GDPR PRIVACY POLICY

Last Updated: May 8, 2025

1. INTRODUCTION

This Privacy Policy (“Policy”) describes how FlixFox (“Company,” “we,” “our,” or “us”) collects, uses, processes, discloses, and safeguards personal data when individuals (“Users,” “you,” or “your”) access or use the FlixFox application (“Application”) on Android devices. This Policy has been drafted in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and outlines the rights and obligations of all parties concerned.

2. INFORMATION COLLECTED

The Company processes the following categories of personal data:

2.1 Account Information: Name, email address, telephone number, and other information provided during account creation or customer service interactions.

2.2 Technical Data: Device specifications, Internet Protocol (IP) address, browser type, operating system version, and device identifiers.

2.3 Usage Information: Content viewing history, feature utilization, session duration, search queries, and interaction metrics.

2.4 Geolocation Data: General location information limited to country/region for content regionalization purposes.

2.5 Transaction Data: Records of premium subscription purchases and related transaction details (excluding complete payment card information).

2.6 Referral Data: Information pertaining to participation in the referral rewards program.

3. PURPOSES OF PROCESSING

Personal data is processed for the following specified purposes:

3.1 Provision and maintenance of the Application’s streaming services and user preferences.

3.2 Processing payments and management of subscription status.

3.3 Application improvement, performance optimization, and feature development based on usage analytics.

3.4 Communication of service updates, offers, and personalized recommendations.

3.5 Administration of the rewards program and tracking of referral activities.

3.6 Detection and prevention of unauthorized access or fraudulent activities.

3.7 Compliance with legal obligations and enforcement of Terms of Service.

4. LEGAL BASIS FOR PROCESSING

The Company processes personal data in accordance with GDPR Article 6, under the following legal bases:

4.1 Performance of Contract: Processing necessary for the provision of services as outlined in the Terms of Service.

4.2 Legitimate Interests: Processing justified by legitimate business interests that do not override Users’ privacy rights, including service improvement and fraud prevention.

4.3 Consent: Processing based on explicit User consent for specific activities, including marketing communications.

4.4 Legal Obligation: Processing required for compliance with applicable laws and regulations.

5. DATA SHARING

The Company restricts data sharing to the following circumstances:

5.1 With service providers acting as data processors who assist in delivering services (payment processors, cloud storage providers, customer support systems).

5.2 With connected devices when Users utilize the multi-device login functionality.

5.3 With authorized premium code vendors for transaction verification purposes.

5.4 With law enforcement or regulatory authorities when legally mandated.

5.5 In connection with corporate transactions, including mergers, acquisitions, or asset sales.

All third parties receiving data are subject to contractual data protection obligations.

6. DATA SECURITY

The Company implements appropriate technical and organizational measures to ensure data security, including:

6.1 Industry-standard encryption for data in transit and at rest.

6.2 Regular security assessments and vulnerability testing.

6.3 Role-based access controls, limiting data access.

6.4 Continuous monitoring for suspicious activities.

6.5 Regular staff training on data protection protocols.

The Company acknowledges that no security system is infallible and commits to prompt notification in the event of a personal data breach in accordance with GDPR requirements.

7. USER RIGHTS

Pursuant to GDPR Articles 15-22, Users have the following rights regarding their personal data:

7.1 Right of Access (Article 15): The right to obtain confirmation of processing and receive a copy of personal data.

7.2 Right to Rectification (Article 16): The right to correction of inaccurate or completion of incomplete personal data.

7.3 Right to Erasure (Article 17): The right to deletion of personal data under specified circumstances.

7.4 Right to Restriction of Processing (Article 18): The right to limit processing during complaint investigations.

7.5 Right to Data Portability (Article 20): The right to receive personal data in a structured, machine-readable format.

7.6 Right to Object (Article 21): The right to oppose certain types of processing, including direct marketing.

7.7 Right to Withdraw Consent: The right to revoke previously granted consent at any time.

To exercise these rights, Users may contact the Company through the in-app Customer Help Service Center.

8. COOKIES AND SIMILAR TECHNOLOGIES

The Application utilizes cookies and similar technologies, categorized as follows:

8.1 Essential Cookies: Required for Application functionality.

8.2 Preference Cookies: Store User settings and personalization parameters.

8.3 Analytics Cookies: Collect anonymized data on Application usage patterns.

8.4 Marketing Cookies: Enable targeted advertising delivery.

Users may manage cookie preferences through device settings, with the understanding that disabling certain cookies may impair functionality.

9. INTERNATIONAL DATA TRANSFERS

As a global service provider, the Company may process data in jurisdictions outside the European Economic Area (EEA). All international data transfers are conducted in compliance with GDPR Chapter V, utilizing:

9.1 Standard Contractual Clauses approved by the European Commission.

9.2 Adequacy decisions issued by the European Commission.

9.3 Binding corporate rules where applicable.

10. DATA RETENTION

The Company retains personal data only for the period necessary to fulfill the purposes outlined in this Policy:

10.1 Account information is retained for the duration of the active account.

10.2 Transaction records are retained as required by applicable financial regulations.

10.3 Usage data is retained for a limited period to facilitate service quality improvement.

Upon expiration of the retention period, personal data is securely deleted or anonymized in accordance with established data protection protocols.

11. POLICY AMENDMENTS

The Company reserves the right to modify this Policy to reflect changes in processing practices or legal requirements. Significant amendments will be communicated via:

11.1 Application notifications.

11.2 Email notifications to registered Users.

11.3 Website updates.

The date of the most recent revision is indicated at the beginning of this Policy.

12. CONTACT INFORMATION

For inquiries regarding this Policy or data protection matters, or to exercise your rights under GDPR, please contact us through the in-app Customer Help Center. Our designated support team will address your concerns in accordance with applicable data protection regulations.

By downloading, installing, or using the Application, Users acknowledge having read and understood this Privacy Policy.