Privacy Policy

Floga – Privacy Policy

Last updated: January 2026

This Privacy Policy explains how Strumpi LTD (“we,” “us,” or “our”) collects, uses, shares, and protects personal data when you use the Floga mobile application, website, and related services (collectively, the “Services”).

We are committed to protecting your privacy and processing personal data in accordance with applicable data protection laws, including the UK GDPR and EU GDPR where applicable.

1. Who We Are

Data Controller: Strumpi LTD
80–82 White Lion Street
London, N1 9PF
United Kingdom
Email: info@playpausebe.com

2. Information We Collect

We may collect the following categories of personal data:

2.1 Information You Provide

  • Account information (such as name, email address, login credentials);

  • Subscription and purchase information (processed via third-party payment providers);

  • Communications with us (support requests, emails, feedback);

  • Content you create or upload within the app.

2.2 Information Collected Automatically

  • Device and app information (device type, operating system, app version);

  • Usage data (features used, sessions, interactions);

  • Log data, IP address, and approximate location;

  • Cookies or similar technologies on our website.

2.3 Information Related to Challenges, Sharing, and Referrals

When you participate in challenges or use sharing and referral features, we may collect additional information, including:

  • Your user identifier and referral link or code;

  • Information confirming whether invited users completed account registration;

  • Referral counts and milestone data (for example, unlocking rewards at predefined thresholds);

  • Technical metadata associated with referrals (timestamps, referral source, device identifiers);

  • Fraud-prevention and validation signals.

We do not require you to upload your contacts. Any invitations are initiated by you through your chosen communication channels.

3. How We Use Your Information

We use personal data to:

  • Provide and operate the Services;

  • Create and manage user accounts;

  • Process subscriptions and payments;

  • Deliver app features, content, and challenges;

  • Track participation in challenges and referral programs;

  • Attribute rewards, prizes, or bonus gifts;

  • Detect and prevent fraud, abuse, or misuse of the Services;

  • Communicate with you about updates, features, or support requests;

  • Improve and optimise the Services;

  • Comply with legal obligations.

4. Legal Bases for Processing

Depending on your location and applicable law, we process personal data on one or more of the following legal bases:

  • Performance of a contract (to provide the Services you request);

  • Consent, where required (for example, certain communications);

  • Legitimate interests, such as operating challenges, referral programs, analytics, and fraud prevention;

  • Legal obligations, where processing is required by law.

5. Sharing of Information

We may share personal data with:

  • Service providers who support app hosting, analytics, customer support, referral tracking, and communications;

  • Payment processors who handle transactions on our behalf;

  • Legal or regulatory authorities when required by law.

We do not sell personal data.

All third-party service providers are required to process data in accordance with applicable data protection laws.

6. Challenges, Referrals, and Incentives

Personal data related to challenges and referral programs is used solely to:

  • Track participation and progress;

  • Verify referral milestones and eligibility for rewards;

  • Prevent abuse, fraud, or manipulation of incentives;

  • Administer prizes and bonus gifts.

Referral-related data is retained only as long as necessary to operate the program, resolve disputes, and comply with legal obligations.

7. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence. Where such transfers occur, we ensure appropriate safeguards are in place, such as standard contractual clauses or equivalent protections.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including legal, accounting, or reporting requirements.

Retention periods may vary depending on the type of data and the purpose for which it is processed.

9. Your Rights

Depending on your location, you may have the right to:

  • Access your personal data;

  • Correct inaccurate or incomplete data;

  • Request deletion of your data;

  • Restrict or object to processing;

  • Request data portability;

  • Withdraw consent at any time, where consent is the legal basis;

  • Lodge a complaint with a supervisory authority.

Requests can be made by contacting us at info@playpausebe.com.

10. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. However, no system is completely secure.

11. Children’s Privacy

The Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Services or other appropriate channels. Continued use of the Services constitutes acceptance of the updated Privacy Policy.

13. Contact Us

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

Strumpi LTD
Email: info@playpausebe.com