Privacy Policy

Effective Date: July, 2025.

FlushRich LLC ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the FlushRich mobile application (“App”), which is available in the United States, United Kingdom, Canada (excluding Quebec), Australia, New Zealand, Ireland, Germany, Austria, and Denmark. If you do not agree, do not use the App.

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1. Information We Collect

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We collect both personally identifiable information (PII) and non-personally identifiable information (non-PII), including:

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  a. Information You Provide

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• Full name, email address, date of birth

• Profile photo (optional)

• Identity verification documents (Driver’s License, Passport)

• In-app messages or support requests

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  b. Automatically Collected Information

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• Device type, OS version, and unique device identifiers

• IP address and geo-location data

• We may use your IP address and geo-location data to determine applicable privacy regulations (such as GDPR) and present relevant consent prompts accordingly.

• Usage activity and interactions

• Ad views and rewards engagement

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  c. Third-Party Data

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• Data from services like Google or Apple if you log in using social or single sign-on tools

• Ad partners (for ad reward verification)

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  d.  Location Information

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• When you claim rewards, we collect your device’s location data to verify your eligibility and prevent fraud. This location data is securely stored in Firebase, a trusted cloud service provider that implements robust security measures to protect your information. Your location data is used solely for these purposes and is not shared with third parties except as required by law. We retain this data only as long as necessary to complete verification and comply with legal obligations. You can control location permissions in your device settings. By using this feature, you consent to the collection, storage, and use of your location data as described here.

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  e.  Tracking and Advertising

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• For iOS users, we comply with Apple's App Tracking Transparency (ATT) framework. We request your permission through the system prompt before collecting or sharing data that could be used to track you across apps and websites owned by other companies. You can control this permission in your device settings.

• We work with advertising partners (such as Google AdMob) who may collect data to deliver personalized ads and measure ad performance, but only after you have granted tracking permission on iOS.

• If you deny tracking permission on iOS, we and our partners will serve non-personalized ads.

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2. How We Use Your Information

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We use your information to:

• Verify your age and U.S. residency

• Deliver sweepstakes participation and results

• Distribute rewards (gift cards, coins)

• Prevent fraud and enforce fair play

• Improve functionality, performance, and user experience

• Comply with legal obligations

 We do not sell your personal data to third parties.

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3. Legal Basis for Processing

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We process your data based on:

• Consent: You give clear permission (e.g., uploading ID).

• Contract: We need it to provide services (e.g., verifying eligibility).

• Legal obligation: Required by law (e.g., age verification).

• Legitimate interest: Fraud prevention, security, and service improvements.

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4. Disclosure of Information

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We may share your information:

• With Service Providers: Only those helping us run the App (e.g., payment processors, ID verification tools).

• With Legal Authorities: If required by law, subpoena, or to enforce our rights.

• In Business Transfers: In case of a merger, acquisition, or asset sale.

All third-party processors are contractually obligated to protect your data.

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5. Your Rights

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As a U.S. resident, you have:

• The right to access your data

• The right to correct inaccurate data

• The right to delete your account and data (subject to sweepstakes recordkeeping requirements)

• The right to withdraw consent at any time (e.g., opt out of marketing)

To exercise these rights, email: info@flushrich.com

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6. Data Retention

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We retain personal data only as long as necessary for:

• Legal compliance

• Sweepstakes integrity and audit logs

• Account recovery and fraud prevention

• Tax or accounting obligations

Afterward, data is securely deleted or anonymized.

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7. Data Security

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We implement industry-standard safeguards, including:

• End-to-end encryption

• Secured cloud storage

• Strict access controls and internal audits

• Secure upload and verification of ID documents

However, no system is 100% secure. By using the App, you accept this risk.

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8. Children’s Privacy

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This App is not intended for children under 18. We do not knowingly collect or allow registration from individuals under 18. If we learn that we have collected such data, it will be deleted immediately.

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9. International Transfers and Use

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• The App is available only to users in countries we explicitly support: the United States, United Kingdom, Canada (excluding Quebec), Australia, New Zealand, Ireland, Germany, Austria, and Denmark.

• If you are located in the European Union or United Kingdom, please note that your data will be transferred to and processed in the United States. We use secure cloud providers (e.g., Google Firebase) and implement appropriate safeguards, including Standard Contractual Clauses (SCCs), to ensure your data is protected in accordance with GDPR.

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10. California Privacy Rights (CCPA)

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California users may request:

• Access to personal data categories collected

• Deletion of personal data (subject to legal limits)

• Disclosure of third parties data is shared with

Submit CCPA requests via info@flushrich.com with subject: “California Request”.

We do not sell California users’ personal data.

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11. EU Privacy Rights (GDPR)

• If you are a resident of the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

  • The right to access the personal data we hold about you;

  • The right to request correction of inaccurate information;

  • The right to request deletion of your data (“right to be forgotten”), subject to applicable legal retention requirements;

  • The right to object to or restrict processing;

  • The right to withdraw consent at any time;

  • The right to data portability.

• Users in the United Kingdom have similar rights under the UK Data Protection Act 2018 and UK GDPR.

• Our legal basis for processing your data includes your consent, performance of a contract (e.g., verifying eligibility), compliance with legal obligations, and legitimate interests (e.g., fraud prevention).

• To exercise your GDPR rights, contact: info@flushrich.com with subject: "GDPR Request".

• Personal data of EEA users is stored in secure cloud environments (Firebase, Google Cloud) and may be processed in the United States under Standard Contractual Clauses (SCCs) or equivalent safeguards.
   

12. Cookies and Analytics

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• We may use cookies, device identifiers, and analytics tools (such as Firebase Analytics) to understand app performance and user engagement. These tools help us improve functionality and personalize your experience.

• Where required by law, users in the EU and UK may be asked to provide consent to non-essential cookies.

• We use third-party advertising services such as Google AdMob to serve ads in the App. On Android devices, we rely on Google's User Messaging Platform (UMP) to collect GDPR consent where applicable.

• On iOS devices, we implement Apple’s ATT framework to request permission for tracking before personalized ads are served. Additionally, for users in the European Economic Area (EEA), United Kingdom, and Switzerland, we provide separate GDPR consent prompts to comply with applicable laws.

• You may opt out of personalized advertising at any time via your device or app settings.

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13. Third-Party Links and Services

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The App may link to third-party sites (e.g., gift card providers, ad partners). We are not responsible for their content or privacy practices. Use them at your own risk.

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14. Changes to This Policy

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We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notification. Continued use of the App means acceptance of the updated policy.

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15. Contact Us

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If you have questions or concerns about this policy, contact us at:

📧 info@flushrich.com
📬 FlushRich LLC, Wilmington, Delaware, USA

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16. User Consent

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By using the FlushRich App, you:

• Confirm you are at least 18 years old and a legal resident of one of the supported countries listed in this Privacy Policy.

• Consent to the collection, processing, and use of your data as described;

• By using the FlushRich App, you consent to the collection and use of your data as described in this Privacy Policy. For iOS users, you will be asked to grant or deny permission for app tracking via Apple's App Tracking Transparency prompt. For users located in the European Economic Area, United Kingdom, and Switzerland, additional consent requests may be presented to comply with GDPR requirements.

• You can manage or withdraw your consents at any time through your device settings or by contacting us at info@flushrich.com.

• Agree to this Privacy Policy and our [Terms and Conditions].