FlipWall

Privacy Policy

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Privacy Policy

Effective Date: June 29, 2026

Last Updated: June 29, 2026

ALUSO ("we," "us," "our," or "Company") operates the FlipWall mobile application (the "App," "Service," or "Application"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Application.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

1. Information We Collect

We collect information that you provide directly to us, information that is automatically collected when you use our Application, and information from third-party sources as described below.

1.1 Personal Data

We may collect personally identifiable information that you voluntarily provide to us when you use the Application, express an interest in obtaining information about us or our products and services, or otherwise contact us. The personal information we collect depends on the context of your interactions with us and the Application, the choices you make, and the features you use.

The personal data we collect may include the following:

  • Contact information such as email addresses when you contact us for support
  • Communications data including any messages you send through the Application or to our support email
  • Any other information you choose to provide to us directly

1.2 Photos and Media Files

FlipWall accesses photos, media files, and files on your device for the core functionality of the Application. Specifically:

  • Photo Gallery Access: The Application requires access to your device's photo gallery and media storage to allow you to select, view, organize, and manipulate images for use as wallpapers
  • Media Storage Access: We access media files stored on your device to enable you to customize your device wallpaper using your personal photos
  • Local Processing: All photo and media processing occurs locally on your device
  • No Upload or Transmission: Photos and media files accessed by FlipWall are not uploaded to our servers, transmitted to third parties, or stored outside of your device
  • User Control: You maintain complete control over which photos and media files the Application accesses, and you can revoke these permissions at any time through your device settings

We do not collect, store, or transmit your photos or media files to any external servers or third parties. All interactions with your photos occur exclusively on your local device.

1.3 Device Information

When you use the Application, we may automatically collect certain information about your device, including:

  • Device type and model
  • Operating system type and version
  • Screen resolution and display characteristics
  • Device identifiers (such as Android ID or Advertising ID)
  • Mobile network information
  • Language settings
  • Time zone settings

1.4 Usage Data

We may collect information about how you access and use the Application, including:

  • Application features accessed and utilized
  • Time spent using the Application
  • Frequency of Application use
  • Application crashes and performance data
  • Error logs and diagnostic information
  • User preferences and settings within the Application

1.5 Information We Do Not Collect

FlipWall does not collect the following types of information:

  • Precise geolocation data
  • Financial or payment information
  • Health or medical information
  • Biometric data
  • Content of your photos or media files
  • Contacts or address book information
  • SMS or call logs
  • Microphone or camera data (except when you explicitly use camera features)

2. How We Use Your Information

We use the information we collect or receive for the following purposes:

2.1 To Provide and Maintain the Application

  • To enable the core functionality of FlipWall, including wallpaper customization features
  • To process and respond to your requests and inquiries
  • To provide you with access to photos and media on your device as required for the Application's functionality
  • To save your preferences and settings within the Application
  • To ensure the Application functions properly on your device

2.2 To Improve and Optimize the Application

  • To understand how users interact with the Application
  • To identify and fix bugs, errors, and technical issues
  • To analyze usage patterns and trends
  • To develop new features and functionality
  • To test and improve Application performance
  • To optimize user experience based on device characteristics

2.3 To Communicate with You

  • To respond to your inquiries and provide customer support
  • To send you technical notices and updates
  • To inform you about changes to our Privacy Policy or Terms of Service
  • To provide you with information about the Application that you request from us

2.4 For Security and Legal Compliance

  • To detect, prevent, and address technical issues and security vulnerabilities
  • To protect against fraudulent, unauthorized, or illegal activity
  • To enforce our Terms of Service and other policies
  • To comply with applicable laws, regulations, and legal processes
  • To respond to lawful requests from public authorities
  • To protect our rights, privacy, safety, or property, and that of our users and the public

2.5 With Your Consent

We may use your information for other purposes with your explicit consent, which you may withdraw at any time.

3. How We Share Your Information

We do not sell, trade, rent, or otherwise transfer your personal information to third parties. However, we may share your information in the following limited circumstances:

3.1 Service Providers

Currently, FlipWall does not utilize any third-party service providers. In the future, if we engage service providers to perform functions on our behalf, they will only have access to the information necessary to perform their specific functions and will be contractually obligated to maintain the confidentiality and security of that information.

3.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

3.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (such as a court, government agency, or law enforcement). We may disclose your information when we believe in good faith that disclosure is necessary to:

  • Comply with a legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with the Application
  • Protect the personal safety of users of the Application or the public
  • Protect against legal liability

3.4 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

3.5 Aggregated or De-identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you. Such information is not considered personal information and may be used and shared without restriction.

4. Third-Party Services and Analytics

FlipWall does not currently integrate any third-party services, analytics platforms, advertising networks, or social media features. Your photos and media files are processed entirely locally on your device and are not transmitted to any external services.

If we integrate third-party services in the future, we will update this Privacy Policy accordingly and provide you with information about:

  • The identity of the third-party service providers
  • The types of information shared with them
  • The purposes for which information is shared
  • Links to their respective privacy policies
  • Options for opting out of such services where applicable

5. Data Storage and Security

5.1 Where We Store Your Information

All photos and media files accessed by FlipWall remain stored locally on your device. We do not upload, transmit, or store your photos or media files on remote servers. Any other data collected through the Application is stored securely and in accordance with applicable data protection laws.

5.2 Security Measures

We implement appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

  • Encryption of data in transit and at rest where applicable
  • Regular security assessments and updates
  • Access controls and authentication procedures
  • Secure coding practices and regular security testing
  • Incident response and breach notification procedures
  • Employee training on data protection and security best practices

However, please be aware that no security measures are perfect or impenetrable. We cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your information for improper purposes. You acknowledge that you provide your information at your own risk.

5.3 Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:

  • The duration of your use of the Application
  • Whether you have deleted your account or uninstalled the Application
  • Whether we have a legal obligation to retain the information
  • Whether retention is advisable in light of our legal position (such as regarding statutes of limitations, litigation, or regulatory investigations)

When we no longer need to retain your information, we will delete it or anonymize it. If deletion is not possible (for example, because information has been stored in backup archives), we will securely store your information and isolate it from further processing until deletion is possible.

6. Your Rights and Choices

Depending on your location and applicable laws, you may have certain rights regarding your personal information.

6.1 Access and Correction

You have the right to access the personal information we hold about you and to request that we correct, update, or complete any inaccurate or incomplete information. Since FlipWall processes photos and media locally on your device, you maintain direct control over this content through your device's native file management systems.

6.2 Deletion

You have the right to request that we delete your personal information under certain circumstances, including:

  • When the information is no longer necessary for the purposes for which it was collected
  • When you withdraw your consent (where consent was the legal basis for processing)
  • When you object to the processing and there are no overriding legitimate grounds
  • When the information has been unlawfully processed
  • When deletion is required to comply with a legal obligation

Please note that we may need to retain certain information for legal compliance, record-keeping purposes, or to complete transactions you initiated.

6.3 Restriction of Processing

You have the right to request that we restrict the processing of your personal information under certain circumstances, such as when you contest the accuracy of the information or object to our processing.

6.4 Data Portability

You have the right to receive the personal information you provided to us in a structured, commonly used, and machine-readable format, and to request that we transfer this information to another controller where technically feasible.

6.5 Objection

You have the right to object to our processing of your personal information under certain circumstances, particularly where we process information based on legitimate interests.

6.6 Withdrawal of Consent

Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

6.7 App Permissions

You can control the permissions granted to FlipWall through your device settings:

  • Storage/Photos Access: You can revoke access to your photos and media files at any time through your device's app permission settings. Note that revoking this permission will prevent the Application from functioning as intended
  • Other Permissions: You can manage all other app permissions through your device settings

6.8 Exercising Your Rights

To exercise any of these rights, please contact us using the contact information provided below. We will respond to your request within the timeframe required by applicable law, typically within 30 days. We may need to verify your identity before processing your request. If we are unable to fulfill your request, we will explain the reasons for our decision.

6.9 Right to Lodge a Complaint

If you believe we have not handled your personal information in accordance with applicable law, you have the right to lodge a complaint with your local data protection authority or supervisory authority.

7. International Data Transfers

ALUSO operates globally, and information may be transferred to, stored, and processed in countries other than the one in which it was collected. These countries may have data protection laws that are different from the laws of your country.

When we transfer personal information internationally, we implement appropriate safeguards to protect your information, including:

  • Ensuring that transfers are made only to countries recognized as providing an adequate level of data protection
  • Implementing standard contractual clauses approved by relevant data protection authorities
  • Ensuring that US-based recipients participate in recognized cross-border transfer frameworks where applicable
  • Obtaining your explicit consent for the transfer where required

By using the Application, you acknowledge and agree that your information may be transferred to and processed in countries outside your country of residence, which may have different data protection standards.

8. Children's Privacy

FlipWall is not intended for use by children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be higher). We do not knowingly collect personal information from children under 13 years of age.

If you are a parent or guardian and you become aware that your child has provided us with personal information without your consent, please contact us using the contact information below. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to remove that information from our servers promptly.

For users in the European Union, we do not knowingly collect personal information from children under 16 years of age without parental consent, or under the age specified by the law of your country if different.

9. Region-Specific Privacy Rights

Depending on your location, you may have additional privacy rights under applicable local laws.

9.1 European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR) and equivalent laws, including:

  • The right to be informed about how your personal data is being used
  • The right of access to your personal data
  • The right to rectification of inaccurate personal data
  • The right to erasure ("right to be forgotten") under certain circumstances
  • The right to restrict processing under certain circumstances
  • The right to data portability
  • The right to object to processing based on legitimate interests
  • Rights in relation to automated decision-making and profiling

Legal Basis for Processing: We process your personal information based on the following legal grounds:

  • Consent: When you have given explicit consent for specific processing activities
  • Contractual Necessity: When processing is necessary to provide the Application services you have requested
  • Legal Obligation: When processing is necessary to comply with legal requirements
  • Legitimate Interests: When processing is necessary for our legitimate interests, such as improving our services, preventing fraud, and ensuring security, provided these interests are not overridden by your data protection rights

You may lodge a complaint with your local supervisory authority if you believe we have violated your privacy rights.

9.2 California Residents (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including:

  • Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, the business purpose for collecting it, and the categories of third parties with whom we shared it
  • Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions
  • Right to Correct: You have the right to request correction of inaccurate personal information
  • Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information. We do not sell your personal information
  • Right to Limit Use of Sensitive Personal Information: Where applicable, you have the right to limit our use of sensitive personal information
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights

Categories of Personal Information Collected:

  • Identifiers (such as device identifiers)
  • Device and usage information
  • Visual information (photos and media accessed locally on your device, not collected or stored by us)

Sale or Sharing of Personal Information: We do not sell your personal information as defined under CCPA. We do not share your personal information for cross-context behavioral advertising.

To exercise your California privacy rights, contact us at alusoa22@gmail.com. We will verify your identity before processing your request.

9.3 Virginia, Colorado, Connecticut, and Utah Residents

If you are a resident of Virginia, Colorado, Connecticut, or Utah, you have rights under your state's comprehensive privacy law, including:

  • The right to confirm whether we process your personal data and access such data
  • The right to correct inaccuracies in your personal data
  • The right to delete personal data you provided
  • The right to obtain a copy of your personal data in a portable format
  • The right to opt out of the processing of personal data for targeted advertising, the sale of personal data, or profiling

We do not engage in targeted advertising, sell personal data, or conduct profiling that produces legal or similarly significant effects.

9.4 Brazil Residents (LGPD)

If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including the right to:

  • Confirm the existence of processing
  • Access your personal data
  • Correct incomplete, inaccurate, or outdated data
  • Anonymize, block, or delete unnecessary, excessive, or unlawfully processed data
  • Request data portability
  • Obtain information about public and private entities with which we share data
  • Obtain information about the possibility of denying consent and the consequences thereof
  • Revoke consent

9.5 Other Jurisdictions

Users in other jurisdictions may have rights under their local privacy laws. We respect these rights and will comply with applicable legal requirements. Please contact us to learn more about your specific rights.

10. Do Not Track Signals

Some web browsers and mobile devices include a "Do Not Track" (DNT) feature or setting that signals your privacy preference not to have data about your online browsing activities monitored and collected. Currently, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy.

If we make material changes to this Privacy Policy, we will notify you by:

  • Posting a prominent notice within the Application
  • Sending an email notification to the email address you provided (if applicable)
  • Requiring you to accept the updated Privacy Policy before continuing to use the Application

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the Application after any changes to this Privacy Policy indicates your acceptance of the updated terms.

12. Third-Party Links and Services

The Application may contain links to third-party websites, applications, or services that are not owned or controlled by ALUSO. This Privacy Policy applies only to FlipWall. We are not responsible for the privacy practices of third-party websites, applications, or services.

We strongly advise you to review the privacy policies of any third-party sites, applications, or services you visit or use. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites, applications, or services.

13. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and applicable regulatory authorities as required by law. We maintain incident response procedures to address potential data breaches promptly and effectively.

Notifications will include:

  • The nature of the breach
  • The categories and approximate number of affected individuals
  • The categories and approximate number of affected records
  • The likely consequences of the breach
  • The measures we have taken or propose to take to address the breach
  • Contact information for further inquiries

14. Automated Decision-Making

FlipWall does not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. All processing of your information involves human oversight where decisions may impact your rights or the services we provide.

15. Business Transitions

In the event that ALUSO undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information may be among the assets transferred. You acknowledge that such transfers may occur and that any acquirer of ALUSO or its assets may continue to use your personal information as set forth in this Privacy Policy.

We will provide notice before your personal information is transferred and becomes subject to a different privacy policy. If material changes to our privacy practices will occur as a result of the business transition, you will be given the opportunity to opt-out or delete your information.

16. Contact Information and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

ALUSO
Email: alusoa22@gmail.com

When contacting us, please include:

  • Your full name
  • A detailed description of your question, concern, or request
  • Information that will help us verify your identity (if you are making a data subject request)
  • Your preferred method of response

We will respond to your inquiry within a reasonable timeframe, typically within 30 days of receipt. If we need additional time, we will inform you of the reason and extension period.

For users in the European Economic Area or United Kingdom, while we have not appointed a formal Data Protection Officer, all privacy-related inquiries should be directed to the email address above.

17. Acceptance of This Policy

By using FlipWall, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Application. Your continued use of the Application following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

18. Additional Information for Specific User Groups

18.1 Educational Institutions

If FlipWall is used within an educational institution, we comply with applicable educational privacy laws, including the Family Educational Rights and Privacy Act (FERPA) where applicable. Educational institutions should review this Privacy Policy to ensure compliance with their own data protection obligations.

18.2 Enterprise Users

If you use FlipWall as part of an organization or enterprise, your organization's administrator may have additional rights to access, control, and process information associated with your use of the Application. Please contact your organization for information about its privacy practices.

19. Privacy by Design

FlipWall is designed with privacy as a core principle. We implement privacy-protective features including:

  • Local processing of photos and media on your device rather than cloud-based processing
  • No transmission of your photos or media files to external servers
  • Minimal data collection limited to what is necessary for Application functionality
  • Transparent information about our data practices
  • User controls over permissions and data access
  • No third-party tracking or analytics services
  • Regular security assessments and updates

20. Legal Disclaimer

This Privacy Policy is designed to comply with privacy laws in multiple jurisdictions. However, privacy laws vary significantly across different countries and regions. While we strive to comply with all applicable laws, this Privacy Policy should not be construed as legal advice, and we recommend that you consult with legal counsel regarding your specific privacy obligations and rights in your jurisdiction.

Nothing in this Privacy Policy is intended to limit any rights you may have under applicable data protection laws. In the event of any conflict between this Privacy Policy and applicable law, the law shall prevail to the extent of the conflict.

21. Survival

All provisions of this Privacy Policy that by their nature should survive termination shall survive termination, including without limitation ownership provisions, warranty disclaimers, indemnity, and limitations of liability.

22. Entire Agreement

This Privacy Policy, together with our Terms of Service and any other legal notices published by us in the Application, shall constitute the entire agreement between you and ALUSO concerning the Application and supersede all prior or contemporaneous agreements, representations, warranties, and understandings with respect to the Application, the content, and the subject matter of this Privacy Policy.

23. Severability

If any provision of this Privacy Policy is held to be invalid or unenforceable by a court of competent jurisdiction, such provision shall be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law, and the remaining provisions shall continue in full force and effect.

24. Language

This Privacy Policy is written in English. Where we have provided translations for your convenience, the English version shall prevail in case of any conflict or inconsistency.

25. Questions and Feedback

We welcome your questions, comments, and concerns about privacy. Please contact us at alusoa22@gmail.com with any privacy-related feedback. Your input helps us improve our privacy practices and this Privacy Policy.

Last Updated: June 29, 2026

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