Privacy policy

Flynn Labs Inc. (“Flynn Labs,” “we,” “us,” or “our”) provides advertising technology that enables mobile application developers and publishers to monetize their applications by displaying advertisements to their users. We provide this functionality primarily through a software development kit (the “Flynn SDK”) that publishers integrate into their iOS, Android, and Flutter applications (collectively, the “Advertising Services” or “Services”).

This Privacy Policy explains how we collect, use, and share information through our Advertising Services and through our corporate website at meetflynn.ai (the “Website”), as well as your choices and privacy rights regarding that information.

By accessing the Website or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Our Advertising Services

Information We Collect

When you use an application containing the Flynn SDK or interact with advertisements served by Flynn Labs, we collect information about your device and your interactions. The exact information collected depends on your device ad settings and publisher permissions:

• Identifiers: IP address, advertising identifiers (such as Apple’s IDFA and Google’s GAID), vendor identifiers (IDFV), and App Set IDs.
• Device & Network Data: Device make, model, operating system, hardware properties, screen size, battery/memory usage, mobile carrier, network connection type (e.g., Wi-Fi, 5G), and country/locale settings (coarse location derived from IP address).
• Internet & Electronic Activity: HTTP header information, internet browser user-agent, application name and version, and software environment.
• Advertising Event Data: Information regarding your interactions with advertisements, such as ad views, clicks, app installations, and post-install in-app actions, which may be received from third parties like Mobile Measurement Partners (MMPs).

How We Use Your Information

We act as an independent Data Controller when processing this data for the following business and commercial purposes:

• Service Delivery: To deliver, secure, and maintain the Flynn SDK and ad delivery network.
• Personalization & Ad Serving: To present interest-based advertising that is relevant to you based on your app usage and ad interactions.
• Measurement & Analytics: To measure the effectiveness of ad campaigns, attribute app installs, and report performance to advertisers and publishers.
• Artificial Intelligence: We use AI-based models trained on aggregated and pseudonymized event data to optimize ad relevance and real-time bidding efficiency. This processing does not produce legal or similarly significant effects on consumers.
• Safety & Integrity: To prevent ad fraud (e.g., bot traffic), enforce our terms, and secure our infrastructure.

How We Share Your Information

We share information with third parties in the following contexts:

• Service Providers: Companies that provide cloud infrastructure, data analytics, and security services. These partners are bound by confidentiality obligations.
• Advertising Partners: Demand-side platforms, ad exchanges, advertisers, and attribution partners (MMPs). We share identifiers and event data so these partners can bid on ad inventory and measure campaign success.
• Legal & Safety: To government authorities or law enforcement when required by law, subpoena, or court order, or to protect the rights, property, and safety of Flynn Labs or others.
• Business Transfers: To an acquiring entity in the event of a merger, acquisition, reorganization, or sale of assets, including in insolvency or bankruptcy.

Data Security and Retention

We implement reasonable administrative, technical, and physical measures designed to protect the information we collect. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot and do not guarantee the absolute security of any information; you provide information at your own risk.

To comply with data minimization principles, we enforce the following retention schedules:

• IP Addresses: Truncated or anonymized within 30 days of collection unless required longer for specific fraud investigations.
• Advertising Identifiers & Event Data: Retained for up to 13 months to support long-term campaign attribution and AI model training, after which it is aggregated or deleted.
• Opt-Out Data: Device IDs submitted for opt-out requests are stored indefinitely on a suppression list to ensure we honor your choices.

2. U.S. State Privacy Rights (CCPA/CPRA Disclosures)

If you are a resident of California or a state with a similar comprehensive privacy law, this section provides required disclosures and explains your rights.

Notice of Collection and Sharing (12-Month Lookback)

We do not collect or seek to collect sensitive personal information (such as precise geolocation, government identifiers, or information about health, race, or religion) through the Advertising Services. In the preceding 12 months, we have collected, used, and disclosed the following categories of personal information for the business and commercial purposes described in Section 1:

Do Not Sell or Share My Personal Information

Under the CCPA, our disclosure of identifiers and event data to third-party ad networks for interest-based advertising may constitute a “sale” or “sharing” of personal information. You have the right to opt out:

• Mobile Device Opt-Out: The most effective way to opt out is to use your device’s native privacy controls. On iOS, toggle off “Allow Apps to Request to Track” or limit tracking for specific apps. On Android, select “Opt out of Ads Personalization” or “Delete advertising ID” in your Google settings. When we receive these technical signals, we treat them as a request to opt out of the sale or sharing of your data.
• Global Privacy Control: For visitors to our Website, we recognize the Global Privacy Control (GPC) browser signal as a valid request to opt out of the sale or sharing of personal information.
• Direct Request: You may also exercise your opt-out rights by emailing your mobile advertising ID (IDFA or GAID) to hello@meetflynn.ai.

Your Consumer Rights

Depending on your state of residence, you have the right to:

• Know/Access: Request a portable copy of the specific pieces of personal information we hold about you.
• Delete: Request that we delete personal information we have collected from you.
• Correct: Request correction of inaccurate data.
• Non-Discrimination: Receive equal service regardless of whether you exercise your privacy rights.

To submit a request, email hello@meetflynn.ai. Please include your mobile advertising identifier (IDFA or GAID) so we can locate your data, as we do not collect names or emails through our Advertising Services. We will respond to verified requests as required by applicable law.

3. Additional Provisions for EU/UK/Swiss Individuals

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you are protected by the GDPR and UK GDPR.

Lawful Bases for Processing

As a Data Controller, Flynn Labs processes your personal data under the following lawful bases:

• Consent: We rely on the consent obtained by our publisher partners to collect device identifiers and serve personalized advertising. You may withdraw this consent at any time via your device settings.
• Legitimate Interests: We process non-identifying technical data for fraud prevention, network security, and internal analytics, provided these interests do not override your fundamental rights.
• Legal Obligation: Where required to comply with European or member-state laws.

International Data Transfers

Flynn Labs is headquartered in the United States, and the information we process is stored and processed in the United States and potentially other jurisdictions. When we transfer personal data from the EEA, United Kingdom, or Switzerland to a country that has not received an adequacy decision, we implement an appropriate safeguard required by applicable law, utilizing the European Commission’s Standard Contractual Clauses (SCCs), together with the UK International Data Transfer Agreement or Addendum for UK transfers, and any required amendments for Swiss transfers.

Your Rights

You have the right to access, rectify, or erase your personal data; restrict or object to its processing; and request data portability. To exercise these rights, email hello@meetflynn.ai with your mobile advertising identifier. You also have the right to lodge a complaint with your local Data Protection Authority.

4. Children’s Privacy

The Advertising Services and Website are not directed to children under 13 (or the applicable age of digital consent in your jurisdiction), and Flynn Labs does not knowingly collect personal information from children or knowingly serve interest-based advertisements to them.

We contractually require our application publishers to identify any application that is directed to children. Where a publisher designates an application as child-directed, it is our policy not to serve personalized or interest-based advertising, and not to engage in tracking, within that application. If you believe we have inadvertently collected information from a child, please contact us at hello@meetflynn.ai and we will take appropriate steps to delete it.

5. Our Website

When you visit meetflynn.ai, request support, or correspond with us, we may collect your name, email address, phone number, and company information. We use this data to provide customer support, manage accounts, and communicate regarding our Services. We do not sell or share business contact information with third-party advertising networks.

Cookies and Similar Technologies

Our Website may use cookies, pixels, and similar technologies for purposes such as analytics and understanding how the Website is used. You can manage or disable cookies through your browser settings, although some features may not function properly without them. Where required by law, we will present a cookie-consent mechanism to visitors before placing non-essential cookies.

6. General Terms

• Changes to This Privacy Policy: We may update this Privacy Policy to reflect business or regulatory changes. We will update the “Last Updated” date at the top of this page. Material changes will be communicated via our Website or by direct notification to our publisher partners.
• Governing Law: This Privacy Policy is governed by the laws of the State of California, without regard to conflict-of-laws principles, except to the extent superseded by applicable federal or international data-protection laws.
• Relationship to Other Agreements: Your use of the Services is also governed by our Publisher & SDK License Agreement and any other agreement between you and Flynn Labs. To the extent of any conflict regarding limitations of liability, warranties, indemnification, or dispute resolution, the terms of the applicable agreement control.
• Reservation of Rights: We reserve all rights not expressly granted, and reserve the right, to the extent permitted by applicable law, to take or refrain from any action described in this Privacy Policy in our reasonable discretion.
• No Third-Party Beneficiaries: This Privacy Policy does not create, and shall not be construed to create, any contractual or other legal rights in or on behalf of any third party.
• Severability: If any provision of this Privacy Policy is held invalid or unenforceable, that provision will be limited or eliminated to the minimum extent necessary, and the remaining provisions will remain in full force and effect.
• International Users: By using the Services or the Website, you understand that your information may be transferred to and processed in the United States and other jurisdictions.

7. Contact Us

For questions about this Privacy Policy or to exercise your data rights, contact us at:

Flynn Labs Inc.
584 Castro St, Suite #4040
San Francisco, CA 94114, USA
Email: hello@meetflynn.ai