Privacy Policy

1. Who is responsible for processing your data?

The data controller for personal data collected through the FLIPLY website and mobile application is SYNKROSS SOLUTIONS, S.L., with Tax ID (NIF) B75429076 and registered address at Paseo de la Castellana 194, Ground Floor, Door B, 28046 Madrid, Spain.

SYNKROSS SOLUTIONS, S.L. is the entity that owns the FLIPLY platform and determines the purposes and means of processing the personal data of users in the context of providing the digital peer-to-peer marketplace service.

For any questions related to the processing of your personal data, you may contact us at the email address [email protected].

Likewise, for general enquiries related to the operation of the Platform, you may write to [email protected].

2. Recommendations

Users are advised to carefully read this Privacy Policy in order to understand how their personal data is collected, used and protected in the context of using the Website.

Additionally, the following security recommendations should be taken into account while browsing:

• Keep your computer equipment properly protected by using up-to-date antivirus software and other security tools that can detect and prevent the presence of malicious programs, such as viruses, malware or spyware, that may compromise the security of Internet browsing or the information stored on the device.
• Use up-to-date versions of Internet browsers, as well as keeping the device operating systems properly updated, in order to reduce potential security vulnerabilities.
• Read and periodically review this Privacy Policy, as well as the other legal texts available on the SYNKROSS SOLUTIONS, S.L. Website, in order to be aware of the applicable conditions at all times.

3. Information about the data FLIPLY collects

For the proper functioning of the FLIPLY website and mobile application, SYNKROSS SOLUTIONS, S.L. may process certain personal data provided by users through forms, registration processes, communications or through the use of the Platform itself.

In particular, the following categories of personal data may be processed:

1. Identification data, such as the user's full name, as well as, where applicable, the profile picture associated with their account.
2. Contact data, including the email address used for registration and account management, as well as any other information provided by the user in the context of their communications with the Platform.
3. Account and Platform usage data, including the information necessary for the creation, authentication and management of the user account, as well as data related to the user's activity within the Platform, such as ad postings, favourite products, ratings, interaction history and feature usage.
4. User-generated content, including ads, descriptions, product images, messages sent through the chat system and ratings of other users.
5. Approximate geolocation data, such as the city, declared location or approximate coordinates of the user, used to validate the territory of use and facilitate the display of nearby products.
6. Technical and browsing data, including IP address, device identifiers, operating system, activity logs, events within the Platform and other technical data necessary to ensure security, prevent fraud and improve the functioning of the service.
7. Data derived from automated interactions, including information processed through artificial intelligence tools or third-party services for functionalities such as automatic content translation or description enhancement.

4. Why is FLIPLY entitled to process your data?

The processing of personal data by SYNKROSS SOLUTIONS, S.L., within the framework of the FLIPLY platform, is based on the various legal bases provided for in Regulation (EU) 2016/679, depending on the specific purpose of the processing.

In particular, the processing of the user's personal data will be necessary for the performance of the contractual or pre-contractual relationship, insofar as it is essential to allow registration on the Platform, the creation and management of the user account, the publication of ads, the interaction between users and the general use of the marketplace features.

Likewise, certain processing activities may be based on compliance with legal obligations applicable to SYNKROSS SOLUTIONS, S.L., particularly in relation to fraud prevention, security, cooperation with competent authorities or compliance with legal requirements.

FLIPLY may process personal data on the basis of its legitimate interest, in particular to ensure the security of the Platform, prevent fraudulent or unlawful use, improve the functioning of the service, carry out internal analyses and optimise the user experience, always respecting the fundamental rights and freedoms of users.

On the other hand, processing activities that are not covered by the above bases, such as the sending of commercial communications, the use of certain personalisation features or the processing of data for non-essential analytical purposes, will be carried out on the basis of the user's consent, which may be withdrawn at any time without affecting the lawfulness of processing based on prior consent.

In relation to specific Platform features, the user accepts that certain content generated by them, such as product descriptions or messages, may be processed by automated tools or third-party services for the purpose of enabling features such as automatic translation or content enhancement, this processing being necessary for the proper provision of the service requested by the user.

5. What are the purposes of processing your personal data?

Personal data that may be collected through the FLIPLY website and mobile application will be processed by SYNKROSS SOLUTIONS, S.L. for the purpose of managing user registration and accounts, enabling access, authentication and use of the Platform, as well as profile configuration and management of the information associated with it.

Likewise, data will be processed for the purpose of providing the services offered through the Platform, including the publication of ads, the display of products, the interaction between users through the messaging system, the management of ratings and the general operation of the peer-to-peer marketplace.

Data may also be used to manage and respond to requests, enquiries or communications made by users through the various channels available, including contact forms, email or communications within the Platform itself.

FLIPLY will process personal data with the aim of ensuring the proper functioning, maintenance and continuous improvement of the Platform, including analysis of service usage, error detection, feature optimisation and personalisation of the user experience to the extent permitted by applicable regulations.

Data may also be processed to ensure the security of the Platform, prevent fraud, detect improper or unlawful use and protect both users and the technological infrastructure itself.

In the context of certain Platform features, data may be processed by automated tools or third-party services, including artificial intelligence technologies or automatic translation systems, for the purpose of facilitating communication between users, improving the quality of content and optimising the user experience.

In particular, certain user-generated content, such as product descriptions or messages, may be processed by external providers that provide artificial intelligence or translation services, which may involve the processing of data outside the European Economic Area, under appropriate safeguards in accordance with applicable regulations.

The use of these features is part of the service offered by the Platform, so their activation by the user implies acceptance of this processing to the extent necessary for their operation.

Finally, personal data may be processed for compliance with legal obligations applicable to SYNKROSS SOLUTIONS, S.L., as well as to respond to requirements from public or administrative authorities when necessary.

Where the user has given their consent, FLIPLY may send informational or commercial communications related to the Platform, its features, news or services, through the contact means provided, and the user may withdraw such consent at any time.

6. Accuracy of data provided by Users

The User guarantees that the personal data provided to SYNKROSS SOLUTIONS, S.L. in the context of using the FLIPLY Platform is truthful, accurate, complete and up to date.

The User shall be responsible for communicating any changes to the personal data provided, so that it can be kept up to date at all times and reflect their actual situation.

In the event that the User provides personal data of third parties, they guarantee that they have previously informed those persons of the content of this Privacy Policy and that they have the necessary legal basis to provide such data to SYNKROSS SOLUTIONS, S.L. for the purposes described.

SYNKROSS SOLUTIONS, S.L. reserves the right to suspend or cancel the account of any user who has provided false, inaccurate or incomplete data, without prejudice to any other legal actions that may apply.

7. Data retention

Personal data provided by users will be retained by SYNKROSS SOLUTIONS, S.L. only for as long as necessary to fulfil the purposes for which they were collected, including user account management, the provision of services offered through the FLIPLY Platform and the handling of requests or enquiries.

In particular, data associated with the user account, published ads and activity within the Platform may be retained for as long as the account remains active or for the time necessary for the proper provision of the service.

Once personal data is no longer necessary for those purposes, it will be deleted or anonymised, without prejudice to the fact that it may be retained, duly blocked, for the legally established periods in order to address any legal or contractual liabilities.

In cases where processing is based on the user's consent, data will be processed as long as such consent has not been withdrawn, without affecting the lawfulness of prior processing.

SYNKROSS SOLUTIONS, S.L. will adopt appropriate technical and organisational measures to ensure the security and confidentiality of personal data throughout the entire retention period.

8. User rights

Users may exercise at any time the rights granted to them by the applicable data protection regulations.

In particular, data subjects may exercise the following rights:

• Right of access: the right to obtain confirmation as to whether SYNKROSS SOLUTIONS, S.L. is processing personal data concerning them and, if so, to access such personal data.
• Right of rectification: the right to request the modification or correction of personal data that is inaccurate or incomplete.
• Right of erasure: the right to request the deletion of personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
• Right to object: the right to object to the processing of personal data when there are grounds related to their particular situation.
• Right to restriction of processing: the right to request the restriction of processing of personal data in certain circumstances provided for by applicable regulations.
• Right to data portability: the right to receive the personal data provided to SYNKROSS SOLUTIONS, S.L. in a structured, commonly used and machine-readable format, and to transmit it to another data controller when technically feasible.

9. Data security

SYNKROSS SOLUTIONS, S.L. will process Users' personal data in an absolutely confidential manner and will maintain the duty of secrecy with respect to such data, in accordance with the applicable data protection regulations.

Likewise, SYNKROSS SOLUTIONS, S.L. has adopted the necessary technical and organisational measures to ensure a level of security appropriate to the risk, in order to prevent the alteration, loss, processing or unauthorised access to personal data, taking into account the state of the art, the nature of the data processed and the risks to which they are exposed.

These measures are reviewed and updated periodically to ensure the security and integrity of the information processed.

However, the User should be aware that security measures on the Internet are not impregnable and that, therefore, the absolute security of information transmitted over the network cannot be guaranteed.

10. Transfers and/or disclosures to third parties

SYNKROSS SOLUTIONS, S.L. will not disclose Users' personal data to third parties, except in cases where such disclosure is necessary for the fulfilment of the purposes described in this Privacy Policy or where there is a legal obligation requiring it.

In this regard, personal data may be disclosed to public administrations, competent authorities or other bodies where such disclosure is necessary for compliance with legal obligations or for the provision of services provided by SYNKROSS SOLUTIONS, S.L.

Likewise, certain service providers that provide services to SYNKROSS SOLUTIONS, S.L. (for example, technology services, web hosting, maintenance or IT support) may have access to personal data as data processors, exclusively for the provision of such services and always under appropriate contractual guarantees regarding data protection.

In no case will such providers process the data for their own purposes or disclose it to third parties.

11. Acceptance and Consent

The User declares to have been informed of the data protection conditions contained in this Privacy Policy. The processing of their personal data will be carried out in accordance with the legal bases indicated herein.

In cases where the processing of data is based on the User's consent, this will be obtained expressly, specifically and in an informed manner through the checkboxes provided in the corresponding forms or Platform settings, which will not be pre-selected under any circumstances.

The User may withdraw their consent at any time, without affecting the lawfulness of processing based on prior consent.

12. Use by Minors

The FLIPLY Platform is not intended for minors. Its use is limited to persons over the minimum legal age applicable in each jurisdiction, and in any case, to persons over 16 years of age within the European Economic Area, unless they have the proper authorisation of their legal representatives.

SYNKROSS SOLUTIONS, S.L. does not knowingly collect personal data from minors. If it becomes aware that personal data of a minor has been collected without proper authorisation, the necessary measures will be taken to delete it.

FLIPLY may carry out automated data processing in order to personalise the user experience, such as product recommendations, content prioritisation or feature enhancement. These processing activities do not involve the adoption of automated decisions with legal effects on the user or that significantly affect them in a similar manner.