.appsflyer.com/trust/privacy/)
● our subcontractors for app hosting and maintenance: Google (https://
policies.google.com/privacy?hl=en-US)
FLASHGAP may also share your information with third parties:
● to comply with legal obligations and to enforce its rights;
● if FLASHGAP is involved in, and without this list being exhaustive, restructuring, change of
control, merger, acquisition, disposal, dissolution...
6. Is your Personal Data transferred outside the European Union?
Users' Personal Data may be transferred to Google in the United States for data hosting services.
These transfers of Personal Data are secured by standard contractual clauses, validated by the
European Commission and approved certifications or other relevant security measures allowing data
transfers from the EU to other countries.
7. What are your rights and how to exercise them?
In accordance with the GDPR and with French law n° 78-17 of 6 January 1978, known as the "Loi
informatique et libertés” , you have the right:
● to access to your Personal Data under the conditions set out in Article 15 of the GDPR;
● to rectify (amendments, updates) your Personal Data that are incomplete, inaccurate,
out-of-date or deleted in accordance with Article 16 of the GDPR. You have the right to
modify and rectify certain data directly from the Application;
● to the portability of the Personal Data you have provided in a structured, commonly used and
machine-readable format and to have such Personal Data transmitted directly to another
Data Controller, when technically possible (Article 20 of the GDPR). FLASHGAP reserves
the right to verify the identity of the applicant. Proof of
identity may be requested which will not be transmitted or transferred to third parties;
● to object at any time, for reasons related to your particular situation, to the processing of
Personal Data for prospecting purposes. FLASHGAP will no longer process such data,
unless it can demonstrate compelling legitimate grounds for the processing which override
the interests and rights and freedoms of the Data Subject, or for the establishment, exercise
or defence of legal claims;
● to request FLASHGAP to erase your data provided within the limits of the rights based on
Article 17 of the GDPR. You also have the possibility to delete your User account directly on
the Application, in the "Settings" tab. FLASHGAP, as host, has the legal obligation to keep
your Personal Data for one (1) year under Article 6-II) of French Law N° 2004-575 of 21
June 2004 “Loi pour la confiance dans l'économie numérique”. The data will be kept in a
separate archive solely for the purpose of responding to a judicial requisition and will be
permanently deleted at the end of the abovementioned one-year period;
● to restrict some of your data under the conditions of Article 18 of the GDPR;
● to define the directives relating to the conservation, deletion and communication of your
Personal Data after your death in accordance with Article 85 of the ”Loi informatique et
liberté”.
FLASHGAP undertakes, within its capabilities, to respect the protection of your Personal Data and to
process your requests as soon as possible.
Please note that the data communicated to FLASHGAP via Facebook Connect or Apple cannot be
rectified without their cooperation.
You can exercise these rights by sending an email to: privacy@fruitz.io , directly from the Application,
or by sending a letter to the following postal address FLASHGAP, 5 rue du Pont aux Choux 75003
Paris.
In case of doubt about the identity of the applicant, proof of identity may be requested.
For any additional information or complaint, you can contact the Commission Nationale de
l'Informatique et des Libertés (CNIL) or any other competent supervisory authority. Please contact
FLASHGAP prior to lodging a complaint.
8. How to contact FLASHGAP?
For any question relating to this Privacy Policy or for any request relating to your Personal Data, you
can contact FLASHGAP:
- by email, directly from the Application at our contact email address : privacy@fruitz.io;
or
- by mail at the following postal address : FLASHGAP, 5 rue du Pont aux Choux 75003 Paris.
9. Language
Should the English and French versions of this Privacy Policy differ, the French version shall prevail.
