This PRIVACY POLICY (this "Policy") explains how 2743499 Alberta Inc., operating under the DBA Lotpoint ("Company", "we", "us", or "our"), collects, uses, discloses, and protects your personal information when you access and use FlipperLog, our web-based software-as-a-service (SaaS) platform (the "FlipperLog", or "Service").
We are committed to protecting your privacy and ensuring you have a positive experience on our platform. We comply with all applicable privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the General Data Protection Regulation (GDPR) in the European Union and European Economic Area, and the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) for California residents.
For privacy concerns, data subject requests, or questions about this Policy, please contact our Privacy Officer at support@flipperlog.com.
1. INFORMATION WE COLLECT
We collect personal information directly from you when you create an account, use the Service, and interact with our platform. The categories of personal information we collect include:
1.1. Information Provided During Account Registration
When you create a FlipperLog account, we collect the following information:
1.1.1. Full Name: We collect your legal first and last name or the name you provide during registration.
1.1.2. Email Address: We collect your email address, which is used for account access, password recovery, and to send you service notifications and updates.
1.1.3. Country of Residence: We collect information about your country of residence to comply with applicable laws and to customize service availability and tax information.
1.1.4. Default Currency Preference: We collect your preferred currency selection during the signup process to display pricing and financial calculations in your preferred currency.
1.1.5. Business Name (Optional): We provide an optional field for you to enter your business name or reselling operation name. Providing this information is entirely at your discretion.
1.2. Information Provided During Service Use
As you use FlipperLog, we collect and store all information you provide through the Service, which is stored securely on our servers to enable the functionality of the Service and to generate accurate reports and analytics specific to your account. The said information includes:
1.2.1. Inventory Data: Details about items you are tracking, including product names, descriptions, categories, quantities, purchase prices, sale prices, and condition information.
1.2.2. Expense Records: Information about expenses related to your business, including transaction amounts, dates, categories, descriptions, and payment methods.
1.2.3. Financial Information: Data used in profit calculations, including cost basis, selling prices, fees, and margin analysis.
1.2.4. Business Information: Any additional details you enter about your reselling business, inventory management processes, or financial operations.
1.2.5. Account Settings: Any preferences, configurations, or customizations you make within your account.
1.3. Information Collected Automatically
When you access and use FlipperLog, we automatically collect certain information about your interaction with the Service:
1.3.1. Usage Data: Information about which features you use, pages you visit, how long you spend on different sections, and the sequence of your actions within the Service.
1.3.2. Device Information: Technical information about the device you use to access the Service, including device type, operating system, browser type, and browser version.
1.3.3. IP Address: Your Internet Protocol (IP) address, which identifies your computer or network on the Internet.
1.3.4. Clickstream Data: Information about links you click, buttons you press, and the sequence of pages you visit within the Service.
1.3.5. Access Logs: Timestamps of when you access the Service, how long you remain logged in, and when you log out.
1.3.6. Referral Information: Information about how you learned about FlipperLog or which website referred you to us, if applicable.
1.4. Information from Third-Party Authentication Services
1.4.1. If you elect to create your FlipperLog account or log in using third-party authentication services such as Google OAuth, we do not directly collect your personal information from those services. However, you authorize the third-party provider to share limited account information with us, typically including your name and email address registered with that service.
1.4.2. We recommend reviewing the privacy policies of third-party authentication providers to understand their data practices and privacy protections.
1.5. Information We Do Not Collect
FlipperLog does not collect or request the following information unless you voluntarily provide it:
1.5.1. Payment Card Information: We do not collect, store, or process credit card numbers, debit card numbers, or other sensitive payment card data. Payment processing is handled by third-party payment processors that comply with PCI DSS standards.
1.5.2. Bank Account Details: We do not collect bank account numbers, routing numbers, or other banking information.
1.5.3. Sensitive Personal Information: We do not collect biometric data, health information, medical records, genetic information, social security numbers, driver's license numbers, passport numbers, or other government-issued identification numbers.
1.5.4. Criminal History: We do not collect information about criminal convictions, criminal charges, or criminal records.
1.5.5. Racial or Ethnic Origin: We do not collect information about your race, ethnicity, national origin, or similar sensitive characteristics unless required by law.
2. PURPOSE OF DATA COLLECTION AND USE
We collect and use your personal information for specific, legitimate purposes. We do not collect personal information without a clearly identified purpose and do not use your information for purposes beyond what we have disclosed.
2.1. Primary Purposes
2.1.1. Service Provision and Functionality: To create and maintain your account, provide access to FlipperLog, process your subscription, and deliver the features and functionality of the Service you have requested.
2.1.2. Account Administration: To manage your account, respond to your account-related requests, process updates to your account information, and provide account support.
2.1.3. Billing and Payment Processing: To process your subscription payments, charge your payment method, generate billing statements and invoices, and manage payment failures or disputes.
2.1.4. Customer Support: To provide technical support, troubleshoot issues, answer your questions about the Service, and respond to your inquiries and complaints.
2.1.5. Communication: To send you service-related communications including account confirmations, welcome emails, subscription renewal notifications, billing notifications, service updates, product announcements, and security alerts.
2.2. Analytics and Service Improvement
2.2.1. Usage Analysis: To analyze how users interact with the Service, which features are most popular, how users navigate the platform, and where users may encounter difficulties.
2.2.2. Performance Optimization: To identify performance bottlenecks, optimize system performance, improve page load times, and enhance the overall speed and reliability of the Service.
2.2.3. Feature Development: To understand which features are most valuable to users, identify gaps in functionality, and inform decisions about new features and improvements.
2.2.4. Trend Analysis: To identify trends in user behavior, preferences, and usage patterns to inform product strategy and development.
2.3. Legal and Compliance Purposes
2.3.1. Regulatory Compliance: To comply with applicable laws, regulations, statutes, court orders, and governmental directives.
2.3.2. Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized access, and abuse of the Service.
2.3.3. Dispute Resolution: To investigate and resolve disputes between users or between users and FlipperLog.
2.3.4. Legal Claims: To protect the legal rights, property, and safety of FlipperLog, our employees, our users, and the public.
2.3.5. Contract Enforcement: To enforce this Policy, our Terms of Service, and other agreements you have with us.
3. DATA SHARING AND DISCLOSURE
3.1. No Sale of Personal Information
3.1.1. FlipperLog does not sell, rent, lease, or otherwise provide your personal information to third parties for their direct marketing purposes. We have never sold personal information and do not intend to do so.
3.1.2. We do not sell your information under any circumstances, whether or not we have a commercial relationship with the buyer or whether the information is considered "personal data" under applicable law.
3.2. Service Providers and Vendors
3.2.1. We engage trusted third-party service providers to perform functions on our behalf. These service providers assist us in operating the Service and conducting our business. Your information may be shared with:
a. Payment Processors: Third-party payment processing companies that process credit card payments, debit card payments, and other payment methods. These processors are bound by strict contractual confidentiality obligations and comply with PCI DSS standards.
b. Cloud Hosting Providers: Companies that host our servers, databases, and infrastructure to ensure the Service remains available and secure.
c. Customer Support Platforms: Services that assist us in providing customer support, managing support tickets, and responding to user inquiries.
d. Email Service Providers: Companies that send service-related emails, notifications, and communications on our behalf.
e. Analytics Services: Providers that help us understand how users interact with the Service and identify opportunities for improvement.
f. Security and Fraud Prevention Vendors: Services that help us protect against fraud, unauthorized access, and security breaches.
3.2.2. All service providers are contractually obligated to:
a. Maintain the confidentiality of your personal information
b. Use your information only for the specific purposes we have identified
c. Implement reasonable security measures to protect your information
d. Comply with applicable privacy laws and regulations
3.3. Aggregated and Anonymized Information
3.3.1. We may use and disclose aggregated and anonymized information that does not identify you personally. Aggregated information combines data from multiple users in a way that obscures individual identity. Anonymized information has identifying elements removed so that it cannot be traced back to any individual user.
3.3.2. We may use aggregated and anonymized information for:
a. Internal research and development
b. Analytics and reporting
c. Marketing and business purposes
d. Benchmarking and industry analysis
e. Identifying trends and patterns
3.3.3. Aggregated and anonymized information is not subject to the restrictions in this Privacy Policy because it does not identify you.
3.4. Legal Requirements and Requests
3.4.1. We may disclose your personal information when required by law, court order, or governmental request, including:
a. Legal Process: When we receive a subpoena, court order, search warrant, or other legal process requiring disclosure.
b. Governmental Requests: When a government agency or official requests information for lawful purposes, including tax authorities, law enforcement, and regulatory agencies.
c. Legal Obligations: When disclosure is necessary to comply with applicable laws, regulations, or legal obligations.
d. Safety and Protection: When disclosure is necessary to protect the safety, rights, and property of FlipperLog, our users, or the public, or to prevent illegal activity.
3.4.2. When we receive a legal request, we will:
a. Notify you of the request when legally permissible and practicable
b. Provide only the minimum information required
c. Seek to obtain a protective order to limit disclosure where possible
3.5. Business Transitions
3.5.1. If FlipperLog is involved in a merger, acquisition, bankruptcy, reorganization, dissolution, or other business transaction or proceeding, your personal information may be disclosed as part of that transaction. We will provide notice to you if your information becomes subject to a different privacy policy.
4. YOUR PRIVACY RIGHTS AND CHOICES
4.1. Rights for European Union, European Economic Area, Swiss, and United Kingdom Residents under General Data Protection Regulation (GDPR)
4.1.1. If you are a resident of the EU, EEA, Switzerland, or the United Kingdom, the General Data Protection Regulation (GDPR) provides you with the following rights:
a. Right to Access: You have the right to request access to the personal information we hold about you. We will provide you with a copy of your personal information in a structured, commonly used, and machine-readable format.
b. Right to Rectification: You have the right to request correction of inaccurate, incomplete, or outdated personal information about you. We will correct the information promptly upon verification.
c. Right to Erasure (Right to Be Forgotten): You have the right to request deletion of your personal information, subject to certain legal and operational exceptions. We will delete your information unless we are required to retain it by law or for legitimate legal purposes.
d. Right to Restrict Processing: You have the right to request that we limit how we use your personal information while we verify your request or assess your objection.
e. Right to Data Portability: You have the right to receive your personal information in a portable, machine-readable format (such as CSV) and to transmit that information to another organization without hindrance.
f. Right to Object: You have the right to object to certain types of processing, including processing for direct marketing purposes.
g. Right to Withdraw Consent: You have the right to withdraw consent to processing at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
h. Right to Lodge a Complaint: You have the right to lodge a complaint with the applicable data protection authority in your jurisdiction if you believe we have violated your privacy rights.
4.1.2. To exercise your GDPR Rights, submit a written request to support@flipperlog.com with the subject line "GDPR Data Subject Request" and specify which right you wish to exercise. Include sufficient information to identify you and your account. We will respond to your request within thirty (30) calendar days. If we are unable to respond within this timeframe, we will notify you and explain the reasons for the delay.
4.2. Rights for California Residents (CCPA and CPRA)
4.2.1. If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with the following rights:
a. Right to Know: You have the right to request what personal information we collect, use, share, or sell about you, including the categories of information, the purpose for collection, and the sources of the information.
b. Right to Delete: You have the right to request deletion of personal information we have collected about you, subject to certain legal exceptions. You may direct us to delete information you have provided, but we may retain information required for legal compliance or operational purposes.
c. Right to Opt-Out: You have the right to opt out of any sale or sharing of your personal information. While FlipperLog does not currently sell personal information, we will honor opt-out requests if we ever engage in such practices.
d. Right to Non-Discrimination: You have the right to receive equal service and pricing even if you exercise your privacy rights. We will not discriminate against you for exercising your CCPA/CPRA rights.
e. Right to Access: You have the right to access your personal information and receive it in a portable format.
f. Right to Correct: You have the right to request correction of inaccurate personal information.
g. Right to Limit Use: You have the right to limit our use of sensitive personal information to what is necessary to provide the Service.
4.2.2. To exercise your California Consumer Privacy Rights, submit a request via email to support@flipperlog.com or through account settings if available. Include your name, email address associated with your account, and a clear description of your request. We will verify your identity before fulfilling your request. We will respond to verifiable requests within forty-five (45) calendar days. We will not charge a fee for your request unless it is excessive or unfounded.
4.2.3. FlipperLog has appointed an authorized agent to receive and respond to California consumer privacy requests. You may submit requests through our authorized agent if you prefer. Please reach out to us at support@flipperlog.com for further details.
4.3. Rights for Canadian Residents (PIPEDA)
4.3.1. If you are a Canadian resident, the Personal Information Protection and Electronic Documents Act (PIPEDA) provides you with the following rights:
a. Right to Access: You have the right to request access to your personal information that we hold. We will provide you with a copy of your information, including how we collected it and how we use it.
b. Right to Correction: You have the right to request correction of personal information about you that is inaccurate, incomplete, or outdated. We will make corrections or will add a notation to your file indicating your disagreement with the accuracy of the information.
c. Right to Withdraw Consent: You have the right to withdraw consent to collection, use, or disclosure of your personal information at any time. Withdrawal of consent does not affect the lawfulness of processing before withdrawal, but it may mean we cannot continue to provide certain aspects of the Service.
d. Right to Challenge Compliance: You have the right to challenge our compliance with PIPEDA principles and to file a complaint with the Privacy Commissioner of Canada if you believe we have violated your privacy rights.
4.3.2. To exercise your PIPEDA Rights, contact support@flipperlog.com with your request for access, correction, or to lodge a complaint. Provide sufficient information to identify you and your account. We will respond to your request within thirty (30) calendar days, or within the timeframe required by applicable provincial privacy laws.
4.4. General Privacy Rights for All Users
4.4.1. Regardless of your location, you have the right to:
a. Update Your Account Information: You may access, view, update, and correct your account information at any time by logging into your account and modifying your profile settings.
b. Opt Out of Marketing Communications: You may opt out of promotional emails and marketing communications by clicking the unsubscribe link in any email we send or by updating your notification preferences in your account settings.
c. Access Your Data: You may request a copy of your personal information at any time by contacting support@flipperlog.com.
d. Request Data Deletion: You may request deletion of your account and associated personal information. Please note that we may retain certain information as required by law or for legitimate business purposes.
5. SECURITY OF YOUR INFORMATION
5.1. Security Measures
FlipperLog takes the security of your personal information very seriously and implements comprehensive technical, organizational, and physical measures to protect your information against unauthorized access, alteration, disclosure, and destruction.
5.1.1. Encryption in Transit: Data transmitted between your device and our servers is encrypted using industry-standard security protocols (SSL/TLS). This encryption protects your information from unauthorized access during transmission.
5.1.2. Encryption at Rest: Sensitive personal information stored on our servers is encrypted using industry-standard encryption algorithms. This protects your information even if our servers are compromised.
5.1.3. Access Controls: We implement strict access controls limiting access to personal information to authorized FlipperLog employees, contractors, and service providers who have a legitimate need to access the information for their job functions.
5.1.4. Authentication: We require strong authentication for access to systems containing personal information, including passwords and multi-factor authentication where appropriate.
5.1.5. Firewalls: We use firewalls and intrusion detection systems to monitor and prevent unauthorized access to our systems.
5.1.6. Security Assessments: We conduct regular security assessments, vulnerability testing, and penetration testing to identify and address security weaknesses.
5.1.7. Employee Training: All FlipperLog employees with access to personal information receive training on privacy, confidentiality, and security obligations.
5.1.8. Incident Response Plan: We maintain an incident response plan to address potential security breaches quickly and to notify affected users as required by law.
5.2. Limitation of Security Assurances
5.2.1. While we employ industry-standard security measures, we cannot guarantee absolute security. The Internet and electronic communications are inherently subject to risks, including unauthorized access, data interception, and security breaches by sophisticated attackers. Despite our efforts, no method of transmission or storage is completely secure.
5.2.2. You acknowledge that there is an inherent risk of unauthorized access despite our security measures. You assume responsibility for the confidentiality of your login credentials and for any unauthorized access to your account that results from your failure to protect your password.
5.2.3. We are not responsible for security breaches resulting from factors outside our reasonable control, including user error, third-party attacks, or compromised user devices.
6. DATA RETENTION
6.1. Active Account Data
6.1.1. While your account is active, we retain all personal information and User Data necessary to provide the Service, generate reports, and maintain account functionality.
6.2. Post-Termination Data Retention
6.2.1. Upon cancellation or termination of your account:
a. Grace Period: We retain your personal information and User Data for a grace period of thirty (30) calendar days following account cancellation. This retention period allows you to recover your account if you change your mind or to export your data before final deletion.
b. Permanent Deletion: After the thirty (30) day grace period expires, your personal information and all associated User Data will be permanently and securely deleted from our systems using data destruction protocols that prevent recovery.
6.2.2. Exceptions: We may retain personal information for longer periods when:
a. Retention is required by applicable laws or regulations
b. We have a legitimate legal purpose, including defending against legal claims
c. Retention is necessary for fraud prevention, security, or abuse prevention
d. You have not exercised your right to deletion
6.3. Legal Holds
6.3.1. If we receive a legal hold, court order, or governmental request requiring preservation of information, we will retain personal information beyond our normal retention periods to comply with the legal obligation.
7. COOKIES AND TRACKING TECHNOLOGIES
7.1. What Are Cookies?
7.1.1. Cookies are small text files stored on your device (computer, tablet, smartphone) that contain information about your interactions with the Service. When you visit FlipperLog, the cookie is stored on your device and provides information to FlipperLog when you return.
7.2. Types of Cookies We Use
7.2.1. Essential Cookies: These cookies are necessary for the basic functioning of the Service. They enable authentication, security verification, session management, and core functionality. The Service will not function properly without essential cookies.
7.2.2. Analytics Cookies: These cookies help us understand how users interact with the Service, including which pages are visited most frequently, how long users spend on different pages, and where users navigate. This information helps us improve the Service.
7.2.3. Preference Cookies: These cookies store your settings and preferences, including your language preference, currency selection, and interface customizations. Preference cookies allow us to remember your choices so you don't have to set them every time you visit.
7.2.4. Security Cookies: These cookies help us protect against fraud and security threats by detecting suspicious activity and unauthorized access attempts.
7.3. Cookie Consent and Control
7.3.1. At this time, we do not implement a cookie consent banner or preference center because we believe all cookies we use are necessary for the functioning of the Service or provide a clear benefit to users. We may implement a formal cookie consent mechanism in future updates if we add non-essential cookies.
7.3.2. Most web browsers allow you to control cookie settings through your browser preferences. You may:
a. Disable all cookies or only accept certain types of cookies.
b. Clear cookies stored on your device.
c. Configure which websites can and cannot set cookies.
7.3.3. Please note that disabling cookies may limit your ability to use certain features of the Service. Some functionality may not work properly or at all without cookies.
7.4. Third-Party Cookies
7.4.1. We work with third-party analytics providers that may set their own cookies on your device. These third parties have their own privacy policies and cookie practices. You can learn more about third-party cookies and control them through websites such as allaboutcookies.org.
8. THIRD-PARTY LINKS AND EXTERNAL CONTENT
8.1. FlipperLog may contain links to third-party websites, applications, and services that are not operated by us. This Policy applies only to FlipperLog and does not cover third-party websites, applications, or services.
8.2. We are not responsible for the privacy practices of third-party websites or applications. We encourage you to review the privacy policies of any third-party services before providing your personal information or using their services.
8.3. When you access third-party services through links from FlipperLog, you are subject to their privacy policies and terms of service, not ours.
9. CHILDREN'S PRIVACY
9.1. FlipperLog is intended for users who are at least thirteen (13) years of age or the age of digital consent in their jurisdiction, whichever is greater. We do not knowingly collect personal information from children under thirteen (13), or the applicable age of digital consent.
9.2. If we become aware that we have collected personal information from a child under thirteen (13) years, we will delete that information and terminate the child's account immediately.
9.3. If you are a parent or guardian and believe we have collected information from your child, please contact support@flipperlog.com immediately.
10. INTERNATIONAL DATA TRANSFERS
10.1. FlipperLog is operated from Canada and stores data on servers located in North America. If you are accessing the Service from outside Canada, you consent to your personal information being transferred to, stored in, and processed in Canada and the United States.
10.2. Countries outside Canada and the European Union may not provide the same level of data protection as your home country. By using FlipperLog, you acknowledge this and consent to the transfer of your personal information to jurisdictions with potentially different data protection standards.
10.3. For EU residents, we have implemented mechanisms to comply with GDPR requirements for international data transfers, including Standard Contractual Clauses and other lawful transfer mechanisms.
11. CHANGES TO THIS POLICY
11.1. FlipperLog may modify, update, or amend this Policy at any time. When we make material changes to this Policy, we will notify you by:
11.1.1. Sending an email to the address associated with your account;
11.1.2. Posting a prominent notice on the our website or within the Service; or
11.1.3. Requiring you to accept the updated Policy before continuing to use the Service.
11.2. Material changes will take effect either immediately upon posting or thirty (30) calendar days after notification, as appropriate. Your continued use of the Service following the effective date of any changes constitutes your acceptance of the modified Policy.
11.3. We encourage you to review this Policy periodically to stay informed about how we protect your privacy.
12. PRIVACY COMPLAINT PROCEDURE
12.1. If you believe FlipperLog has violated your privacy rights or this Policy, you may file a formal complaint:
12.1.1. Internal Complaint: First, contact support@flipperlog.com and describe your complaint in reasonable detail. We will investigate and attempt to resolve your complaint informally.
12.1.2. Regulatory Complaint: If internal resolution is unsatisfactory, you may file a complaint with the applicable privacy regulator in your jurisdiction:
a. Canada: Privacy Commissioner of Canada (https://www.priv.gc.ca/)
b. European Union: Your local data protection authority
c. California: California Attorney General (https://oag.ca.gov/)
13. CONTACT US
13.1. If you have questions about this Policy, our privacy practices, your personal information, or your privacy rights, please contact our Privacy Officer:
13.1.1. Email: support@flipperlog.com
13.1.2. Company: 2743499 Alberta Inc. (DBA Lotpoint)
13.1.3. Jurisdiction: Alberta, Canada
13.2. We will endeavor to respond to inquiries within forty-eight (48) business hours where practicable.
14. ACKNOWLEDGMENT
14.1. By accessing and using FlipperLog, you acknowledge that you have read, understood, and agree to this Privacy Policy. You further acknowledge that you understand how we collect, use, and protect your personal information.
14.2. If you do not agree with this Policy, you should not use FlipperLog.