Our Privacy Policy​

XI Media, LLC. dba Flairr Labs respects your privacy rights and recognizes the importance of protecting your personal information (or “personal data”). Our Privacy Notice describes the kinds of personal information we collect, why we collect it, how we share it, and choices we give you.


This Privacy Policy has been updated as June 28th, 2021.

1. What does this Privacy Notice cover?

Our Privacy Notice applies to the collection and processing of personal information by XI Media, LLC. dba Flairr Labs and our subsidiaries and affiliated companies acting on our behalf (collectively the “Company”, “Flairr”, “we”, “us”, or “our”). This Privacy Notice applies only to personal information collected about you as a consumer through the Flairrcoin website, Flairr Vault, Flairr App, Flairr Wallet, Flairr Partner Apps, as well as apps, features, services provided by Flairr Labs where this Privacy Notice is posted (“Services”). This notice does not apply to human resources data.

Our international affiliates and third-party websites or apps that our Services link to, or with whom we may have a presence, or with whom we may license use of our Service, trademarks and copyrights, may collect and use personal information for their own purposes. Where they do so, their respective privacy notices apply. Please review the respective terms and privacy notices of these entities to learn how they process your personal information.


2. What personal information is collected about you?

We don’t require personal information to use many of our Services. If you choose not to disclose personal information, however, you will not be able to enjoy certain features of our Services.


2.1. Information you provide to us

The types of personal information we may collect directly from you may include, for example:

  • Contact information: such as your first and last name, email address, telephone number, postal address, and non-Services account IDs.
  • Profile and demographic information: such as details on your personality, gender, sexual orientation, date of birth, country/region of residence, hobbies, game preferences, interests and other details about you.
  • Content and files: data and content you share or upload, such as photos (including any metadata included in your photos and content). To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
  • Government issued IDs: for specific services (e.g. digital wallet, et.) we may collect photographs of one or more government issued IDs for security purposes.
  • Payment information: for example, credit card numbers or financial account information if you purchase a product or service from us or one of our partners
  • If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
  • If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
  • Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services. 
2.2. Information we collect automatically

We automatically collect certain information when you use our Services. For example:

  • Identifiers and device information: such as your device type, operating system type, browser type, device ID, Internet Protocol (IP) address, and other software including type, version, language, settings, and configuration. hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses.
  • Usage data: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, taps, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
2.3. Information we create or generate

We derive other information from the other data we collect about you, and we may combine this with other personal information to generate information about your likely preferences or other characteristics (“inferences”).


2.4. Information we obtain from third-party sources

In limited circumstances, we also obtain information from third parties. We protect information obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the information. These third-party sources include, for example:

  • Mobile Platforms: when you download our apps, we receive information from the app stores and other mobile platform providers about you that is limited to username and/or device ID and the fact a purchase was made, but no other sensitive or financial information, unless you authorize the mobile platform providers to provide us additional information;
  • Service Providers: third parties may collect any of the categories of personal information described above to provide services on our behalf, including to help us determine your device’s general location based on its IP address to customize certain products to your location, provide you a more convenient experience, and provide additional security measures to protect our Services; and
  • Social Networks: where the information, including your name, username, and content you post, is publicly available to us, we may use such data for purposes such as measuring public reaction to the Services.

3. Cookies and other similar technologies

We use and may allow others to use cookies and similar technologies such as web beacons, pixels, etc. to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.


4. How is your personal information used?

We use your personal information to the extent reasonably necessary to fulfill your requests in performing our contract with you, or based on consent where we have requested it or where required by law, and for our legitimate business objectives, including for the following business purposes:

  • Account Administration: to create and manage your account
  • Connecting you with others: analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others.
  • Business Operations: to provide you with and operate, maintain, optimize, and improve our products, services, operations, and the security of our Services, including to perform operational tasks such as billing, accounting, communicating, and fulfilling your transactions for products and services.
  • Product and Service Delivery: to personalize content and experiences on our Services, including providing you recommendations based on your preferences.
  • Marketing: to deliver and personalize your notifications, communications, newsletters, advertisements, offers, event notices, and promotions for products and services of the Company and our third-party partners;
  • Product Improvement, Development, and Research: to develop information to understand you based on demographics, your activity on our Services, responses to surveys, or activity on third-party websites and applications, including for purposes of troubleshooting and improving our Services; to conduct market research and perform statistical, demographic, and marketing analyses of users of our Services and their purchasing patterns;
  • Administration of services: administer sweepstakes, contests, discounts or other offers; Develop, display and track content and advertising tailored to your interests on our services and other sites.
  • Communications: to send and display administrative communications about the Services and our partners and our respective products and services.
  • Security of Services: to detect, investigate, and prevent activities that are unauthorized, may violate our terms and policies, or may be illegal, such as fraudulent activity or security violations; and
  • Customer Support: to provide customer support and respond to your questions submitted to us.

Except for payment information, which is used solely for accounting, billing, order fulfillment, and fraud prevention purposes, all of the categories of information described in Section 2 are used for each of the purposes described above.

For the purposes listed above, we may also link or combine information about you with other personal information we receive from third parties. We also use personal information in settings and for the purposes described below. We may store and process personal information in the United States, and other countries or regions that may not have the same types of data protection laws as those in your country.


5. How is your personal information shared?

We do not share your personal information with third parties other than as follows:

  • With your consent, for example, when you agree to our sharing your information with other third parties for their own purposes, subject to their separate privacy policies
  • With third-party vendors, consultants, and other service providers who work for us or with us, and need to access your personal information to do that work, including for business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support).
  • If you’ve selected options available through our Services to publicly display your name and/or username and your other information
  • If appropriate to (a) comply with laws or to respond to lawful requests and legal processes, including, for example, to comply with a court order or subpoena; (b) protect the rights and property of the Company, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements; (c) protect the safety and security of any person; and/or (d) protect the safety and security of the Company’s and our partners’ Services, websites, and applications
  • In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets for use in accordance with applicable law.

6. How long do we keep your personal information?

We keep your personal information for as long as appropriate to maintain your accounts, to provide Services, to fulfill your requests, for legal compliance and enforcement purposes, and for resolving disputes. Actual retention periods depend on a variety of factors, such as the type of product, the type and sensitivity of the data, business needs, customer expectations and needs, the types of available user controls, and the form in which the data is stored.


7. What steps do we take to safeguard your personal information?

We implement technical, organizational, administrative, and physical security measures designed to protect your personal information from unauthorized access and improper use. However, please understand that despite our best efforts, no security measure is perfect or impenetrable.


8. Children’s Policy

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.


9. Your Rights

We want you to be in control of your information, so we have provided you with the following tools:

  • Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help at support@flairrlabs.com
  • Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
  • Deletion. You can delete your account by using the corresponding functionality directly on the service. By deleting your account, we reserve the right to keep your information for at least the second anniversary of the deletion date, unless it is against the law.

We want you to be aware of your privacy rights. Here are a few key points to remember:

  • Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request at support@flairrlabs.com
  • Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at support@flairrlabs.com

For your protection and the protection of all our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user’s written consent is required, before such information is released. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

  • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
  • Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established. Having said that, we would appreciate if you let us help with your request/complaint and try to resolve the problem, by contacting us first at support@flairrlabs.com


10. How to contact us

If you have questions about this Privacy Policy, here’s how you can reach us:


Online:            support@flairrlabs.com


By mail:


Flairr Labs

3259 Progress Drive

Orlando, FL 32826

United States of America


11. California Privacy Rights

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to support@flairrlabs.com. Please allow 30 days for a response. For your protection and the protection of all our users, we may ask you to provide proof of identity before we can answer such a request.


12. How will you know if we amend this Privacy Notice?

We may amend this Privacy Notice at any time by changing the last updated date. If we make material changes to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes.