Fliply – Privacy Policy
FLIPLY.MARKET PRIVACY POLICY
Last Updated: Apr 15, 2026
1. Introduction
This Privacy Policy (“Policy”) describes how Fliply Technologies Ltd, a company incorporated
under the laws of the British Virgin Islands (“Fliply Technologies Ltd,” “we,” “us,” or “our”),
collects, uses, stores, shares, and protects your personal information when you access or use
and all related services and features (collectively, the “Services”).
We are committed to protecting your privacy and handling your personal information
transparently. Please read this Policy carefully. By accessing or using the Services, you consent
to the collection, use, and disclosure of your information as described in this Policy. If you do not
agree with this Policy, please do not use the Services.
This Policy should be read together with our Terms of Service, available at
https://fliply.market/terms, which govern your use of the Services.
If you have any questions regarding this Policy or our data practices, please contact our
2. Information We Collect
2.1 Information You Provide
We may collect the following information that you voluntarily provide to us:
•
•
•
•
Email Address. When you create an account, you authenticate via email through our
authentication provider, Privy. Your email address is collected for account verification and
communication purposes.
Wallet Address. Upon account creation, an embedded wallet is automatically created
for you through Privy. Your public wallet address is associated with your account and is
used to facilitate transactions on the Services.
Communications. If you contact us for support, submit feedback, or otherwise
communicate with us, we may collect the content of your communications, including your
email address and any other information you choose to provide.
Survey Responses. If you participate in surveys or promotional activities, we may
collect the information you provide in connection with those activities.
2.2 Information Collected Automatically
When you access or use the Services, we automatically collect certain information, including:
•
IP Address. Your Internet Protocol (IP) address is collected for security, fraud
prevention, geo-restriction enforcement, and analytics purposes.
Page 1 of 7
Fliply – Privacy Policy
•
•
•
Device Information. We collect information about the device you use to access the
Services, including device type, operating system, browser type and version, screen
resolution, language settings, and unique device identifiers.
Usage Data. We collect information about how you interact with the Services, including
pages viewed, features used, tournament participation, prediction activity, timestamps,
and referring URLs.
Transaction Data. We collect information about transactions you conduct through the
Services, including tournament entries, predictions made, and wallet transaction history.
Note that all blockchain transactions are publicly visible on the Solana blockchain.
2.3 Cookies and Tracking Technologies
We use cookies and similar tracking technologies (collectively, “Cookies”) to collect and store
information when you access the Services. Cookies are small data files placed on your device
that help us improve the Services, analyze usage patterns, and deliver a better user experience.
We use the following types of Cookies:
•
•
Essential Cookies. Required for the basic functionality of the Services, such as
maintaining your session and security settings. These cannot be disabled.
Analytics Cookies. Used to understand how users interact with the Services. We use
third-party analytics tools including Google Analytics and Mixpanel to collect and analyze
usage data.
•
•
Functional Cookies. Used to remember your preferences and settings to provide a
more personalized experience.
Advertising and Tracking Pixels. We may use tracking pixels and similar technologies
from third-party advertising platforms (such as Meta Pixel, TikTok Pixel, and similar tools)
to measure the effectiveness of our advertising campaigns, deliver relevant
advertisements, and perform retargeting. These technologies may collect information
about your device, browsing activity, and interactions with our Services and share such
data with the respective advertising platforms.
Cookie Consent: When required by applicable law, we will obtain your consent before placing
non-essential Cookies on your device through a cookie consent banner displayed upon your
first visit to the Site. You may manage your Cookie preferences at any time through your
browser settings or through our cookie consent tool (where available). However, disabling
certain Cookies may affect the functionality of the Services. We do not respond to Do Not Track
(“DNT”) signals.
2.4 Information from Third Parties
We may receive information about you from third-party services that you use in connection with
the Services, including Privy (authentication and wallet provider) and blockchain networks
(publicly available transaction data).
3. How We Use Your Information
We use the information we collect for the purposes set out below. Where required by applicable
law, we have identified the legal basis for each processing activity:
Page 2 of 7
Fliply – Privacy Policy
Purpose
Data Types
Legal Basis
Retention Period
Account creation &
authentication
Email, wallet address
Contractual necessity
Duration of account +
12 months
Providing Services
(tournaments,
predictions)
Email, wallet, transaction data, Contractual necessity
usage data
Duration of account +
12 months
Security & fraud
prevention,
geo-restriction
IP address, device info, usage
data
Legitimate interest
24 months
24 months
Analytics &
improvement
Usage data, device info,
cookies
Legitimate interest /
Consent
Communications &
support
Email, communication content
Contractual necessity /
Legitimate interest
Duration of account +
12 months
Legal compliance
(AML, tax, regulatory)
All applicable data
Legal obligation
5 years (or as required
by law)
Advertising
measurement &
retargeting
Device info, usage data,
cookies, pixels
Consent
24 months
We may also use your information to:
•
Communicate: Send you service-related notifications, respond to your inquiries, and
provide customer support.
•
•
Protect: Protect the rights, property, and safety of Fliply, our users, and the public.
Comply: Comply with applicable laws, regulations, legal processes, or governmental
requests, and to enforce our Terms of Service.
4. How We Share Your Information
We do not sell your personal information to third parties. We may share your information in
the following circumstances:
•
•
•
Service Providers. We share information with third-party service providers who perform
services on our behalf, including Privy (authentication and wallet infrastructure), Google
Analytics and Mixpanel (analytics), and hosting and cloud infrastructure providers. We
have entered into appropriate data processing agreements with our service providers to
ensure your data is processed in accordance with applicable data protection laws and
only for the purposes of providing services to us.
Advertising Partners. We may share certain information (such as device identifiers,
usage data, and Cookie data) with third-party advertising platforms, including Meta
(Facebook/Instagram) and TikTok, for the purposes of measuring advertising
effectiveness, delivering relevant advertisements, and performing retargeting. You may
opt out of personalized advertising through your device settings or by using the opt-out
tools provided by the respective advertising platforms.
Blockchain Networks. When you conduct transactions through the Services, certain
information (including your public wallet address and transaction details) is recorded on
Page 3 of 7
Fliply – Privacy Policy
the Solana blockchain and becomes publicly available. This is inherent to blockchain
technology and cannot be reversed or deleted by Fliply.
•
•
•
Legal Requirements. We may disclose your information if required by law, court order,
subpoena, or other legal process, or if we believe disclosure is reasonably necessary to
protect the rights, property, or safety of Fliply, our users, or the public.
Business Transfers. In connection with any merger, acquisition, reorganization, sale of
assets, or bankruptcy, your information may be transferred to the acquiring entity or
successor.
With Your Consent. We may share your information with third parties when you have
given us your explicit consent to do so.
5. Data Retention
We retain your personal information for as long as reasonably necessary to fulfill the purposes
for which it was collected. The specific retention periods are as follows:
•
•
Account Data (email, wallet address): Retained for the duration of your account plus
12 months after account deletion or termination.
Transaction Data: Retained for 5 years after the transaction date for tax, compliance,
and regulatory purposes.
•
•
Analytics and Usage Data: Retained for 24 months from the date of collection.
Communication Records: Retained for the duration of your account plus 12 months, or
longer if required for ongoing disputes or legal matters.
•
Legal and Compliance Data: Retained for such period as required by applicable law
(typically 5-7 years).
Blockchain Data: Information recorded on the Solana blockchain (including public wallet
addresses and transaction data) is permanently stored on the blockchain and cannot be deleted
or modified by Fliply or any other party. This is an inherent characteristic of blockchain
technology.
In some circumstances, we may anonymize your personal information so that it can no longer
be associated with you, in which case we may use such anonymized information without further
notice to you.
6. Data Security
We implement reasonable administrative, technical, and physical security measures to protect
your personal information from unauthorized access, use, alteration, or destruction. These
measures include encryption, access controls, secure development practices, and regular
security assessments.
However, no method of transmission over the Internet or electronic storage is 100% secure.
While we strive to protect your personal information, we cannot guarantee its absolute security.
You are responsible for maintaining the confidentiality of your account credentials and wallet
any unauthorized access to your account.
Page 4 of 7
Fliply – Privacy Policy
7. International Data Transfers
Your information may be transferred to, stored, and processed in countries other than the
country in which you reside, including countries that may have different data protection laws
than your jurisdiction. By using the Services, you consent to the transfer of your information to
such countries.
We take reasonable steps to ensure that your information is treated securely and in accordance
with this Policy, regardless of where it is processed. Where required by applicable law, we
implement appropriate safeguards for cross-border data transfers, including standard
contractual clauses or other legally recognized transfer mechanisms.
8. Your Privacy Rights
Depending on your jurisdiction and applicable law, you may have certain rights regarding your
personal information, including:
•
•
•
Right to Access. You have the right to request access to the personal information we
hold about you and to receive a copy of such information.
Right to Correction. You have the right to request correction of any inaccurate or
incomplete personal information we hold about you.
Right to Deletion. You have the right to request deletion of your personal information,
subject to certain exceptions (such as legal retention requirements or
blockchain-recorded data that cannot be deleted).
•
•
•
Right to Object. You have the right to object to our processing of your personal
information in certain circumstances, including processing for direct marketing purposes.
Right to Restriction. You have the right to request restriction of processing of your
personal information in certain circumstances.
Right to Data Portability. You have the right to receive your personal information in a
structured, commonly used, and machine-readable format and to transmit it to another
controller.
•
•
Right to Withdraw Consent. Where we rely on your consent to process your personal
information, you have the right to withdraw your consent at any time. Withdrawal of
consent does not affect the lawfulness of processing carried out before the withdrawal.
Right to Opt Out. You have the right to opt out of the processing of your personal
information for purposes of targeted advertising, and to opt out of the sale or sharing of
your personal information, to the extent applicable under your jurisdiction’s data
protection laws.
verification of your identity before processing your request. We will respond to your request
within thirty (30) days, or such shorter period as may be required by applicable law. If we
require additional time, we will notify you of the extension and the reasons for the delay.
Important Note: Due to the nature of blockchain technology, certain data recorded on the
Solana blockchain (including your public wallet address and transaction history) is permanently
and immutably stored and cannot be deleted, modified, or restricted by Fliply. Your rights under
this section do not extend to data that has been recorded on a public blockchain.
Page 5 of 7
Fliply – Privacy Policy
9. Children’s Privacy
The Services are not intended for individuals under the age of 21. We employ age verification
measures and do not knowingly allow individuals under 21 to create accounts or use the
Services. We do not knowingly collect personal information from individuals under 21 years of
age. If we become aware that we have inadvertently collected personal information from a
person under 21, we will take steps to delete such information as soon as practicable. If you
believe we have collected personal information from a person under 21, please contact us at
10. Third-Party Links and Services
The Services may contain links to third-party websites, applications, or services that are not
owned or controlled by Fliply, including Polymarket, Privy, and various blockchain explorers. We
are not responsible for the privacy practices of these third parties. We encourage you to review
the privacy policies of any third-party services before providing them with your personal
information.
11. Third-Party Analytics and Advertising
We use third-party analytics services, including Google Analytics and Mixpanel, to help us
understand how users interact with the Services. These services collect information about your
use of the Services using Cookies and similar technologies. The information generated is used
to compile reports and help us improve the Services. We have entered into data processing
agreements with these providers to ensure compliance with applicable data protection laws.
For more information about Google Analytics and how to opt out, visit:
https://tools.google.com/dlpage/gaoptout. For more information about Mixpanel’s privacy
practices, visit Mixpanel’s privacy policy page.
We may also use third-party advertising and retargeting tools, including Meta Pixel and TikTok
Pixel, to measure the effectiveness of our advertising campaigns and to deliver relevant
advertisements on third-party platforms. These tools may collect information about your
browsing activity across different websites. You can manage your advertising preferences
through the settings of the respective platforms (e.g., Facebook Ad Preferences, TikTok Ad
Settings) or through industry-standard opt-out mechanisms.
12. Changes to This Policy
We may update this Policy from time to time. When we do, we will revise the “Last Updated”
date at the top of this Policy and post the updated Policy on the Site. We encourage you to
review this Policy periodically. Your continued use of the Services after any modification to this
Policy constitutes your acceptance of the modified Policy. If we make material changes to this
Policy, we will notify you through the Services or by email at least fifteen (15) days before the
changes take effect.
13. Governing Law
Page 6 of 7
Fliply – Privacy Policy
This Policy and any dispute arising out of or related to this Policy shall be governed by and
construed in accordance with the laws of the British Virgin Islands, without regard to conflict of
laws principles. The Services are made available from the British Virgin Islands and are not
intended to subject Fliply Technologies Ltd to the laws or jurisdiction of any state, country, or
territory other than the British Virgin Islands.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data
practices, including requests to exercise your privacy rights, please contact us at:
Fliply Technologies Ltd
Email: [email protected]
Privacy Contact: [email protected]
Page 7 of 7