Effective date: 14 July 2026
This Privacy Policy explains how Fluck AI LTD ("Fluck", "we", "us", "our") collects and uses your personal data when you use the Fluck consumer app and related services (the "App"). Please read it alongside our Cookie Policy and Terms of Service.
1. Who we are and our role
Fluck AI LTD is a company registered in England & Wales under company number 15723506, with its registered office at Innovation Centre, Knowledge Gateway, Boundary Road, Colchester, Essex, CO4 3ZQ, United Kingdom.
For the personal data described in this policy, Fluck is the data controller. This means we decide why and how your personal data is processed.
You can contact us about privacy at any time:
- Email: hello@fluckai.com, or via the contact form at https://www.fluckai.com/contact
- Post: Data Protection, Fluck AI LTD, Innovation Centre, Knowledge Gateway, Boundary Road, Colchester, Essex, CO4 3ZQ, United Kingdom
We have not appointed a statutory Data Protection Officer, as we are not legally required to. The privacy contact above is responsible for handling privacy matters.
2. What the Fluck App does
The Fluck App helps you plan social activities and manage shared money with the people in your life. It includes:
- Plans — creating and coordinating social plans and events.
- Group chat — messaging within your plans and groups.
- Bill-splitting — recording who paid for what and calculating who owes whom. Fluck tracks and displays balances only; Fluck does not itself hold, store, transfer or move your money. Any actual payment happens directly between you and other people, outside the App.
- Rewards and loyalty — earning and redeeming rewards, including offers from nearby businesses.
- Documents vault — storing documents you choose to upload.
- Calendar — organising your plans and events over time.
3. The personal data we collect
We collect the following categories of personal data.
3.1 Data you give us
| Category | Examples |
|---|---|
| Account data | Name, email address, phone number, password (stored hashed), profile photo, date of birth (to confirm you meet the age requirement). |
| Contacts | To help you find friends already on Fluck, we let you match your phone contacts. We do this using privacy-preserving hashing: contact identifiers (such as phone numbers) are cryptographically hashed on your device and only the hashes are transmitted and compared. We do not store your contacts' raw phone numbers or build shadow profiles of people who are not Fluck users. |
| Plans and messages | The plans you create or join, group chat messages, reactions, and any content you post within a plan or group. |
| Bill-split records | Amounts, descriptions, participants, and the balances showing who owes whom. This is financial record-keeping data, not payment-processing data. |
| Uploaded documents | Files, images and documents you add to your documents vault or attach to plans and chats. |
| Support and correspondence | Messages you send us, feedback, and survey responses. |
3.2 Data we collect automatically
| Category | Examples |
|---|---|
| Device and technical data | Device model, operating system and version, app version, language, time zone, IP address, device identifiers, and crash and diagnostic logs. |
| Usage data | Features you use, screens you view, actions you take, and interaction timestamps. |
| Approximate location | With your permission, we use your approximate location to show you nearby rewards and relevant offers. You can decline or later disable this in your device settings; the App remains usable without it. We do not use continuous background precise-location tracking for advertising. |
We do not intentionally collect special category data (such as health, religion or political opinions). Please do not upload such data to the documents vault or chats unless necessary; if you do, you consent to us processing it to provide the storage and messaging features you have requested.
4. Why we use your data and our lawful bases (UK GDPR / EU GDPR)
We rely on the following lawful bases under Article 6 of the UK GDPR and EU GDPR.
| Purpose | Lawful basis |
|---|---|
| Create and manage your account; provide plans, chat, bill-split tracking, the documents vault and calendar | Contract (Article 6(1)(b)) — necessary to deliver the service you sign up for. |
| Match contacts via hashing so you can find friends | Consent (Article 6(1)(a)) — you choose to enable contact matching. |
| Show nearby rewards using approximate location | Consent (Article 6(1)(a)) — you choose to allow location. |
| Send service and transactional messages (e.g. plan updates, security notices) | Contract and legitimate interests (Article 6(1)(f)) in operating the service. |
| Send marketing and optional notifications | Consent (Article 6(1)(a)); you can withdraw it at any time. |
| Improve, secure and troubleshoot the App; prevent fraud and abuse; keep the service safe | Legitimate interests (Article 6(1)(f)) in running a secure, reliable product, balanced against your rights. |
| Provide our AI assistant features | Legitimate interests and, where applicable, consent (see section 12). |
| Comply with legal, tax, accounting and regulatory obligations; respond to lawful requests | Legal obligation (Article 6(1)(c)). |
| Establish, exercise or defend legal claims | Legitimate interests (Article 6(1)(f)). |
Where we rely on legitimate interests, we have carried out a balancing assessment. You can ask us for more detail using the contact in section 1.
5. Who we share your data with
We do not sell your personal data. We share it only as follows.
- The people in your plans and groups — content you post (messages, plans, bill-split entries, shared files) is visible to the other participants you choose to share it with. Bill-split balances are shown to the participants in that bill.
- Businesses you interact with — if you redeem a reward, claim an offer, or contact a business through Fluck, we share the information needed to fulfil that interaction (for example that you redeemed a specific reward). Those businesses act as their own controllers for what they do with that data.
- Service providers and sub-processors — we use trusted providers for cloud hosting, storage, messaging delivery, push notifications, email, analytics, crash reporting and customer support. They process data on our instructions under written contracts and may not use it for their own purposes.
- Professional advisers and authorities — lawyers, auditors, insurers, and regulators or law enforcement where we are legally required to disclose, or to protect our rights, users or the public.
- Corporate transactions — if Fluck is involved in a merger, acquisition or sale of assets, data may be transferred subject to this policy.
6. International data transfers
We are based in the UK and use service providers that may process data outside the UK and the European Economic Area (EEA). Where we transfer personal data internationally, we put appropriate safeguards in place, including:
- the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses for transfers from the UK; and
- the EU Standard Contractual Clauses (SCCs) for transfers from the EEA;
- transfers to countries covered by a UK or EU adequacy decision, where applicable.
You can request a copy of the relevant safeguards using the contact in section 1.
7. How long we keep your data
We keep personal data only as long as necessary for the purposes it was collected for.
- Account, plans, chats, bill-split records and vault documents — for as long as your account is active.
- After account deletion — we delete or anonymise your personal data within 90 days, except where we must retain limited data longer to meet legal obligations (for example, financial or tax records), resolve disputes, or enforce our agreements.
- Backups — residual copies in secure backups are deleted on our normal backup rotation.
- Diagnostic and log data — typically retained for up to 12 months.
8. Your rights
8.1 UK and EU GDPR rights
Subject to conditions in the law, you have the right to:
- access a copy of your personal data;
- request rectification of inaccurate data;
- request erasure ("right to be forgotten");
- restrict processing;
- object to processing based on legitimate interests, and to object to direct marketing at any time;
- data portability — receive certain data in a portable format;
- withdraw consent at any time where we rely on consent (this does not affect earlier processing);
- not be subject to solely automated decisions with legal or similarly significant effects (we do not make such decisions in the App).
To exercise any right, email hello@fluckai.com. We will respond within one month, and we will not charge a fee or discriminate against you for exercising your rights. We may ask you to verify your identity.
8.2 California rights (CCPA/CPRA)
If you are a California resident, you have the right to:
- know what personal information we collect, use and disclose;
- delete personal information we hold about you;
- correct inaccurate personal information;
- opt out of the "sale" or "sharing" of personal information; and
- non-discrimination — we will not discriminate against you for exercising your rights.
We do not sell or share your personal information as those terms are defined under the CCPA/CPRA, and we do not use or disclose sensitive personal information beyond the purposes permitted by law. To exercise your rights, contact hello@fluckai.com. You may use an authorised agent, and we will verify requests before acting on them.
9. Cookies and similar technologies
The App and our websites use cookies and similar technologies (including mobile SDK identifiers). Please see our Cookie Policy for details on categories, consent and how to manage your choices.
10. Children
The Fluck App is intended for users aged 16 and over. We do not knowingly collect personal data from anyone under 16. If you believe a child under 16 has provided us data, contact hello@fluckai.com and we will delete it.
11. How we protect your data
We use technical and organisational measures appropriate to the risk, including encryption in transit (TLS) and at rest, hashed and salted passwords, access controls and least-privilege permissions, network security, logging and monitoring, and staff confidentiality obligations. No system is completely secure, but we work continuously to protect your data and will notify you and the relevant authority of any breach where we are legally required to.
12. Artificial intelligence features
Fluck offers AI-assisted features (for example, suggestions, summaries and helper tools). These features are assistive and human-reviewable: they help you but do not make legally or similarly significant decisions about you on a solely automated basis. Where an AI feature processes your content, it does so to provide the feature you have requested. We do not use your private chat or vault content to train third-party foundation models without a lawful basis and appropriate safeguards. You can choose not to use optional AI features.
13. Changes to this policy
We may update this policy from time to time. If we make material changes, we will notify you in the App or by email before they take effect. The "Effective date" at the top shows when this version applies.
14. How to complain
If you have concerns, please contact us first at hello@fluckai.com so we can try to resolve them.
You also have the right to complain to a data protection authority:
- UK: Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — https://ico.org.uk — 0303 123 1113.
- EU: the supervisory authority in your country of residence, place of work, or where the alleged infringement took place.
15. Alignment with app store privacy disclosures
To help you understand our app store labels:
- Apple App Privacy labels — we disclose the data types we collect (such as contact info, user content, identifiers, usage data, diagnostics and approximate location) and whether they are linked to you. We do not use data for third-party advertising tracking, and we request App Tracking Transparency permission only if and where any tracking would occur.
- Google Play Data Safety — we disclose the data we collect and share, our security practices (encryption in transit, ability to request deletion), and that data sharing is limited to the purposes described in this policy.
These summaries are simplified; this Privacy Policy is the authoritative description of our practices.
Questions? hello@fluckai.com
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