Privacy Policy

Effective Date: May 2026 · Last Updated: May 2026

1. Introduction and Scope

Flecks, Inc. (“Flecks,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the Personal Data we collect. This Privacy Policy describes how we collect, use, and share Personal Data that we collect directly from individuals when you visit our website, register for an account, or communicate with us.

Important Note Regarding Platform Data: This Privacy Policy does not apply to data that is uploaded, transmitted, or processed through the Flecks Platform on behalf of our corporate customers (“Customer Data”). The Processing of Personal Data by Flecks on behalf of a Customer is governed by the Flecks Data Protection Agreement (DPA), available at flecks.ai/dpa, and incorporated into our Customer Terms and Conditions or other master agreement with that Customer. Additional detail regarding Flecks’ technical and organizational security measures is available in the Flecks Security Practices document at flecks.ai/security. If you are an end-user of a Flecks Customer (for example, an employee whose endpoint is monitored by a Flecks-powered security program), please direct privacy inquiries to your organization’s administrator.

2. Information We Collect

We collect information that identifies, relates to, describes, or is reasonably capable of being associated with you (“Personal Data”) in the following ways:

A. Information You Provide Directly

  • Account Registration: When you sign up for Flecks, we collect contact details such as your name, email address, job title, company name, and phone number.
  • Billing Information: If you purchase a subscription, we (or our third-party payment processors) collect payment information, billing addresses, and tax identifiers.
  • Communications: Information you provide when you contact our support team, schedule a demo, or sign up for newsletters.

B. Information Collected Automatically

When you interact with our website or Platform portal, we may automatically collect:

  • Device Data: IP address, browser type, operating system version, and unique device identifiers.
  • Usage Data: Pages viewed, features used, clickstream data, and login history.
  • Cookies: We use cookies and similar technologies to authenticate users, remember preferences, and analyze traffic.

C. Exclusion of Sensitive Data

Per our Customer Terms and Conditions, the Flecks Platform is not designed to store Sensitive Data, and customers agree not to knowingly transmit Sensitive Data to the Platform. We do not knowingly collect Sensitive Data through our website or services. “Sensitive Data” includes government-issued identifiers (e.g., SSNs), biometric data, health information (PHI), payment cardholder data, and data revealing racial or ethnic origin, political opinions, or religious beliefs.

3. How We Use Your Information

We use the Personal Data we collect directly from you for the following business purposes:

  • Service Provision: To create and manage your account, process transactions, and authenticate your identity.
  • Communication: To send administrative information (e.g., invoices, security alerts, changes to terms) and respond to customer support requests.
  • Marketing: To send promotional materials regarding Flecks features or services, subject to your opt-out rights.
  • Security and Compliance: To detect fraud, secure our infrastructure, and comply with legal obligations.
  • Improvement: To analyze usage trends and improve the functionality of our website and services.

4. How We Share Information

We do not sell your Personal Data. We may disclose your information in the following circumstances:

  • Service Providers: We share data with trusted third-party vendors who perform services on our behalf (e.g., cloud hosting, payment processing, CRM management). Our sub-processors for Platform data are listed in the DPA Annex III.
  • Legal Compliance: We may disclose information if required by law, regulation, or valid legal process (e.g., a subpoena or court order). Where legally permitted, we will notify you of such requests before responding.
  • Business Transfers: If Flecks is involved in a merger, acquisition, or sale of assets, your Personal Data may be transferred as part of that transaction, subject to the same protections described in this Privacy Policy.
  • Aggregated Data: We may use and share Aggregated Data (data that has been de-identified such that individuals are no longer identifiable) for any purpose, including product improvement and benchmarking. We will not attempt to re-identify Aggregated Data.

5. Data Retention and Security

We retain Personal Data only as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements. For Customer Data retained after contract termination, the DPA governs retention and deletion obligations.

We implement technical and organizational security measures designed to protect your data from unauthorized access or disclosure, as further described in the Flecks Security Practices document available at flecks.ai/security. However, no internet transmission is 100% secure.

6. Your Rights

Depending on your jurisdiction (e.g., GDPR, UK GDPR, CCPA), you may have the right to:

  • Access: Request copies of the Personal Data we hold about you.
  • Correction: Request correction of inaccurate data.
  • Deletion: Request deletion of your Personal Data (subject to legal exceptions).
  • Portability: Request a copy of your data in a structured, machine-readable format (where applicable).
  • Opt-Out: Unsubscribe from marketing communications via the link provided in our emails.

To exercise these rights, please contact us at privacy@flecks.ai. If you are an end-user of a Flecks Customer and believe your data is processed through the Platform, please direct your request to the Customer (your employer or service provider) in the first instance.

7. International Transfers

Flecks, Inc. is headquartered in the United States. If you are accessing our website or services from outside the United States, please be aware that information you provide may be transferred to, stored, and processed in the United States and other countries where our service providers operate.

For Customer Data processed through the Platform, Flecks uses Standard Contractual Clauses (SCCs) and other approved transfer mechanisms as described in the DPA to transfer Personal Data from the European Economic Area, United Kingdom, and Switzerland to the United States and other jurisdictions. Customers may configure their data storage region at Platform setup, with all AWS commercial regions supported.

8. Cookies

Our website uses cookies and similar tracking technologies to analyze website traffic and improve user experience. You can control cookie preferences through your browser settings or, where required by law, through our cookie consent mechanism. Note that disabling cookies may affect certain website functionality.

9. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated Privacy Policy on our website and updating the “Last Updated” date above. Where required by law, we will obtain your consent before making material changes.

10. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Flecks, Inc.
6400 S. Fiddler’s Green Cir., Suite 300, Greenwood Village, CO 80111
privacy@flecks.ai