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Privacy Policy

Version 2.1 · Last updated: 20 July 2026

Contents

  1. Who We Are & Scope
  2. Information We Collect
  3. Sensitive (Special-Category) Personal Data
  4. How We Use Your Data & Legal Bases
  5. Location Data
  6. Age & Identity Verification (Didit)
  7. AI & Automated Processing
  8. Safety, Moderation & Anti-Abuse
  9. Connected Services & Third-Party Integrations
  10. Advertising & Rewarded Ads
  11. Cookies & Similar Technologies
  12. How We Share Your Personal Information
  13. International Transfers & Where Your Information Is Stored
  14. Data Retention
  15. Your Privacy Rights & Choices
  16. Children
  17. Security
  18. Changes to This Privacy Policy
  19. Contact & Complaints

1. Who We Are & Scope

Flare (“Flare”, “we”, “us”, “our”) is operated by Backroom Studio Ltd, a company registered in the United Kingdom with its registered office in London.

For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and other applicable privacy legislation, Backroom Studio Ltd acts as the data controller for the personal information described in this Privacy Policy.

This Privacy Policy explains how Flare collects, uses, stores, protects, shares and otherwise processes personal information when you use:

  • the Flare mobile applications for iOS and Android;
  • the Flare website (currently available at joinflare.io);
  • companion applications, including wearable applications such as the Apple Watch app;
  • future websites, applications or digital services operated by Flare that expressly reference this Privacy Policy.

This Privacy Policy should be read together with our:

  • Terms of Service;
  • Community Guidelines;
  • Safety Centre;
  • Cookie Policy (where applicable); and
  • any feature-specific notices presented within the Platform.

Together, these documents explain how Flare operates and how we protect our users.

Where this Privacy Policy refers to “the Platform”, this includes all Flare services described above.

Adults-Only Platform

Flare is designed exclusively for adults aged 18 years or older.

We do not knowingly permit anyone under the age of 18 to create an account or use the Platform.

To help enforce this requirement, Flare uses age-assurance technology provided by Didit, as described in Section 6.

Our Privacy Principles

We designed Flare around several core privacy principles:

  • collecting only the information reasonably necessary to operate the Platform;
  • giving users meaningful privacy controls;
  • protecting sensitive information;
  • applying data minimisation wherever possible;
  • using trusted specialist providers for security-sensitive processes;
  • continuously improving our privacy and security practices.

We regularly review our systems to ensure they remain appropriate as technology, legal requirements and user expectations evolve.

International Users

Flare is available in multiple countries.

Because privacy laws differ between jurisdictions, some features, notices, verification requirements and privacy rights may vary depending on where you use the Platform.

Where local law provides additional protections, those protections will apply.

Your Agreement

By creating an account or using Flare, you acknowledge that your personal information will be processed as described in this Privacy Policy.

Where applicable law requires your consent-for example, for processing certain sensitive personal information or delivering personalised advertising-we will request that consent separately before processing begins.

2. Information We Collect

Flare collects information in different ways depending on how you use the Platform, the features you choose to use and the permissions you grant on your device.

Some information is required to provide the Service, while other information is optional and only collected if you choose to use certain features.

We aim to collect only the information reasonably necessary to operate, improve and protect Flare and its users.

Account Registration & Authentication

When you create a Flare account, we collect information necessary to establish and secure your account.

This may include:

  • Email address.
  • Date of birth.
  • Password (stored only as a secure cryptographic hash through our authentication provider).
  • Authentication credentials.
  • Account identifier.
  • Country or region.
  • Language preference.

Depending on the sign-in method you choose, we may also process:

  • Passkeys (WebAuthn).
  • Two-factor authentication (2FA).
  • Recovery information.
  • Security tokens.

To reduce fraud and abuse, Flare may refuse registrations using disposable, temporary or anonymous email services.

Social Sign-In

You may choose to register or sign in using supported third-party identity providers.

These may include:

  • Apple.
  • Google.
  • Meta (Facebook).
  • X.
  • Other providers introduced in the future.

When using social sign-in, the provider shares only the information necessary to authenticate you and create your Flare account.

Depending on the provider, this may include:

  • Name.
  • Email address.
  • Account identifier.
  • Profile image (where authorised).

Flare never receives your password for those services.

Your use of those services remains subject to the provider’s own privacy policy.

Profile Information

Your profile contains information that you choose to provide.

Examples include:

  • Display name.
  • Username.
  • Age.
  • Pronouns.
  • Gender identity.
  • Sexual orientation.
  • Relationship status.
  • Relationship intentions.
  • Biography.
  • Interests.
  • Tribes.
  • Languages.
  • Physical characteristics.
  • Lifestyle preferences.
  • Health information you voluntarily choose to share.
  • Occupation.
  • Education.
  • Hobbies.
  • Social links.
  • Gaming profiles.

Many profile fields are optional.

You may edit or remove most profile information at any time.

Some profile information may be visible to other users depending on your privacy settings.

Photos, Videos & Media

You may upload:

  • Profile photos.
  • Profile videos.
  • Community photos.
  • Meetup photos.
  • Venue photos.
  • Service photos.
  • Chat media.
  • Voice messages.
  • Private Album content.

Media uploaded to Flare may be processed to:

  • Display it correctly.
  • Optimise file size.
  • Generate thumbnails.
  • Protect platform security.
  • Detect prohibited content.
  • Prevent abuse.

Media uploaded to public areas of the Platform may be visible according to your privacy settings.

Private Album content remains accessible only to users you authorise.

Private Albums

Private Albums allow you to share selected photographs or videos with individual users.

When using Private Albums, Flare processes information including:

  • Album ownership.
  • Users granted access.
  • Access history.
  • Shared media.
  • Permission changes.
  • Revoked access.
  • Album settings.

To help protect private content, Flare may apply visible or invisible account-specific identifiers, digital watermarks or similar protective technologies to eligible content.

These protections are intended to discourage unauthorised sharing and assist investigations where private content is distributed without permission.

The existence of these protections does not guarantee that every unauthorised disclosure can be detected or prevented.

Messages, Calls & Shared Content

Flare allows users to communicate through:

  • Direct Messages.
  • Group Chats.
  • Community Chats.
  • Meetup Chats.
  • Voice messages.
  • Voice calls.
  • Video calls.
  • Shared media.
  • View-once content.
  • Shared locations.

Voice and video communications are transmitted through our communication provider and are not routinely recorded by Flare.

Messages may be processed where reasonably necessary to:

  • Deliver communications.
  • Maintain security.
  • Detect abuse.
  • Investigate reports.
  • Comply with legal obligations.

Flare does not routinely monitor every private conversation.

Matches, Discovery & Interactions

To operate discovery features, Flare processes information relating to your interactions.

Examples include:

  • Likes.
  • Passes.
  • Matches.
  • Taps.
  • Profile views (where supported).
  • Blocks.
  • Reports.
  • Discovery preferences.
  • Search preferences.
  • Recommendation preferences.

These interactions help operate features including:

  • Open.
  • Nearby.
  • Suggested Users.
  • Suggested Communities.
  • Suggested Meetups.
  • Suggested Venues.
  • Suggested Services.

Communities

If you participate in Communities, Flare processes information including:

  • Communities created.
  • Community memberships.
  • Community ownership.
  • Moderator roles.
  • Community posts.
  • Comments.
  • Reactions.
  • Membership requests.
  • Community reports.
  • Community settings.

This information enables Community management, moderation and participation.

Meetups

When using Meetups, Flare may process:

  • Meetups you create.
  • Meetups you attend.
  • RSVP status.
  • Attendance history.
  • Host status.
  • Co-host permissions.
  • Event reviews.
  • Safety check-ins.
  • Venue selections.
  • Meetup communications.

This information helps operate Meetup features and improve user safety.

Venues

When interacting with Venues, Flare may process:

  • Saved venues.
  • Venue reviews.
  • Ratings.
  • Photos.
  • Favourite venues.
  • Check-ins.
  • Venue reports.
  • Future business interactions.

Venue check-in information shown publicly is presented in aggregated or anonymised form where appropriate.

Services

When using Services, Flare may process:

  • Service listings.
  • Listing descriptions.
  • Listing photographs.
  • Listing duration.
  • Promotion status.
  • Service enquiries.
  • Reviews.
  • Listing moderation history.
  • Listing expiry dates.

Commercial negotiations, including prices, normally occur through Direct Messages.

Music & Connected Accounts

Where you choose to connect supported music services such as Spotify or Apple Music, Flare may process limited information including:

  • Top artists.
  • Top tracks.
  • Selected playlists.

Only the information necessary for the features you enable is processed.

You may disconnect these services at any time.

Location Information

With your permission, Flare collects location information to operate location-based features.

Depending on the feature, this may include:

  • GPS location.
  • Approximate location.
  • Country.
  • Region.
  • Time zone.
  • Location history required for specific safety features.

Your precise GPS location is never displayed publicly.

Further information is provided in Section 5.

Device & Technical Information

To operate securely, Flare processes technical information including:

  • Device type.
  • Operating system.
  • Browser type.
  • App version.
  • IP address.
  • Push notification tokens.
  • Device identifiers.
  • Diagnostic information.
  • Crash reports.
  • Security events.

We use this information to:

  • Protect accounts.
  • Prevent fraud.
  • Improve reliability.
  • Diagnose technical issues.
  • Maintain security.

Verification Information

Where verification is required, Didit processes:

  • Selfies.
  • Liveness checks.
  • Government-issued identity documents.

Flare receives only:

  • Verification outcome.
  • Verification status.
  • Resolved country.
  • Verification timestamps where necessary.

Flare does not receive or permanently store verification selfies, videos or identity documents.

Further information is provided in Section 6.

Payments & Subscriptions

If you purchase subscriptions or paid features, Flare processes information necessary to manage your entitlements, including:

  • Subscription status.
  • Purchase confirmation.
  • Product purchased.
  • Renewal status.
  • Expiry dates.
  • Promotional credits.

Flare does not receive your full payment card information.

Payments are processed by authorised third-party payment providers.

Support & Reports

If you contact Flare or submit a report, we may process:

  • Support messages.
  • Safety reports.
  • Appeals.
  • Uploaded evidence.
  • Communication history.
  • Investigation records.
  • Resolution history.

This information helps us investigate issues, protect users and improve our services.

Automatically Collected Information

Certain information is collected automatically when you use Flare.

Examples include:

  • Session activity.
  • Feature usage.
  • Performance metrics.
  • Security logs.
  • Error reports.
  • Device events.
  • Authentication events.

This information helps us maintain, improve and secure the Platform.

3. Sensitive (Special-Category) Personal Data

Our Commitment

Flare is an adults-only LGBTQ+ platform designed to help people build meaningful friendships, relationships, communities and professional connections.

Because of the nature of our Platform, some information that users choose to provide may be considered special-category (or sensitive) personal data under privacy laws such as the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR) and similar legislation in other jurisdictions.

We recognise that this information deserves a higher level of protection.

We process sensitive personal data only where necessary, lawful and proportionate, and we apply additional safeguards designed to protect your privacy.

Types of Sensitive Data

Depending on how you use Flare, sensitive personal data may include information that you voluntarily choose to provide, such as:

  • Sexual orientation.
  • Gender identity.
  • Pronouns.
  • Relationship preferences.
  • Relationship intentions.
  • Health-related information.
  • HIV status or other health information where you voluntarily choose to disclose it.
  • Accessibility requirements.
  • Other information that may reveal aspects of your identity or personal life.

Providing this information is entirely optional unless a specific feature requires it.

You may edit or remove most sensitive profile information at any time.

Why We Process Sensitive Data

Sensitive personal data is processed only for purposes directly connected with operating the Platform.

Examples include:

  • Displaying your profile.
  • Helping users discover compatible people.
  • Supporting Communities.
  • Improving discovery features.
  • Personalising certain profile features that you choose to use.
  • Providing accessibility features.
  • Protecting user safety.

We do not process sensitive data for advertising purposes.

We do not sell sensitive personal data.

Your Choice

Most sensitive profile fields are optional.

You decide:

  • Whether to provide them.
  • Whether to display them.
  • Who can view them where privacy controls are available.
  • Whether to edit or remove them later.

Choosing not to provide sensitive information will not prevent you from using most features of Flare, although some optional features may work differently.

Legal Basis

Where UK GDPR, EU GDPR or similar privacy laws apply, Flare generally processes sensitive personal data on one or more of the following legal bases:

  • Your explicit consent.
  • Information that you have chosen to make public on your profile where permitted by law.
  • Compliance with legal obligations.
  • Protection of substantial public interests where applicable.
  • Other lawful bases permitted by applicable legislation.

Where processing relies on your consent, you may withdraw that consent at any time by removing the relevant information or adjusting your privacy settings, without affecting processing already carried out.

Biometric Information

Flare itself does not collect, permanently store or create biometric templates from your face.

Where age or identity verification is required, facial images, liveness checks and identity documents are processed exclusively by Didit, our independent age and identity verification provider.

Flare receives only the verification result required to operate the Platform, such as:

  • Verified.
  • In Review.
  • Declined.
  • Resolved country.

Flare does not receive or permanently store:

  • Verification selfies.
  • Liveness videos.
  • Government-issued identity documents.
  • Facial recognition templates.
  • Biometric identifiers.

Verification information is processed solely for age assurance, identity verification where required, fraud prevention and community safety.

It is never used by Flare for:

  • Advertising.
  • Marketing.
  • Behavioural profiling.
  • Facial recognition.
  • AI model training.
  • Product recommendations.

Further information about verification is provided in Section 6.

Health Information

Some users may voluntarily choose to include health-related information in their profile.

Examples might include:

  • Accessibility information.
  • Health practices.
  • Other health information they wish to share.

Flare does not verify the accuracy of this information.

Users remain responsible for deciding whether they wish to disclose any health-related information publicly.

We encourage users to share only information they are comfortable making available to others.

Protecting Sensitive Data

Sensitive personal data receives additional protection through technical and organisational safeguards.

These may include:

  • Restricted internal access.
  • Role-based permissions.
  • Encryption where appropriate.
  • Security monitoring.
  • Data minimisation.
  • Staff confidentiality obligations.
  • Secure verification processes.
  • Regular security reviews.

Access to sensitive information is limited to authorised personnel who require it for legitimate operational purposes.

AI and Sensitive Data

Flare’s AI systems may process certain content that contains sensitive information only where necessary to provide features requested by users or to help protect the Platform.

Examples include:

  • Moderating uploaded photos.
  • Translating messages when requested.
  • Assisting moderators with reported content.

Sensitive personal data is not used by Flare to:

  • Deliver targeted advertising.
  • Build advertising profiles.
  • Train Flare’s own AI models.
  • Make solely automated decisions that produce legal or similarly significant effects.

Where significant moderation decisions are required, human moderators review the matter before final action is taken whenever appropriate.

Sharing Sensitive Data

Flare does not disclose sensitive personal data to advertisers.

Sensitive information is shared only where reasonably necessary, including:

  • With service providers acting on our behalf under appropriate contractual safeguards.
  • Where you instruct us to share it through a feature you choose to use.
  • Where required by law.
  • To protect the safety of users or others.
  • To respond to lawful requests from competent authorities.

Any sharing is limited to the minimum information reasonably necessary for the relevant purpose.

Your Rights

Where applicable privacy laws apply, you may have rights relating to sensitive personal data, including the right to:

  • Access your information.
  • Correct inaccurate information.
  • Delete sensitive information.
  • Withdraw consent where processing relies on consent.
  • Restrict certain processing.
  • Object to certain processing.
  • Lodge a complaint with the appropriate supervisory authority.

Information about exercising these rights is provided in Section 15.

4. How We Use Your Data & Legal Bases

Our Approach

Flare processes personal information only where there is a lawful reason to do so.

The legal basis we rely upon depends on:

  • The feature you use.
  • The type of information involved.
  • The purpose of the processing.
  • The laws that apply in your jurisdiction.

Where UK GDPR, EU GDPR or similar privacy laws apply, we rely on one or more of the following legal bases:

  • Performance of a contract.
  • Your consent.
  • Legitimate interests.
  • Compliance with legal obligations.
  • Protection of vital interests.
  • Other lawful bases permitted by applicable law.

Providing the Platform

We process personal information to create and operate your Flare account and provide the features you choose to use.

Examples include:

  • Creating your account.
  • Authenticating your identity.
  • Displaying your profile.
  • Matching you with other users.
  • Delivering messages.
  • Operating Communities.
  • Managing Meetups.
  • Operating Services.
  • Displaying Venues.
  • Providing Private Albums.
  • Operating Open and Nearby.

Legal basis

  • Performance of our contract with you.

Managing Your Account

We use your information to:

  • Verify your account.
  • Maintain account security.
  • Reset passwords.
  • Manage subscriptions.
  • Respond to support requests.
  • Update account settings.
  • Recover access where appropriate.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Age & Identity Verification

We process information necessary to:

  • Confirm users are 18 or older.
  • Comply with online safety laws.
  • Prevent underage access.
  • Support identity verification where required.
  • Reduce fraud.

Age estimation, liveness checks and identity verification are performed by Didit.

Flare receives only the verification outcome necessary to operate the Platform.

Legal basis

  • Compliance with legal obligations.
  • Legitimate interests in maintaining a safe adults-only community.

Providing Discovery Features

To help users discover people, Communities, Meetups, Venues and Services, Flare processes information such as:

  • Interests.
  • Preferences.
  • Approximate location.
  • Discovery settings.
  • Open status.
  • Nearby settings.
  • Previous interactions.

Recommendations are generated automatically but are not intended to produce legal or similarly significant effects.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Processing Location Information

Where you grant permission, Flare processes location information to:

  • Show nearby users.
  • Display nearby Venues.
  • Display Meetups.
  • Enable Open.
  • Support Travel Mode.
  • Improve safety features.
  • Apply country-specific legal requirements.

Your precise GPS location is never displayed publicly.

Legal basis

  • Your consent for device location.
  • Performance of our contract.

Moderation & Community Safety

Flare processes information to:

  • Review reports.
  • Detect scams.
  • Detect fake accounts.
  • Detect spam.
  • Detect ban evasion.
  • Investigate abuse.
  • Protect vulnerable users.
  • Enforce the Community Guidelines.
  • Enforce the Terms of Service.

Moderation may involve automated systems and trained human moderators.

Legal basis

  • Legitimate interests.
  • Compliance with legal obligations.
  • Protection of vital interests where applicable.

AI-Assisted Features

Flare uses artificial intelligence to support features such as:

  • Photo moderation.
  • Translation.
  • Report triage.
  • Spam detection.
  • Fraud detection.
  • Content classification.

AI assists human decision-making but does not replace it.

Flare does not use sensitive profile information, verification selfies or identity documents to train its own AI models or for advertising.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Services

Flare processes information relating to Services to:

  • Publish listings.
  • Display listings.
  • Process listing extensions.
  • Support enquiries.
  • Display reviews.
  • Moderate listings.
  • Prevent fraud.

Commercial negotiations normally occur directly between users through Direct Messages.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Communities

Flare processes Community information to:

  • Create Communities.
  • Manage membership.
  • Support moderators.
  • Deliver Community Chats.
  • Moderate Community content.
  • Recommend Communities.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Meetups

Flare processes Meetup information to:

  • Create Meetups.
  • Manage attendance.
  • Notify attendees.
  • Support Hosts.
  • Operate safety check-ins.
  • Display event information.
  • Improve Meetup recommendations.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Venues

Flare processes Venue information to:

  • Display Venues.
  • Show reviews.
  • Display ratings.
  • Operate check-ins.
  • Recommend Venues.
  • Moderate Venue content.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Communications

We process communications to:

  • Deliver messages.
  • Deliver voice and video calls.
  • Share media.
  • Support Private Albums.
  • Provide notifications.
  • Investigate reports where appropriate.

Flare does not routinely monitor every private communication.

Legal basis

  • Performance of our contract.
  • Legitimate interests.
  • Compliance with legal obligations where applicable.

Payments & Subscriptions

We process payment-related information to:

  • Confirm purchases.
  • Manage subscriptions.
  • Provide paid features.
  • Prevent payment fraud.
  • Process refunds where applicable.

Payment card information is processed by authorised payment providers rather than Flare.

Legal basis

  • Performance of our contract.
  • Compliance with legal obligations.

Customer Support

When you contact us, we process information necessary to:

  • Respond to enquiries.
  • Resolve technical issues.
  • Investigate reports.
  • Process appeals.
  • Improve support services.

Legal basis

  • Performance of our contract.
  • Legitimate interests.

Analytics & Improvements

We analyse how the Platform is used to:

  • Improve reliability.
  • Develop new features.
  • Fix bugs.
  • Understand usage patterns.
  • Improve accessibility.
  • Improve performance.

Where required by law, we obtain consent before using analytics technologies.

Legal basis

  • Legitimate interests.
  • Consent where required.

Advertising

Free users may be shown advertisements.

Where required by law:

  • Personalised advertising relies on your consent.
  • Non-personalised advertising relies on legitimate interests or other lawful bases permitted by applicable law.

Flare does not share your messages, profile photos, verification documents, Private Album content or sensitive personal information with advertising partners for advertising purposes.

Legal basis

  • Consent.
  • Legitimate interests.

Security

We process information to:

  • Protect accounts.
  • Detect fraud.
  • Detect suspicious activity.
  • Secure authentication.
  • Prevent abuse.
  • Protect Platform integrity.

This may include security logs, authentication records and device information.

Legal basis

  • Legitimate interests.
  • Compliance with legal obligations.

Compliance with Law

Flare may process personal information where necessary to:

  • Respond to lawful requests.
  • Comply with court orders.
  • Meet regulatory obligations.
  • Protect users.
  • Prevent serious harm.
  • Cooperate with competent authorities where legally required.

Legal basis

  • Compliance with legal obligations.
  • Legitimate interests.
  • Protection of vital interests where applicable.

Legitimate Interests

Where we rely on legitimate interests, we carefully assess whether our interests are balanced against your rights and freedoms.

Examples include:

  • Improving security.
  • Preventing fraud.
  • Operating Communities.
  • Improving recommendations.
  • Maintaining platform stability.
  • Protecting users from abuse.

Where your interests override ours, we will not rely on legitimate interests as the legal basis.

Withdrawing Consent

Where processing relies on your consent, you may withdraw that consent at any time.

Examples include consent for:

  • Device location.
  • Personalised advertising.
  • Optional sensitive profile information.
  • Connected music services.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

5. Location Data

Our Approach

Location is one of Flare’s core features.

It allows users to discover people, Communities, Meetups, Venues and Services nearby while maintaining control over their privacy.

Flare is designed so that your precise GPS location is never displayed publicly to other users.

Instead, we use approximate location information and privacy protections to help reduce the risk of users identifying your exact whereabouts.

Information We Collect

With your permission, Flare may collect location information including:

  • GPS coordinates.
  • Approximate location.
  • Country.
  • Region.
  • City or town.
  • Time zone.
  • Device location permissions.
  • Location accuracy information where necessary.

We may also estimate your approximate location from your IP address where necessary to:

  • Apply country-specific legal requirements.
  • Protect the Platform from fraud.
  • Improve security.
  • Provide basic regional functionality where GPS permission has not been granted.

How We Use Location

Location information may be used to operate features including:

  • Nearby.
  • Open.
  • Meetups.
  • Venue discovery.
  • Services.
  • Communities.
  • Travel Mode.
  • Suggested users.
  • Suggested Venues.
  • Suggested Meetups.
  • Suggested Services.

Location may also help:

  • Improve search results.
  • Prevent location fraud.
  • Detect suspicious activity.
  • Apply age-assurance rules for your country.
  • Improve platform safety.

Location Permissions

Flare requests access to your device’s location only with your permission.

Depending on your device, you may choose to grant:

  • Precise location.
  • Approximate location.
  • Location only while using the app.
  • No location access.

You may change these permissions at any time through your device settings.

Some Flare features may become unavailable or have reduced functionality if location access is disabled.

Protecting Your Privacy

Flare is designed so that your exact GPS coordinates are not shown to other users.

Instead, the Platform may display:

  • Approximate distances.
  • General proximity.
  • Nearby ordering.

Distance information may be intentionally adjusted or “fuzzed” to reduce the likelihood that another user can determine your precise location.

The exact methods used to protect location privacy may change over time as we improve the Platform.

For security reasons, we do not publicly disclose all of the techniques used.

Open

If you enable Open, your profile may become more discoverable to nearby users according to your chosen settings.

Enabling Open is entirely optional.

You may enable or disable Open at any time through the Platform.

Turning Open off may reduce how often your profile appears in certain discovery features.

Nearby

Nearby helps users discover other members who are geographically close.

Nearby uses approximate location information rather than displaying your exact location.

Your visibility within Nearby depends on factors including:

  • Your privacy settings.
  • Your account status.
  • Device permissions.
  • Platform safety measures.
  • Applicable legal requirements.

You may hide your approximate distance where that setting is available.

Travel Mode

Where available, Travel Mode allows users to explore other locations without physically travelling there.

When using Travel Mode:

  • Your actual location is not replaced for security purposes.
  • Discovery features may reflect the selected destination.
  • Some location-dependent safety measures may continue to rely on your actual region where legally required.

Meetups & Venues

Location information helps Flare display:

  • Meetup locations.
  • Venue maps.
  • Venue recommendations.
  • Event discovery.
  • Navigation information where supported.

When you attend a Meetup or check in at a Venue, other users may see information that you have chosen to make visible through that feature.

Aggregated statistics (such as the number of people currently at a Venue) may be displayed without identifying individual users.

Services

Location information helps users discover nearby Services.

Providers may choose to display:

  • General service areas.
  • Cities.
  • Regions.

Flare encourages Service providers not to publish unnecessary personal address information unless essential for the Service being offered.

Location Integrity

To maintain the integrity of location-based features, Flare may use measures designed to detect suspicious location activity.

Examples include:

  • Location spoofing.
  • Mock GPS applications.
  • Impossible travel patterns.
  • Automated location manipulation.

These checks help protect users and improve the reliability of Nearby, Meetups and other location-based features.

Background Location

Flare does not continuously track your location in the background.

Location information is collected only when reasonably necessary to operate features you choose to use and in accordance with your device permissions.

Where background location functionality is introduced in the future for optional safety features, Flare will clearly explain how it works and request any permissions required by law.

Retention of Location Information

Flare retains location information only for as long as reasonably necessary to:

  • Operate the Platform.
  • Maintain security.
  • Investigate abuse.
  • Support safety features.
  • Comply with legal obligations.

Location history is not retained indefinitely.

Further information is provided in Section 14 (Data Retention).

Your Choices

You remain in control of your location information.

Depending on the feature, you may be able to:

  • Disable device location.
  • Hide approximate distance.
  • Disable Open.
  • Leave Nearby.
  • Disable Travel Mode.
  • Delete your account.

Some choices may reduce the availability or accuracy of location-based features.

International Requirements

Different countries have different legal requirements relating to location information and age assurance.

Flare may use your approximate country or region to:

  • Apply local legal requirements.
  • Determine whether age verification is required.
  • Deliver region-specific safety features.
  • Display information relevant to your jurisdiction.

6. Age & Identity Verification (Didit)

Our Commitment

Flare is an adults-only platform intended exclusively for individuals aged 18 years or older.

To help maintain a safe community, protect users and comply with applicable laws, Flare uses age and identity verification measures.

We have partnered with Didit, an independent specialist in digital identity and age assurance, to perform these checks.

Flare has intentionally designed its verification process using the principles of privacy by design and data minimisation.

Where possible, Flare receives only the information necessary to determine whether verification has been successfully completed.

Why Verification Is Required

Verification helps Flare:

  • Prevent access by minors.
  • Maintain an adults-only community.
  • Comply with online safety legislation.
  • Reduce fraud.
  • Reduce impersonation.
  • Improve user trust.
  • Protect Community Hosts.
  • Protect Meetup Hosts.
  • Protect Service providers and customers.
  • Protect vulnerable users.

Verification also helps maintain the integrity of certain Platform features that require a higher level of trust.

Age Estimation

Where available, users may complete age verification through an age estimation process.

This involves:

  • Taking a selfie.
  • Completing a liveness check.
  • Processing the information using Didit’s age estimation technology.

The processing takes place on Didit’s secure systems.

Flare receives only the verification outcome, such as:

  • Approved.
  • In Review.
  • Declined.

Flare does not receive:

  • The selfie.
  • The liveness video.
  • Facial images.
  • Facial recognition templates.

Age estimation is used solely to determine whether you appear to meet Flare’s minimum age requirement.

Identity Verification

Additional identity verification may be required where:

  • Age estimation cannot confidently confirm that you are an adult.
  • You wish to host Meetups.
  • You wish to operate certain Venue features.
  • You wish to provide certain Services.
  • Verification is required by law.
  • Fraud prevention requires additional verification.

Identity verification may require:

  • A government-issued identity document.
  • Additional liveness checks.
  • Document authenticity verification.

These checks are performed entirely by Didit.

Flare receives only the verification result required to operate the Platform.

Information Processed by Didit

Depending on the verification method used, Didit may process:

  • Selfies.
  • Liveness videos.
  • Government-issued identity documents.
  • Facial images.
  • Document security features.
  • Device information necessary to complete verification.

This information is processed by Didit in accordance with its own privacy obligations and applicable law.

Information Received by Flare

Following verification, Flare normally receives only limited information necessary to operate the Platform.

Examples include:

  • Verification status.
  • Verification outcome.
  • Resolved country.
  • Verification timestamp where required.
  • Verification method where operationally necessary.

Flare does not routinely receive:

  • Verification selfies.
  • Liveness recordings.
  • Identity document images.
  • Facial recognition templates.
  • Biometric measurements.

This significantly reduces the amount of sensitive information processed directly by Flare.

Automatic Deletion

Flare is committed to minimising the retention of sensitive verification information.

Once a verification session reaches a final outcome:

  • Flare automatically instructs Didit to delete the verification session using our secure integration.
  • Verification selfies are deleted.
  • Liveness videos are deleted.
  • Identity document images are deleted.
  • Associated verification files are removed from Didit’s systems in accordance with our integration and retention policies.

Flare retains only the verification status necessary to continue operating your account.

Biometric Information

Facial images and identity documents processed during verification may constitute biometric or special-category personal data under laws such as:

  • UK GDPR.
  • EU GDPR.
  • Other applicable privacy legislation.

Flare does not use this information for:

  • Advertising.
  • Marketing.
  • Behavioural profiling.
  • Facial recognition outside verification.
  • Product recommendations.
  • AI model training.

Verification data is processed solely for:

  • Age assurance.
  • Identity verification.
  • Fraud prevention.
  • Platform safety.
  • Compliance with legal obligations.

Country-Specific Verification

Verification requirements may differ depending on:

  • Your country.
  • Your region.
  • Applicable laws.
  • Regulatory requirements.

Flare uses your resolved country to determine which verification requirements apply.

Examples may include legislation relating to:

  • The UK Online Safety Act.
  • EU Digital Services Act.
  • Australian online safety legislation.
  • Other national age assurance requirements.

Verification requirements may change as laws evolve.

Verification Refusal

If required verification cannot be completed successfully, Flare may:

  • Restrict access to certain features.
  • Delay activation of your account.
  • Prevent creation of a new account.
  • Decline access to age-restricted functionality.

This helps protect both users and the integrity of the Platform.

Reverification

Flare may request that a user completes verification again where reasonably necessary.

Examples include:

  • Suspected account compromise.
  • Fraud investigations.
  • Significant account changes.
  • Legal requirements.
  • Updates to verification technology.
  • Safety investigations.

Reverification requests are made only where reasonably necessary.

Verification Providers

Flare may change verification providers in the future if necessary to improve:

  • Security.
  • Accuracy.
  • User privacy.
  • Legal compliance.
  • Platform functionality.

Where such changes materially affect how your personal information is processed, this Privacy Policy will be updated and users will be informed where required by law.

Your Rights

Where applicable law grants you rights relating to verification information, those rights may be exercised in accordance with:

  • This Privacy Policy.
  • Didit’s Privacy Policy.
  • Applicable privacy legislation.

Because Flare does not retain verification selfies or identity documents, requests relating to those materials may need to be directed to Didit where appropriate.

Security

Verification is protected using technical and organisational security measures designed to safeguard sensitive information during transmission and processing.

Flare and Didit both implement security measures appropriate to the nature of the information being processed.

7. AI & Automated Processing

Our Approach

Flare uses artificial intelligence (“AI”), machine learning and other automated technologies to help operate the Platform, improve user experience and protect our community.

AI is designed to assist-not replace-human judgement.

Where appropriate, important moderation decisions are reviewed by trained human moderators before becoming final.

Flare is committed to using AI responsibly, transparently and in accordance with applicable privacy and online safety laws.

Why We Use AI

AI helps us:

  • Protect users.
  • Detect harmful content.
  • Improve platform safety.
  • Reduce spam.
  • Detect scams.
  • Identify fake accounts.
  • Improve translations.
  • Improve accessibility.
  • Improve discovery features.
  • Improve platform performance.

AI allows Flare to respond more quickly to harmful behaviour while helping moderators focus on reports requiring human judgement.

AI Photo & Video Moderation

When users upload photographs or videos, AI may analyse the content to identify material that may violate our Community Guidelines or applicable law.

This may include detecting:

  • Nudity.
  • Sexually explicit content.
  • Graphic violence.
  • Possible child safety concerns.
  • Illegal content.
  • Prohibited commercial content.
  • Spam images.
  • Manipulated or deceptive media.

Where appropriate:

  • Safe content may be approved automatically.
  • Clearly prohibited content may be blocked automatically.
  • Borderline content may be referred to trained human moderators for review.

The purpose of this processing is to help maintain a safe community.

AI Report Triage

When users submit reports, AI may assist by:

  • Organising reports.
  • Identifying duplicate reports.
  • Summarising information.
  • Identifying urgent safety concerns.
  • Prioritising reports based on risk.

AI recommendations assist moderators but do not automatically determine the final outcome of serious moderation cases.

AI Translation

Where users choose to translate messages or other content, the relevant text may be securely processed by Flare’s AI provider to generate a translation.

Translation is performed only when requested by a user.

Translated content is intended to improve communication and may not always be perfectly accurate.

Users should not rely on AI translations for legal, medical or other professional purposes.

AI-Assisted Discovery

Flare may use AI and other automated systems to improve recommendations for:

  • People.
  • Communities.
  • Meetups.
  • Venues.
  • Services.
  • Interests.
  • Suggested connections.

Recommendations may consider factors such as:

  • Profile information.
  • Interests.
  • Approximate location.
  • Previous interactions.
  • Community participation.
  • Meetup attendance.
  • Privacy settings.
  • Discovery preferences.

These recommendations are intended to improve your experience and do not produce legal or similarly significant effects.

AI Fraud Detection

AI may help identify behaviour associated with:

  • Fake accounts.
  • Spam.
  • Account compromise.
  • Ban evasion.
  • Payment fraud.
  • Scam activity.
  • Automated account creation.
  • Suspicious behavioural patterns.

This processing helps protect users and maintain the integrity of the Platform.

Human Review

Flare recognises that AI is not perfect.

Where reasonably appropriate, trained human moderators review matters requiring context or judgement, including:

  • Serious safety reports.
  • Permanent account termination.
  • Appeals.
  • Child safety concerns.
  • Complex harassment cases.
  • Identity disputes.

Human moderators may confirm, modify or overturn AI-assisted recommendations.

Automated Decisions

Flare does not make decisions that produce legal or similarly significant effects based solely on automated processing where prohibited by applicable law.

Where automated systems assist moderation, appropriate human review is carried out before significant enforcement decisions where required.

Where applicable law provides rights relating to automated decision-making, users may exercise those rights in accordance with Section 15 of this Privacy Policy.

Information Processed by AI

Depending on the feature being used, AI may process information including:

  • Uploaded photographs.
  • Uploaded videos.
  • Reported content.
  • Messages submitted for translation.
  • Safety reports.
  • Metadata reasonably necessary to provide the requested feature.

AI processing is limited to the information reasonably necessary for the relevant purpose.

Information Not Used for AI Training

Flare does not use the following information to train its own AI models:

  • Verification selfies.
  • Liveness videos.
  • Government-issued identity documents.
  • Biometric information.
  • Sensitive profile information for advertising.
  • Private Album content.
  • Private messages, except where individually submitted for moderation following a report or submitted for translation at your request.

Where Flare works with third-party AI providers, processing is governed by contractual safeguards and applicable privacy laws.

AI Providers

Flare currently uses Anthropic (Claude) to support certain AI-powered features.

Examples include:

  • Photo moderation.
  • Report triage.
  • Translation.

Flare may introduce additional AI providers in the future where necessary to improve:

  • Accuracy.
  • Safety.
  • Reliability.
  • Accessibility.
  • Performance.

If changes materially affect how personal information is processed, we will update this Privacy Policy and notify users where required by law.

Security & Confidentiality

Information processed through AI features is protected using appropriate technical and organisational security measures.

AI providers engaged by Flare are required to process personal information only for authorised purposes and in accordance with contractual obligations and applicable privacy laws.

We seek to minimise the amount of personal information shared with AI providers wherever reasonably possible.

Continuous Improvement

Flare continually evaluates and improves its AI systems to:

  • Reduce false positives.
  • Reduce false negatives.
  • Improve moderation accuracy.
  • Improve accessibility.
  • Improve translations.
  • Improve user safety.
  • Improve fraud detection.

These improvements are designed to enhance the Platform while respecting user privacy and applicable legal requirements.

Transparency

We believe users should understand when AI is involved in operating the Platform.

Where reasonably appropriate, Flare aims to explain:

  • Why AI is used.
  • What information is processed.
  • Whether human review is involved.
  • How users may challenge certain moderation decisions through the appeals process.

8. Safety, Moderation & Anti-Abuse

Our Commitment

Creating a safe, respectful and trustworthy community is one of Flare’s highest priorities.

To help achieve this, we process certain personal information to:

  • Protect users.
  • Detect harmful behaviour.
  • Prevent fraud.
  • Enforce our Community Guidelines.
  • Enforce our Terms of Service.
  • Comply with applicable laws.
  • Respond to safety reports.
  • Improve our moderation systems.

We aim to balance user privacy with our responsibility to maintain a safe platform.

Reporting Content & Behaviour

Users may report content or behaviour that they reasonably believe violates:

  • Our Community Guidelines.
  • Our Terms of Service.
  • Applicable law.

Reports may relate to:

  • Harassment.
  • Hate speech.
  • Bullying.
  • Fake profiles.
  • Scams.
  • Fraud.
  • Spam.
  • Child safety concerns.
  • Non-consensual sharing of intimate images.
  • Impersonation.
  • Abuse within Communities.
  • Unsafe Meetups.
  • Fraudulent Services.
  • False Venue reviews.
  • Other harmful behaviour.

When a report is submitted, we may process the information necessary to investigate and respond appropriately.

Information We Process During Investigations

Where reasonably necessary, we may process information such as:

  • The report itself.
  • Messages relevant to the report.
  • Photos or videos submitted as evidence.
  • User profile information.
  • Verification status.
  • Community activity.
  • Meetup participation.
  • Service listings.
  • Venue reviews.
  • Technical information relevant to the investigation.
  • Device and account security information.

We only process information that is reasonably necessary for the investigation.

AI-Assisted Moderation

Flare uses AI to help identify behaviour that may violate our rules.

AI may assist in identifying:

  • Spam.
  • Scam activity.
  • Fake accounts.
  • Explicit content.
  • Harassment.
  • Abuse.
  • Dangerous behaviour.
  • Fraud.
  • Child safety risks.
  • Prohibited Services.
  • Manipulated media.

AI helps moderators prioritise reports and identify potentially harmful content more quickly.

AI does not replace human judgement for significant moderation decisions.

Human Moderation

Many reports require context that automated systems cannot fully understand.

For that reason, Flare employs trained human moderators to review reports where appropriate.

Human moderators may consider:

  • Available evidence.
  • Context.
  • Previous reports.
  • Previous enforcement history.
  • User safety.
  • Applicable law.
  • Our Community Guidelines.
  • Our Terms of Service.

Moderators act in good faith using the information available at the time.

Protective Technologies

To help protect users and reduce misuse of the Platform, Flare may use protective technologies including:

  • Spam detection.
  • Fraud detection.
  • Device integrity checks.
  • Security monitoring.
  • Ban-evasion detection.
  • Digital watermarking.
  • Account-specific identifiers.
  • Screenshot attribution technology.
  • Media protection technologies.
  • Abuse detection systems.

These technologies are intended to protect users and maintain the integrity of the Platform.

For security reasons, we do not publicly disclose all technical details about how these systems operate.

Screenshot Protection

Certain private content, including eligible Private Album media and protected chats, may include security measures designed to discourage unauthorised sharing.

Depending on the device and operating system, Flare may:

  • Apply visible or invisible account-specific identifiers.
  • Apply digital watermarks.
  • Notify users that a screenshot has been taken where technically supported.
  • Restrict screenshots where supported by the operating system.

Operating system limitations mean that these protections are not available on every device.

Taking a screenshot does not grant permission to copy, distribute or publish another person’s content.

Detecting Unauthorised Sharing

Where Flare reasonably believes that private content has been shared without permission, we may investigate the matter.

As part of an investigation, we may use protective technologies incorporated into eligible content to help identify the account through which that content was originally accessed.

These technologies are intended to support investigations and discourage misuse.

They do not guarantee that every unauthorised disclosure can be detected or prevented.

Fraud Prevention

We process information to help prevent:

  • Fake accounts.
  • Identity fraud.
  • Payment fraud.
  • Account compromise.
  • Spam.
  • Automated abuse.
  • Ban evasion.
  • Location spoofing.
  • Coordinated malicious activity.

Fraud prevention helps protect both individual users and the wider Flare community.

Safety Records

To help maintain a safe Platform, Flare may retain limited records relating to:

  • Previous reports.
  • Warnings.
  • Suspensions.
  • Appeals.
  • Serious Community Guidelines violations.
  • Serious Terms of Service violations.
  • Fraud investigations.

These records help us:

  • Prevent repeated abuse.
  • Enforce previous decisions.
  • Protect vulnerable users.
  • Comply with legal obligations.

Retention periods are explained in Section 14.

Appeals

Where appropriate, users may appeal moderation decisions affecting their account.

Appeals may require us to process additional information provided by the user, including:

  • Supporting evidence.
  • Explanations.
  • Relevant documents.
  • Other information reasonably necessary to review the decision.

Appeals are reviewed fairly and independently where reasonably possible.

Cooperation with Authorities

Where required or permitted by applicable law, Flare may preserve relevant information and cooperate with competent authorities in relation to:

  • Child protection.
  • Serious criminal investigations.
  • Human trafficking.
  • Terrorism.
  • Fraud.
  • Court orders.
  • Other matters involving public safety.

Any disclosure is limited to what is required or permitted by law.

User Safety

Flare encourages users to:

  • Report harmful behaviour.
  • Block unwanted users.
  • Use available privacy controls.
  • Meet in public places.
  • Review our Safety Centre before meeting someone offline.
  • Contact local emergency services where immediate assistance is required.

Flare’s reporting tools do not replace emergency services.

Continuous Improvement

Flare continually reviews and improves its safety systems.

This may include:

  • Improving AI models.
  • Enhancing fraud detection.
  • Strengthening moderation tools.
  • Introducing new privacy protections.
  • Improving reporting systems.
  • Responding to emerging online threats.

These improvements are designed to better protect our users while respecting their privacy.

Your Privacy During Investigations

We recognise that investigations often involve sensitive personal information.

Where possible, Flare seeks to:

  • Limit access to authorised personnel.
  • Process only information reasonably necessary.
  • Protect the confidentiality of those involved.
  • Avoid unnecessary disclosure.
  • Respect the rights of all affected users.

Not every report results in enforcement action.

Each matter is assessed individually based on the available evidence.

9. Connected Services & Third-Party Integrations

Our Approach

Flare works with carefully selected third-party providers to help deliver, secure and improve the Platform.

These providers perform specific services on our behalf, such as:

  • Identity verification.
  • Authentication.
  • Cloud hosting.
  • Messaging.
  • Voice and video calling.
  • Artificial intelligence.
  • Analytics.
  • Advertising.
  • Payment processing.
  • Maps.
  • Music integrations.
  • Push notifications.
  • Email delivery.
  • Bot protection.

We only share the information reasonably necessary for each provider to perform the services we request.

Where providers process personal information on our behalf, they are required to do so in accordance with applicable privacy laws and appropriate contractual safeguards.

Supabase & Cloudflare

Flare uses Supabase and Cloudflare to provide core platform infrastructure.

These services help us operate:

  • User accounts.
  • Authentication.
  • Databases.
  • Realtime services.
  • Serverless functions.
  • Media storage.
  • Security.
  • Performance optimisation.

Photos, videos, voice messages and other uploaded media are securely stored using Cloudflare R2.

These providers process personal information only as necessary to provide their infrastructure services.

Stream

Flare uses Stream to provide:

  • Real-time messaging.
  • Group chats.
  • Community chats.
  • Meetup chats.
  • Voice calls.
  • Video calls.

Voice and video calls are transmitted in real time.

Flare does not routinely record voice or video calls.

Certain technical metadata may be processed to establish and maintain communications, improve reliability and protect the security of the Platform.

Didit

Flare uses Didit to perform:

  • Age estimation.
  • Liveness verification.
  • Identity verification.
  • Document authenticity checks.

Verification is described in greater detail in Section 6.

Didit processes verification information on Flare’s behalf.

Following verification, Flare receives only the information necessary to determine whether verification has been successfully completed.

Verification selfies, liveness videos and identity documents are not retained by Flare.

Anthropic

Flare currently uses Anthropic (Claude) to support certain AI-powered features.

Examples include:

  • Photo moderation.
  • Report triage.
  • Translation.
  • Safety assistance.

Information is processed only where reasonably necessary to provide the requested feature or protect the Platform.

Flare does not permit AI providers to use verification selfies, government-issued identity documents or biometric verification information to train Flare’s own AI systems.

Google

Depending on the feature you use, Flare may use Google services including:

  • Google Analytics.
  • Firebase.
  • Firebase Cloud Messaging.
  • Google Maps.
  • Google Places.
  • Google Sign-In.
  • Google AdMob.
  • Google AdSense.

These services help provide:

  • Analytics.
  • Push notifications.
  • Maps.
  • Venue information.
  • Advertising for free users.
  • Authentication.

Google processes personal information in accordance with its own privacy documentation and applicable legal obligations.

Apple

Where you use Apple devices or services, Flare may use:

  • Sign in with Apple.
  • Apple Push Notification service.
  • Apple In-App Purchases.
  • Apple Music integration.

If you choose to connect Apple Music, Flare accesses only the information necessary for the music features you enable.

Flare never receives your Apple account password.

Spotify

If you choose to connect Spotify, Flare may access limited information including:

  • Selected playlists.
  • Top artists.
  • Top tracks.

Only information required for the features you enable is processed.

You may disconnect Spotify at any time through your account settings.

Meta & X

Flare supports social authentication through providers such as:

  • Meta (Facebook).
  • X.

These providers may supply limited account information necessary to authenticate you and create your Flare account.

Your relationship with these providers remains governed by their own privacy policies.

GIPHY

Flare integrates with GIPHY so you can search for and share GIFs in chats. When you open the GIF picker, your search terms and the GIFs you select are sent to GIPHY to return and deliver results.

GIPHY collects anonymised usage information to operate and improve its service: your GIF search history, and product-interaction data such as taps, scrolls, and which GIFs you view or send. GIPHY uses this for analytics, product personalisation, and app functionality. This information is not linked to your identity and is not used to track you across other apps or websites.

For details, see GIPHY's privacy policy.

Cloudflare Turnstile

Flare uses Cloudflare Turnstile to help prevent:

  • Automated account creation.
  • Spam.
  • Bot attacks.
  • Credential abuse.

Turnstile may process limited device and interaction information necessary to distinguish legitimate users from automated systems.

Email Providers

Flare uses trusted email delivery providers, such as Amazon Simple Email Service (SES) or equivalent providers, to send:

  • Verification emails.
  • Password resets.
  • Security alerts.
  • Subscription notifications.
  • Service announcements.
  • Support communications.

These providers process only the information necessary to deliver communications.

Payment Providers

Payments for subscriptions and paid features are processed through authorised payment providers, including:

  • Apple App Store.
  • Google Play.
  • Other payment providers introduced in the future.

Flare does not receive or store your complete payment card information.

We receive only the information necessary to manage your purchases and subscriptions.

Future Providers

As Flare grows, we may introduce new service providers or replace existing providers to improve:

  • Security.
  • Privacy.
  • Reliability.
  • Performance.
  • Accessibility.
  • User experience.
  • Legal compliance.

Examples may include providers for:

  • Identity verification.
  • Communications.
  • Artificial intelligence.
  • Cloud infrastructure.
  • Analytics.
  • Payments.
  • Customer support.

Where changes materially affect how personal information is processed, we will update this Privacy Policy and notify users where required by law.

Data Protection

Before engaging new providers, Flare seeks to assess whether they provide appropriate safeguards for protecting personal information.

Depending on the provider, these safeguards may include:

  • Data processing agreements.
  • Standard Contractual Clauses.
  • Security certifications.
  • Encryption.
  • Privacy impact assessments.
  • Compliance with applicable privacy legislation.

Your Choices

Some third-party integrations are optional.

For example, you may choose whether to:

  • Connect Spotify.
  • Connect Apple Music.
  • Use social sign-in.
  • Enable personalised advertising where available.

Disabling optional integrations may reduce the availability of certain features but will not normally prevent you from using the core Platform.

10. Advertising & Rewarded Ads

Our Approach

Flare offers both free and paid subscription plans.

To help support the free version of the Platform, Flare may display advertisements to users who do not subscribe to Flare Plus or Flare Premium.

Users with an active Plus or Premium subscription are not shown third-party advertisements within the Platform unless we clearly state otherwise for a specific feature.

Advertising helps us maintain and improve Flare while keeping core features accessible to all eligible adults.

Advertising Providers

Flare currently uses Google advertising services, including:

  • Google AdMob (mobile applications).
  • Google AdSense (website).

These services may display:

  • Banner advertisements.
  • Native advertisements.
  • Interstitial advertisements.
  • Rewarded advertisements.

Advertising providers may process limited technical information necessary to deliver, measure and improve advertising.

Information Processed for Advertising

Depending on your device, location and privacy choices, advertising providers may process information such as:

  • Device type.
  • Operating system.
  • Browser type.
  • Mobile advertising identifier (where available).
  • IP address.
  • Approximate location.
  • Language.
  • App version.
  • Advertising interactions.
  • Basic diagnostic information.

Flare does not provide advertisers with access to:

  • Your private messages.
  • Private Album content.
  • Voice or video calls.
  • Verification selfies.
  • Identity documents.
  • Biometric information.
  • Sensitive profile information.
  • Exact GPS location.

Personalised Advertising

Where permitted by applicable law and where you have provided consent, advertisements may be personalised based on limited advertising information.

Personalised advertising may consider information such as:

  • General region.
  • Device information.
  • Advertising preferences.
  • Previous advertising interactions.

Flare does not use your:

  • Sexual orientation.
  • Gender identity.
  • Health information.
  • Private messages.
  • Private Album content.
  • Verification information.
  • Sensitive personal information.

to personalise advertising.

Non-Personalised Advertising

If you choose not to receive personalised advertising, Flare may continue displaying non-personalised advertisements.

These advertisements are based on general contextual information rather than your personal profile or interests.

Choosing non-personalised advertisements will not affect your ability to use the free version of Flare.

Rewarded Advertisements

Flare may offer optional rewarded advertisements.

Rewarded advertisements allow users to voluntarily watch an advertisement in exchange for temporary Platform benefits.

Examples may include:

  • Temporary profile boosts.
  • Additional discovery opportunities.
  • Other promotional features introduced in the future.

Watching rewarded advertisements is entirely optional.

Users are never required to watch advertisements in order to access basic Platform functionality.

Consent

Where required by applicable law, Flare requests your consent before personalised advertising is enabled.

Depending on your jurisdiction, this may include:

  • Google-certified consent messages.
  • Cookie consent banners.
  • Apple’s App Tracking Transparency (ATT) permission request.
  • Other legally required consent mechanisms.

You may withdraw or change your advertising preferences at any time through:

  • Privacy & Safety settings.
  • Ad privacy settings.
  • Device privacy settings where applicable.

Advertising Identifiers

Some mobile devices provide advertising identifiers.

Examples include:

  • Apple’s Identifier for Advertisers (IDFA).
  • Android Advertising ID.

Depending on your privacy choices, these identifiers may be used to:

  • Measure advertising performance.
  • Prevent advertising fraud.
  • Deliver personalised advertising where permitted.

You can usually reset or restrict these identifiers through your device settings.

Analytics Related to Advertising

Advertising providers may process limited information to:

  • Measure advertisement performance.
  • Prevent fraud.
  • Detect invalid traffic.
  • Understand advertisement effectiveness.
  • Improve advertising services.

This processing helps ensure advertisements function correctly while protecting advertisers and users from fraudulent activity.

No Sale of Personal Information

Flare does not sell your personal information to advertisers.

We do not permit advertisers to access:

  • Your messages.
  • Private Albums.
  • Voice calls.
  • Video calls.
  • Verification documents.
  • Verification selfies.
  • Sensitive profile information.
  • Exact location.

Advertising providers receive only the information reasonably necessary to deliver advertising services.

Future Advertising Services

As Flare evolves, we may introduce additional advertising partners or advertising formats.

Examples may include:

  • Sponsored content.
  • Business promotions.
  • Event promotions.
  • Venue promotions.
  • Service promotions.

Where these changes materially affect how personal information is processed, we will update this Privacy Policy and notify users where required by applicable law.

Transparency

Flare believes users should understand why advertisements are shown.

Where reasonably possible, we aim to explain:

  • Why an advertisement appears.
  • Whether it is personalised.
  • How advertising preferences may be changed.
  • Which privacy choices affect advertising.

Your Choices

You may be able to:

  • Disable personalised advertising.
  • Change advertising preferences.
  • Reset advertising identifiers.
  • Limit app tracking.
  • Subscribe to Flare Plus or Premium to remove advertisements (subject to your subscription benefits).

These choices may affect the relevance of advertisements but will not normally prevent you from using Flare.

11. Cookies & Similar Technologies

Our Approach

Flare uses cookies and similar technologies to operate, secure and improve our website and certain web-based features of the Platform.

Depending on how you access Flare, these technologies may include:

  • Cookies.
  • Local storage.
  • Session storage.
  • Device storage.
  • Software development kits (SDKs).
  • Similar technologies that help remember preferences, improve security and understand how the Platform is used.

Mobile applications may use technologies that perform similar functions to cookies even though traditional browser cookies are not always available.

Why We Use Cookies

Cookies and similar technologies help us:

  • Keep you signed in.
  • Remember your preferences.
  • Maintain security.
  • Prevent fraud.
  • Improve website performance.
  • Measure website usage.
  • Support accessibility.
  • Deliver advertisements where applicable.
  • Remember consent choices.

Without certain essential cookies, some parts of Flare may not function correctly.

Types of Cookies

Depending on your device and how you access Flare, we may use:

Strictly Necessary Cookies

These cookies are essential for operating the Platform.

Examples include cookies used for:

  • Authentication.
  • Security.
  • Session management.
  • Fraud prevention.
  • Load balancing.
  • User preferences necessary for core functionality.

These cookies generally cannot be disabled because they are required for the Service to function.

Functional Cookies

These cookies remember choices you make, such as:

  • Language.
  • Accessibility preferences.
  • Theme preferences.
  • Login preferences.
  • Region.

They help personalise your experience without tracking your activity for advertising purposes.

Analytics Cookies

With your consent where required, analytics technologies help us understand:

  • Which features are used.
  • Website performance.
  • User journeys.
  • Error rates.
  • Platform improvements.

Analytics information helps us improve Flare.

Advertising Cookies

Where applicable and where required by law, advertising technologies help:

  • Deliver advertisements.
  • Measure advertisement performance.
  • Prevent advertising fraud.
  • Display personalised advertising where consent has been given.

Further information is available in Section 10 (Advertising).

Consent

Where required by applicable law, Flare will request your consent before placing non-essential cookies or similar technologies on your device.

Depending on your location, this may include:

  • Cookie banners.
  • Consent management platforms.
  • Google-certified consent mechanisms.

You may withdraw or change your consent at any time.

Browser Controls

Most web browsers allow you to:

  • View cookies.
  • Delete cookies.
  • Block cookies.
  • Restrict cookies.
  • Manage website permissions.

Blocking certain cookies may affect how some parts of the Platform operate.

Mobile Applications

Traditional browser cookies are not always used within mobile applications.

Instead, mobile applications may use:

  • Secure device storage.
  • SDK technologies.
  • Authentication tokens.
  • Local storage.

These technologies perform functions similar to cookies and help the Platform operate securely.

Third-Party Technologies

Some third-party providers used by Flare may place or access cookies or similar technologies.

Examples include providers supporting:

  • Analytics.
  • Advertising.
  • Authentication.
  • Maps.
  • Embedded content.

These providers process information according to their own privacy policies and applicable contractual obligations.

Cookie Policy

Flare maintains a separate Cookie Policy, which provides additional information including:

  • The categories of cookies we use.
  • The purposes for which they are used.
  • How long they remain on your device.
  • How to manage cookie preferences.
  • Information about third-party cookies.

Where there is any inconsistency between this Privacy Policy and the Cookie Policy regarding cookies and similar technologies, the Cookie Policy will govern those specific matters.

Changes

As Flare evolves, the cookies and similar technologies we use may change.

We may update our Cookie Policy and this Privacy Policy to reflect:

  • New features.
  • New providers.
  • Changes in legislation.
  • Improvements to our Platform.

12. How We Share Your Personal Information

Our Approach

Flare is committed to protecting your privacy.

We do not sell your personal information to third parties.

We share personal information only where reasonably necessary to:

  • Operate the Platform.
  • Provide features you request.
  • Protect users.
  • Comply with legal obligations.
  • Prevent fraud and abuse.
  • Improve our services.

Whenever possible, we limit the information shared to the minimum reasonably necessary for the relevant purpose.

Sharing with Other Users

Because Flare is a social platform, some information you choose to provide is visible to other users.

Depending on your privacy settings and the features you use, this may include:

  • Your display name.
  • Profile photos.
  • Profile videos.
  • Biography.
  • Pronouns.
  • Gender identity.
  • Sexual orientation (if you choose to display it).
  • Interests.
  • Tribes.
  • Approximate age.
  • Approximate distance.
  • Open status.
  • Online status where enabled.
  • Communities you choose to display.
  • Public Meetups.
  • Public Service listings.
  • Venue reviews you publish.

You remain responsible for deciding what information you choose to share publicly.

Private Sharing

Some information is shared only with users you specifically choose.

Examples include:

  • Direct Messages.
  • Group Chats.
  • Voice messages.
  • Voice calls.
  • Video calls.
  • Private Albums.
  • View-once media.
  • Shared locations.
  • Partner links.
  • Private Meetup communications.

Access to this information is limited to the users involved, subject to our safety, moderation and legal obligations.

Service Providers

Flare works with trusted third-party service providers who process personal information on our behalf.

Examples include providers responsible for:

  • Cloud hosting.
  • Authentication.
  • Database services.
  • Messaging.
  • Voice and video calls.
  • Artificial intelligence.
  • Analytics.
  • Advertising.
  • Identity verification.
  • Payment processing.
  • Email delivery.
  • Push notifications.
  • Maps.
  • Fraud prevention.
  • Customer support.

These providers are contractually required to process information only for authorised purposes and in accordance with applicable privacy laws.

Age & Identity Verification

Age and identity verification is performed by Didit.

Where verification is required:

  • Verification selfies remain with Didit during processing.
  • Identity documents remain with Didit during processing.
  • Liveness checks remain with Didit during processing.

Flare receives only:

  • Verification outcome.
  • Verification status.
  • Resolved country.
  • Limited operational information necessary to manage your account.

Verification information is never shared with advertisers.

Artificial Intelligence Providers

Where AI-powered features are used, limited information may be shared with our AI providers only where reasonably necessary to provide the requested feature or protect the Platform.

Examples include:

  • Photo moderation.
  • Translation.
  • Report triage.

Flare seeks to minimise the information shared with AI providers.

Verification selfies, identity documents and biometric verification information are not shared for AI model training.

Payment Providers

When you purchase subscriptions or paid features:

  • Apple processes Apple App Store purchases.
  • Google processes Google Play purchases.
  • Other authorised providers may process future payment methods.

Flare receives confirmation of:

  • Purchase status.
  • Subscription entitlement.
  • Renewal information.

Flare does not receive or retain your complete payment card details.

Advertising & Analytics Providers

Advertising and analytics providers may receive limited technical information necessary to:

  • Measure advertising.
  • Prevent advertising fraud.
  • Analyse Platform performance.
  • Improve reliability.

Flare does not share with advertisers:

  • Private messages.
  • Private Album content.
  • Voice calls.
  • Video calls.
  • Verification information.
  • Government-issued identity documents.
  • Sensitive profile information for advertising.
  • Exact GPS location.

Business Transfers

If Flare or Backroom Studio Ltd is involved in:

  • A merger.
  • An acquisition.
  • Corporate restructuring.
  • Investment transaction.
  • Sale of assets.

Personal information may be transferred as part of that transaction where legally permitted.

If such a transfer materially affects how your personal information is processed, we will provide notice where required by applicable law.

Legal Requirements

Flare may disclose personal information where reasonably necessary to:

  • Comply with court orders.
  • Comply with legal obligations.
  • Respond to lawful requests from competent authorities.
  • Protect users.
  • Prevent fraud.
  • Investigate criminal activity.
  • Prevent serious harm.
  • Enforce our Terms of Service.
  • Enforce our Community Guidelines.

We assess each request carefully and disclose only the information that is legally required or reasonably necessary.

Protecting Users

We may share limited information where reasonably necessary to:

  • Prevent child exploitation.
  • Prevent human trafficking.
  • Prevent terrorism.
  • Prevent serious violence.
  • Protect vulnerable users.
  • Respond to credible threats to life or safety.

Any disclosure is limited to the minimum reasonably necessary under applicable law.

Professional Advisers

Where reasonably necessary, Flare may share limited personal information with professional advisers acting on our behalf, including:

  • Solicitors.
  • Barristers.
  • Auditors.
  • Insurers.
  • Accountants.
  • Regulatory advisers.

These advisers are subject to professional confidentiality obligations.

Your Instructions

Certain Flare features require us to share information because you ask us to.

Examples include:

  • Connecting Spotify.
  • Connecting Apple Music.
  • Social sign-in.
  • Sharing your location.
  • Granting access to Private Albums.
  • Linking partner profiles.
  • Joining Communities.
  • RSVPing to Meetups.

These disclosures occur because you choose to use those features.

International Sharing

Some of our service providers operate internationally.

As a result, personal information may be transferred to countries outside your country of residence.

Where required by applicable law, Flare implements appropriate safeguards, including:

  • Standard Contractual Clauses.
  • The UK International Data Transfer Addendum.
  • Adequacy decisions where available.
  • Other lawful transfer mechanisms.

Further information is provided in Section 13.

Data Minimisation

Whenever Flare shares personal information, we seek to:

  • Share only the information reasonably necessary.
  • Limit access to authorised recipients.
  • Use secure transmission methods.
  • Apply contractual safeguards.
  • Monitor compliance where appropriate.

This reflects our commitment to privacy by design and data minimisation.

Future Sharing

As Flare introduces new features or service providers, the categories of information we share may evolve.

If changes materially affect how your personal information is processed, we will update this Privacy Policy and notify users where required by applicable law.

Transparency

We believe users should understand how their information is shared.

Where reasonably possible, we aim to explain:

  • Why information is shared.
  • Who receives it.
  • The safeguards that apply.
  • The choices available to you.

13. International Transfers & Where Your Information Is Stored

Our Approach

Flare is available in multiple countries and works with carefully selected service providers located in different parts of the world.

As a result, your personal information may be processed or stored outside the country in which you live.

Whenever personal information is transferred internationally, Flare seeks to ensure that appropriate safeguards are in place to protect your privacy and comply with applicable data protection laws.

Where Information May Be Processed

Depending on the feature you use, your personal information may be processed by Flare or our authorised service providers in:

  • The United Kingdom.
  • The European Economic Area (EEA).
  • The United States.
  • Other countries where our authorised service providers operate.

The locations involved may change over time as Flare grows and introduces new providers.

Media Storage

Photos, videos, voice messages and other uploaded media are stored using Cloudflare R2.

Where possible:

  • Users located in the United Kingdom, European Union, European Economic Area or Switzerland will have media stored within European data centres.

Users located elsewhere may have media stored in other secure locations depending on the infrastructure available and operational requirements.

Storage locations may change to improve:

  • Reliability.
  • Performance.
  • Disaster recovery.
  • Security.
  • Legal compliance.

Account Information

Account information, authentication records and profile information may be processed by authorised infrastructure providers supporting Flare.

These providers help us operate:

  • User accounts.
  • Authentication.
  • Databases.
  • Messaging.
  • Notifications.
  • Security systems.

Only authorised personnel and authorised service providers have access to personal information where reasonably necessary to perform their responsibilities.

Verification Information

Age and identity verification is performed by Didit.

Verification selfies, liveness videos and identity documents are processed on Didit’s systems.

Following completion of verification:

  • Flare receives only the verification outcome.
  • Verification sessions are automatically deleted in accordance with our integration and retention process.
  • Flare retains only your verification status and related operational information.

This significantly reduces the amount of sensitive information stored by Flare.

International Transfers

Where personal information is transferred outside your country or region, Flare seeks to ensure that appropriate legal safeguards are in place.

Depending on the circumstances, these safeguards may include:

  • UK International Data Transfer Addendum.
  • EU Standard Contractual Clauses (SCCs).
  • Adequacy Regulations or Adequacy Decisions.
  • Binding contractual commitments.
  • Other lawful international transfer mechanisms recognised under applicable law.

Security Measures

International transfers are supported by technical and organisational measures designed to protect personal information.

These measures may include:

  • Encryption during transmission.
  • Encryption where appropriate while stored.
  • Secure authentication.
  • Access controls.
  • Data minimisation.
  • Monitoring and auditing.
  • Staff confidentiality obligations.
  • Incident response procedures.

Service Providers

Flare carefully selects service providers that support appropriate security and privacy standards.

Before engaging providers, we seek to assess factors including:

  • Security controls.
  • Privacy commitments.
  • Regulatory compliance.
  • Technical capabilities.
  • Data protection safeguards.

We periodically review these relationships as our Platform evolves.

Legal Requirements

Certain countries require service providers to disclose information to government authorities under specific legal circumstances.

Where Flare receives requests relating to your personal information, we assess each request carefully.

Unless prohibited by law, we seek to ensure that any disclosure is:

  • Lawful.
  • Necessary.
  • Proportionate.
  • Limited to the information required.

Future Infrastructure

As Flare expands internationally, we may introduce:

  • Additional data centres.
  • New cloud providers.
  • Regional infrastructure.
  • Additional security services.

These changes are intended to improve:

  • Reliability.
  • Performance.
  • User experience.
  • Disaster recovery.
  • Legal compliance.

Where such changes materially affect how personal information is processed, we will update this Privacy Policy and notify users where required by applicable law.

Your Rights

Depending on your location, you may have the right to request additional information about international transfers affecting your personal information.

Where required by applicable law, Flare will provide information about the safeguards used to protect transferred personal information.

Requests may be submitted through our Help Center or designated privacy contact.

Data Minimisation

Regardless of where personal information is processed, Flare applies the same core privacy principles:

  • Data minimisation.
  • Purpose limitation.
  • Appropriate security measures.
  • Limited access.
  • Privacy by design.
  • Accountability.

International transfers do not reduce the protections described in this Privacy Policy.

Transparency

We are committed to being transparent about where personal information is processed.

As our infrastructure evolves, we will continue updating this Privacy Policy to reflect significant changes in our international data processing practices.

14. Data Retention

Our Approach

Flare retains personal information only for as long as reasonably necessary to:

  • Provide the Platform.
  • Protect users.
  • Comply with legal obligations.
  • Resolve disputes.
  • Prevent fraud and abuse.
  • Enforce our Terms of Service.
  • Enforce our Community Guidelines.
  • Maintain the integrity and security of the Platform.

When personal information is no longer required, we seek to securely delete, anonymise or otherwise dispose of it in accordance with our retention practices and applicable law.

Active Accounts

While your account remains active, Flare generally retains the information necessary to operate your account, including:

  • Account information.
  • Profile information.
  • Profile photographs and videos.
  • Communities.
  • Meetups.
  • Venue activity.
  • Service listings.
  • Messages.
  • Subscription information.
  • User preferences.
  • Privacy settings.

This information is retained while you continue to use the Platform.

Account Deletion

If you delete your Flare account, deletion begins immediately.

Unless a longer retention period is required by law or for legitimate operational reasons:

  • Your account and sign-in credentials are deleted.
  • Your profile stops being visible to other users.
  • Your active sessions end.
  • Your photos and videos are removed from our storage.
  • Your profile data, messages, matches, verification record, travel history and check-ins are deleted.

Most of this happens at the point you confirm deletion, rather than being queued for later.

Certain backup systems may require additional time before information is permanently overwritten.

Two things are deliberately kept, and are described below: safety and moderation records (see Safety & Moderation Records), and messages other users have already received (see Messages & Communications).

Verification Information

Verification selfies, liveness videos and government-issued identity documents are not retained by Flare.

These materials are processed by Didit solely for the purpose of completing verification.

Once verification reaches a final outcome:

  • Flare automatically instructs Didit to delete the verification session.
  • Verification media is removed from Didit’s systems in accordance with our integration and retention processes.
  • Flare retains only your verification status and limited operational information necessary to manage your account.

This approach reflects our commitment to data minimisation.

Messages & Communications

Messages, shared media and communications are generally retained while your account remains active so that conversations continue to function.

When you delete your account:

  • Your messages may no longer appear as being associated with your profile.
  • Copies of messages already received by other users may remain available within their conversations, unless removed in accordance with our retention policies or applicable law.
  • Certain communications may be retained where necessary for safety investigations, legal obligations or dispute resolution.

Communities, Meetups & Services

Information relating to Communities, Meetups and Services may be retained for limited periods after account deletion where reasonably necessary to:

  • Protect other users.
  • Maintain historical event records.
  • Resolve disputes.
  • Investigate abuse.
  • Preserve moderation records.

Where possible, personal identifiers are removed or minimised.

Safety & Moderation Records

To help maintain a safe Platform, Flare may retain limited information relating to:

  • Reports.
  • Warnings.
  • Suspensions.
  • Appeals.
  • Fraud investigations.
  • Ban-evasion attempts.
  • Serious Community Guidelines violations.
  • Serious Terms of Service violations.

These records help us:

  • Protect users.
  • Prevent repeated abuse.
  • Enforce previous moderation decisions.
  • Comply with legal obligations.

Retention periods depend on the nature and seriousness of the matter.

These records are retained even if the account they concern is deleted.

If deleting an account also erased the reports made about it, a person could remove their own history of abuse simply by deleting their account and registering again. Retaining these records is what prevents that, and it is necessary for the safety of other users.

What is retained is limited to what is needed for that purpose. Once the account is deleted, the identifiers held in these records no longer correspond to an existing Flare account, profile or contact details.

This retention is based on our legitimate interest in keeping the Platform safe and preventing abuse, and on our obligations to protect users. Where you object to it, we will consider your request, but we may need to keep a record where doing so is necessary to protect others.

Payment Information

Flare does not store complete payment card information.

Subscription and payment records may be retained for the periods required by:

  • Tax legislation.
  • Accounting obligations.
  • Financial reporting requirements.
  • Fraud prevention.

These records are retained only as long as reasonably necessary.

Analytics Information

Analytics information may be retained for periods reasonably necessary to:

  • Understand Platform performance.
  • Improve features.
  • Monitor reliability.
  • Prevent fraud.
  • Produce aggregated usage statistics.

Where possible, analytics information is aggregated or anonymised so that it no longer identifies individual users.

Technical Logs

Technical logs may include:

  • Authentication events.
  • Security events.
  • Device information.
  • Error reports.
  • System diagnostics.

These logs help:

  • Detect fraud.
  • Investigate incidents.
  • Maintain Platform security.
  • Improve reliability.

Retention periods vary depending on the operational purpose.

Legal Requirements

Certain personal information may be retained longer where reasonably necessary to:

  • Comply with legal obligations.
  • Respond to court orders.
  • Respond to lawful requests from competent authorities.
  • Resolve legal claims.
  • Protect Flare’s legal rights.
  • Protect users from serious harm.

Such information is retained only for as long as required by applicable law or the relevant legal process.

Backups

Flare maintains secure backup systems to protect against accidental data loss.

Information deleted from active systems may continue to exist within encrypted backups for a limited period until those backups are securely overwritten in accordance with our backup retention schedules.

Backup information is not routinely accessed except where necessary for disaster recovery, security or legal compliance.

Anonymised Information

Flare may retain information that has been anonymised so that it can no longer reasonably identify an individual.

Anonymised information may be used for:

  • Platform improvement.
  • Analytics.
  • Security analysis.
  • Product development.
  • Statistical reporting.

Once information has been genuinely anonymised, it is no longer considered personal information under many privacy laws.

Your Choices

You may reduce the amount of information retained by:

  • Editing your profile.
  • Removing optional profile information.
  • Deleting uploaded content.
  • Disconnecting connected services.
  • Deleting your account.

Some information may still be retained where required by law or for legitimate operational purposes.

Periodic Review

Flare regularly reviews its retention practices to ensure that personal information is not retained for longer than reasonably necessary.

Retention periods may change where required by:

  • New legislation.
  • Regulatory guidance.
  • Security requirements.
  • Operational improvements.

Any material changes will be reflected in this Privacy Policy where appropriate.

15. Your Privacy Rights & Choices

Our Commitment

Flare believes you should remain in control of your personal information.

Depending on where you live and the laws that apply to you, you may have certain privacy rights regarding the personal information we hold about you.

Some rights may vary depending on your country or region.

Where applicable law grants additional rights, those rights will also apply.

Right of Access

You may request confirmation of whether Flare processes your personal information.

Where applicable, you may also request a copy of the personal information we hold about you.

This may include information relating to:

  • Your account.
  • Your profile.
  • Messages where applicable.
  • Verification status.
  • Communities.
  • Meetups.
  • Services.
  • Subscription information.
  • Privacy settings.
  • Other personal information associated with your account.

We may need to verify your identity before responding.

Right to Rectification

If you believe that your personal information is inaccurate or incomplete, you may request that it be corrected.

Many profile details can also be updated directly through your account settings.

Keeping your information accurate helps Flare operate safely and effectively.

Right to Erasure (“Right to be Forgotten”)

Where applicable, you may request deletion of your personal information.

You may also delete your Flare account at any time through:

Settings → Delete Account

or, where available,

joinflare.io/delete-account

Deleting your account normally begins the deletion process described in Section 14.

Certain information may continue to be retained where reasonably necessary to:

  • Comply with legal obligations.
  • Resolve disputes.
  • Protect users.
  • Prevent fraud.
  • Enforce previous moderation decisions.

Right to Restrict Processing

Depending on applicable law, you may request that Flare temporarily restrict the processing of certain personal information.

For example, you may request restriction where:

  • You dispute the accuracy of information.
  • Processing is unlawful.
  • Information is no longer needed but you require it for legal claims.
  • You have objected to certain processing.

During restriction, some Platform features may operate differently.

Right to Object

Where we rely on legitimate interests as the legal basis for processing, you may object to that processing in certain circumstances.

Examples include processing relating to:

  • Analytics.
  • Fraud prevention.
  • Platform improvements.
  • Recommendation systems.

We will consider your request in accordance with applicable law.

Some processing may continue where compelling legitimate grounds exist.

Right to Withdraw Consent

Where processing relies on your consent, you may withdraw that consent at any time.

Examples include consent for:

  • Optional sensitive profile information.
  • Device location.
  • Personalised advertising.
  • Connected music services.
  • Certain optional Platform features.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Right to Data Portability

Where applicable, you may request a copy of certain personal information in a structured, commonly used and machine-readable format.

Where technically feasible and legally required, you may also request that such information be transferred directly to another provider.

This right generally applies only to information processed:

  • With your consent; or
  • Under a contract with you.

Rights Relating to Automated Decision-Making

Where applicable law provides such rights, you may request information about certain automated processing carried out by Flare.

Flare does not make decisions producing legal or similarly significant effects based solely on automated processing where prohibited by applicable law.

Important moderation decisions are reviewed by trained human moderators where appropriate.

Right to Lodge a Complaint

If you believe Flare has not handled your personal information appropriately, you have the right to lodge a complaint with the relevant supervisory authority.

For example:

  • In the United Kingdom, the supervisory authority is the Information Commissioner’s Office (ICO).
  • In the European Economic Area, you may contact the supervisory authority in your country.

We encourage users to contact Flare first so that we have the opportunity to resolve concerns directly.

California & Other U.S. Privacy Rights

If you live in California or another U.S. state with applicable privacy legislation, you may have additional rights.

Depending on applicable law, these may include the right to:

  • Know what personal information we collect.
  • Access personal information.
  • Correct inaccurate information.
  • Delete personal information.
  • Obtain a copy of certain information.
  • Opt out of certain types of data sharing where applicable.
  • Appeal certain privacy decisions where required by law.

Flare does not sell personal information.

Where required by applicable law, we will honour applicable opt-out rights.

Exercising Your Rights

You may exercise your privacy rights by contacting Flare through:

  • The Help Center.
  • Our designated privacy contact.
  • Other contact methods identified in this Privacy Policy.

To protect your privacy, we may ask you to verify your identity before fulfilling certain requests.

Timeframes

Where applicable law specifies response deadlines, Flare will respond within the required time.

If additional time is reasonably necessary due to the complexity of your request, we will inform you where required by law.

Exceptions

Certain privacy rights are not absolute.

Flare may decline or limit requests where permitted by applicable law, including where reasonably necessary to:

  • Protect other users.
  • Prevent fraud.
  • Protect public safety.
  • Comply with legal obligations.
  • Preserve evidence.
  • Protect Flare’s legal rights.

Where appropriate, we will explain the reasons for our decision.

No Discrimination

Flare will not discriminate against you for exercising your privacy rights.

However, certain features may become unavailable if the information necessary to operate those features is deleted or if consent is withdrawn.

For example:

  • Disabling location will affect Nearby.
  • Removing profile information may reduce discovery.
  • Deleting your account will end access to the Platform.

Continuous Improvement

Privacy laws continue to evolve.

Flare regularly reviews its privacy practices and user rights procedures to ensure continued compliance with applicable legislation.

Where privacy laws change, we may update this Privacy Policy accordingly.

16. Children

Adults-Only Platform

Flare is designed exclusively for adults aged 18 years or older.

Individuals under the age of 18 are not permitted to create an account or use the Platform.

This restriction applies regardless of local age-of-consent laws unless Flare expressly states otherwise in accordance with applicable legislation.

Age Assurance

To help prevent minors from accessing the Platform, Flare uses age-assurance technology provided by Didit, as described in Section 6.

Depending on applicable law and the circumstances, verification may include:

  • Age estimation using a selfie and liveness check.
  • Identity verification using a government-issued identity document.
  • Additional verification where reasonably necessary.

These checks help us maintain an adults-only community and comply with applicable legal requirements.

Accounts Believed to Belong to Minors

If Flare reasonably believes that an account belongs to someone under the age of 18, we may:

  • Suspend the account.
  • Request additional verification.
  • Restrict access to the Platform.
  • Permanently remove the account.

Where required by law, we may also preserve relevant information or notify the appropriate authorities.

Reports from Users

If you believe someone under 18 is using Flare, please report the account immediately using our in-app reporting tools or the Help Center.

We review such reports as quickly as reasonably possible because protecting children is one of our highest priorities.

Parents & Guardians

Because Flare is an adults-only service, we do not knowingly collect personal information from children.

If you are a parent, guardian or legal representative and believe that a child has created a Flare account, please contact us immediately so we can investigate and take appropriate action.

17. Security

Our Commitment

Protecting your personal information is one of Flare’s highest priorities.

We use technical, organisational and administrative safeguards designed to protect personal information against:

  • Unauthorised access.
  • Unauthorised disclosure.
  • Loss.
  • Alteration.
  • Misuse.
  • Destruction.

Although no online service can guarantee absolute security, we continually improve our systems to reduce risk.

Security Measures

Depending on the feature, Flare may use security measures including:

  • Encryption in transit (TLS/HTTPS).
  • Encryption at rest where appropriate.
  • Role-based access controls.
  • Multi-factor authentication for internal systems.
  • Secure authentication.
  • Passkeys.
  • Two-factor authentication (2FA).
  • Cloud security protections.
  • Security monitoring.
  • Fraud detection.
  • AI-assisted abuse detection.
  • Bot protection.
  • Device integrity checks.
  • Digital watermarking.
  • Screenshot attribution technology.
  • Signed URLs and short-lived access tokens for Private Albums.
  • Regular software updates.
  • Security testing.

Access Controls

Access to personal information is limited to authorised personnel who require that access to perform their responsibilities.

Employees, contractors and authorised service providers are subject to confidentiality obligations and appropriate access restrictions.

Your Responsibilities

You also play an important role in protecting your account.

We recommend that you:

  • Use a strong, unique password.
  • Enable a passkey where supported.
  • Enable two-factor authentication (2FA).
  • Keep your device secure.
  • Avoid sharing your login credentials.
  • Report suspicious activity immediately.
  • Keep your device and operating system up to date.

Security Incidents

If Flare becomes aware of a personal data breach that is likely to pose a risk to your rights and freedoms, we will respond in accordance with applicable law.

Where required, this may include:

  • Investigating the incident.
  • Containing the breach.
  • Notifying the appropriate supervisory authority.
  • Notifying affected users.
  • Taking steps to reduce the impact of the incident.

Continuous Improvement

Security threats constantly evolve.

Flare regularly reviews and improves its security measures to:

  • Address emerging risks.
  • Improve fraud detection.
  • Strengthen authentication.
  • Improve privacy protections.
  • Protect users.

18. Changes to This Privacy Policy

Updates

We may update this Privacy Policy from time to time to reflect:

  • Changes in the law.
  • New Platform features.
  • Changes to our service providers.
  • Improvements to security.
  • Changes to our business operations.
  • Clarifications or corrections.

Notification

Where changes materially affect how your personal information is processed, we will provide notice where required by applicable law.

Notification may be provided through:

  • The Flare app.
  • Email.
  • The Flare website.
  • Other appropriate communication methods.

The “Last Updated” date at the beginning of this Privacy Policy will also be revised.

Continued Use

Where permitted by applicable law, your continued use of Flare after an updated Privacy Policy becomes effective constitutes your acknowledgement of the updated policy.

If you do not agree with the changes, you may stop using the Platform and delete your account.

19. Contact & Complaints

Contacting Flare

If you have questions about this Privacy Policy, your personal information or your privacy rights, you may contact Flare at:

support@joinflare.io

You may also reach us through:

  • The Help Center.
  • The support section of the Flare app.
  • Other official contact methods published on our website.

Privacy Requests

You may use these contact methods to:

  • Exercise your privacy rights.
  • Request access to your information.
  • Request correction of inaccurate information.
  • Request deletion of your information.
  • Ask questions about verification.
  • Raise privacy concerns.
  • Report suspected security issues.

We may request information necessary to verify your identity before responding.

Complaints

If you believe Flare has not handled your personal information appropriately, we encourage you to contact us first so we have the opportunity to investigate and resolve your concern.

If you remain dissatisfied, you may lodge a complaint with the relevant supervisory authority in your jurisdiction.

For example:

  • In the United Kingdom, this is the Information Commissioner’s Office (ICO).
  • Within the European Economic Area, you may contact your local Data Protection Authority.

Our Commitment

Privacy is a core part of how Flare is designed and operated.

We are committed to:

  • Protecting personal information.
  • Being transparent about our practices.
  • Giving users meaningful privacy controls.
  • Continuously improving our privacy and security measures.
  • Complying with applicable privacy laws.

We appreciate the trust you place in Flare and remain committed to maintaining a safe, respectful and privacy-focused platform for our community.

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