Flip Privacy Policy

Last updated: April 10, 2025

This Privacy Policy (“Privacy Policy” or “Policy”) applies to the collection and use of personal information by Humans, Inc. d/b/a Flip (“Flip,” “Company”, or “we,” or “us,” or “our”). It describes the Company’s practices regarding the collection, use, disclosure, and sale of personal information when you visit and interact with us, our application (the “Application”) or our website (collectively, the “Sites”) to access our services (the “Services”). By accessing the Sites, you agree to our collection and use of personal data as described herein and agree to our Terms of Use.

For purposes of this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

Opt out

By opting out here, we will not “share” or “sell” your information and you will be opted out of “targeted advertising” as defined under certain privacy laws. Please note that you won’t be able to change this preference. Your choice here is unrelated to the mechanisms by which you can opt out of emails from us, which are described in our Privacy Policy.

Notice at Collection: Personal Information We Collect

We collect the following categories of Personal Information:

• Personal identifiers: Name, billing and mailing addresses, email address, telephone numbers, IP address, mobile ad ID, account username and password, social media platform usernames/handles, date of birth, gender, your contacts and their contact information (if you choose to provide us with access), social media avatar, and identifying information you may voluntarily provide to use through our Live Support or other customer service platforms.
• Commercial information: Records of products purchased or considered; consuming histories or tendencies; records of videos viewed and engagement with those videos (comments, likes, dislikes) and products that appear on them; comments, reviews, likes and dislikes and purchases associated with videos you post; beauty preferences (hair type, skin type and tone, skin concerns) provided.
• Internet or other electronic activity information: Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites (including flip videos on the Site) and our advertisements.
• Professional information: Name of the company or entity that you represent, title and position information.
• Audio and visual information: Recordings of customer service calls, your voice and image as they appear on videos uploaded to the platform, photographs you post.
• Inferences drawn from any of the Personal Information identified above.

We have collected the same categories of personal information in the 12 months preceding the date of this Policy.

Notice at Collection - Purposes for Collection of Personal Information

We collect the categories of Personal Information identified for the following purposes:

Notice at Collection: Categories of Personal Information We Sell or Share for Targeted Advertising

We work with AppLovin, an advertising platform, to deliver advertisements on the FLIP mobile application and we sell / share for cross-context behavioral or targeted advertising the following categories of personal information with them:

• Personal identifiers: names, email addresses, phone numbers, mailing addresses, usernames, IP address, mobile advertising IDs
• Commercial information: records of products purchased or considered; consuming histories or tendencies; records of videos viewed and engagement with those videos (comments, likes, dislikes) and products that appear on them
• Internet or other electronic activity information: device and browser type, browsing and search history on our Sites, and information regarding your interaction with our Sites (including flip videos on the Site) and our advertisements

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for marketing purposes.

For more information about AppLovin’s collection and use of personal information we provide to it with it, visit https://www.applovin.com/privacy/.

For more information about the use of cookies and other tracking technologies, see the section “Our Use of Cookies and Analytics” below.

If your state law provides rights to opt-out of such sales and sharing of personal information for cross-context behavioral advertising or targeted advertising, click here to exercise those rights. See U.S. State Data Privacy Rights section below for more information about states with such rights.

We do not sell or share for cross-context behavioral advertising any other categories of personal information.

Opt-out Preference Signals / Do Not Track

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control (“GPC”) signal for users in California, Colorado, Connecticut, Montana, New Hampshire, and Oregon. If you are logged into your account when you visit our website with the Global Privacy Control signal enabled, we will recognize your opt-out selection with respect to all personal information we collect about you, including through our mobile application. If you are not logged in when you visit the website, we will only recognize your opt-out preference on the browser and device that transmits the signal. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

We do not recognize the “do not track” or “DNT” signal that was introduced in the early 2010s and not broadly adopted.

Notice at Collection: Retention Periods

We retain the categories of personal information we collect for the length of time necessary to provide our Services and to comply with legal obligations or to protect our legal rights.

Sources From Which We Collect Personal Information

We collect personal information directly from users of our Services, visitors to our website, users who may share your contact information with us, AppLovin, Facebook, and representatives of entities with which we do business or may do business.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.

No Profiling to Facilitate Decisions with Legal or Other Significant Effects

We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects, such as the provision or denial of financial or lending services, housing, insurance, or access to essential goods or services.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of personal information we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information to the categories of third parties identified above to process payments, fulfill and ship orders, and to operate our IT systems and secure our systems.

Additional Information About How We May Disclose Personal Information and Purposes for Disclosures

We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Our Use of Cookies and Analytics

We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our Sites. Tracking technologies are small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our Sites. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with our Services.

We may also allow third parties to use third party cookies, web beacons, and other storage technologies to collect or receive information about how you interact with our Sites and elsewhere on the Internet and use that information to provide analytics and other measurements services, and to deliver and target advertisements tailored to you.

You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

Third Party Websites and Applications

Our Sites may contain links to other third-party websites, applications or social media platforms, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites, applications or platforms. Accordingly, we recommend that you review the privacy policies posted on any website, application or social media platform that you may access through our Sites.

How We Keep Your Personal Information Secure

We implement and maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of personal information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

International Residents

Personal information collected from you, including via our Sites, will be transferred to the United States where the Sites are hosted. You hereby consent to the transfer of your personal information to the United States as described in this Privacy Policy. Please do not use the Sites if you do not agree to the transfer and processing of your personal information in the United States, which may not provide the same level of protection for your data as your home country.

Minors

Our Sites are not directed to minors under the age of 13 and are not to be used by minors under 16 years old. If you are under age 16, please do not access our Sites or download the Application (or delete it if you have downloaded it) and do not provide any personal information to us.

Changes to the Privacy Policy

We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Sites notification that the Policy has been updated and by updating the date of the Policy.

Accessibility

We work to make our Sites accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at legal@flip.shop.

Facebook User Deletion Rights

In addition to any U.S. State Data Privacy Rights you may have as explained below, we offer Facebook account holders the ability to delete the following categories of personal information to the extent we collect such data from Facebook and no other source: email addresses, first and last name, Facebook avatar. To exercise this deletion right, please email us at privacy@flip.shop and provide your Facebook username.

U.S. State Data Privacy Rights

Consumer Rights Under Comprehensive U.S. State Data Privacy Laws

State privacy laws in the following states give residents of those states various rights with respect to the personal information we collect: California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia. In addition, the following other state data privacy laws will come into effect after the date of this Privacy Policy: Tennessee (effective July 1, 2025); Minnesota (effective July 31, 2025); and Maryland (effective October 1, 2025). The rights provided under these laws are similar in many respects, with some differences from state to state. We list below these rights, noting that not all rights are available under each state’s law:

Right to Know: The right to confirm whether we are processing a resident’s personal information and to access such data. Laws in some states provide the right to know more detailed information.

• California’s privacy law gives residents the right to request the following additional information collected since January 1, 2022: Categories of personal information we have collected about them; categories of sources from which such personal information was collected; categories of personal information that the business sold or disclosed for a business purpose about the consumer; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling your personal information.
• Oregon’s privacy law gives residents the right to request a list of third party entities to which we have disclosed personal information. Minnesota’s privacy law will have the same right when it comes into effect on July 31, 2025.

Right to Access / Copy: The right to access or request a copy of the personal information we have collected from the resident, subject to certain exceptions.

Right to Delete: The right to request deletion of their personal information that we have collected from or about the resident and to have such information deleted, subject to certain exceptions.

Right to Correct: The right to request that we correct inaccuracies in personal information, taking into account the nature of personal data and purposes of processing such information.

Rights to Opt-Out: Various rights to request that we stop using an individual’s personal information for one or more of the following purposes:

• Sale of Personal Information: The right to request that we stop selling their personal information, consistent with the definition of “sale” in each law.
• Targeted Advertising: The right to request that we stop processing their personal information for targeted advertising, subject to exceptions in some state laws.
• Sharing for Cross-Context Behavioral Advertising: California’s law provides the right to request that we stop sharing personal information for cross-context behavioral advertising.

Please note, California’s law is the only law that applies to all state residents, irrespective of the context in which they interact with us (e.g., a customer, a business contact, a vendor). Laws in other states apply only to people when acting in an individual or household context.

California Shine the Light

With reference to California Civil Code Section 1798.83, also known as the “Shine the Light” law, we allow California residents to opt-out of the disclosure of personal information to third parties for those third parties’ direct marketing purposes. To exercise that opt-out option, click contact us at privacy@flip.shop.

Exercising Your Rights and How We Will Respond

We will respond to requests from residents of states with data privacy laws that apply to us and will do so with respect to the rights that are provided under the requestor’s state law as of the effective date of that law. The laws in some states listed above may not be in effect as of the date of this Privacy Policy.

To exercise rights to know, access/copy, delete, correct, or know third parties to whom personal information is disclosed, contact us at privacy@flip.shop. We will provide a substantive response to these requests within 45 days of the date on which we receive your request. If we require additional information or time to process your requests, we will contact you.

To exercise opt-out rights, submit your request here.

Opt-out Preference Signals and Do Not Track

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt-out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal where required by law in California, Colorado, Connecticut, Montana, New Hampshire, and Oregon, and do so at the browser level. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

We will respond to opt-out requests as soon as feasibly possible, but no later than 15 business days after receipt of your request. If we require additional information or time to process your requests, we will contact you.

We do not respond to the DNT or “Do Not Track” signal.

Exercising Your Rights Using Authorized Agents

Agents may submit opt-out requests on behalf of individuals under several state data privacy laws; this is not an option that is available under all state data privacy laws, though. California residents have the right to designate an agent to submit all other types of requests.

If your agent submits an opt-out request on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. This requirement does not apply to any tool that facilitates the operation of the Global Privacy Control signal. Agents can submit opt-out requests by contacting us at privacy@flip.shop.

If you are a California resident and you use an agent to submit other types of requests, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. You will also be required to verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request. Agents can submit requests on behalf of California residents (other than opt-out requests) by contacting us at privacy@flip.shop.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with state law pertaining to powers of attorney.

Verification of Requests

When you exercise rights other than opt-out rights, we will take steps to verify your identity. We will ask you for at least two pieces of personal information, depending on the nature of the request, and attempt to match those to information that we maintain or collect about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.

When We Do Not Act on a Request – Appeal Process

In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.

Additionally, you have the right to appeal our decision by contacting us at privacy@flip.shop within 30 days after your receipt of our decision.

Non-Discrimination

If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.

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