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Privacy Policy

Last Updated: July 26, 2025

Welcome

Welcome to Fleur (the "App" or "Fleur") and all of its associated websites and its associated content, products and services are owned and operated by IP Reznik Yuliya ("us", "we" or "our"). At Fleur, your privacy is of the utmost importance to us. To provide our users with the highest levels of data protection, as well as assurance that we will not misuse your information, Fleur is compliant with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) as stated below and the California Privacy Rights Act ("CPRA").

This Privacy Policy (also "Policy") governs the use of Fleur, the Fleur Website and your use of any of our Services provided through the same. When using or accessing the Website and the Services, you are agreeing to be bound by the terms of this Privacy Policy and our Terms of Use policy. This policy may refer to users as "you" or "user" and may refer to Fleur as "us," "we," or "our." If you do not agree to the terms within this Privacy Policy and the corresponding Terms of Use, do not access or use Fleur, the Website or the Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with the terms of this Privacy Policy, please do not use Fleur or our Website and the Services. By accessing or using the Website, the App and Services, you agree to this privacy policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website, the App and the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

A small note on how AI Videos feature works:

We do our best to moderate the settings of the AI model, however, it is still possible that you may encounter content that you may see as inappropriate for you. We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively. By Using Fleur, you understand and agree that we are providing you with tools for editing and adjusting photos and videos that you upload, and, if you so request, for generating or creating new content from them, for example with our AI Videos feature. If you have any questions about this Privacy Policy or Fleur, please contact us at contact@fleurlab.ai(for additional contact information, please, see Section "Contact Information" of this Privacy Policy).

Information collected and stored by Fleur

In order to carry out the Services of Fleur and to provide a great user experience, we will collect and store the following information about you:

Personal Information, that may be used to identify you as an individual

(Personal information is any information related to an identified or identifiable natural person).

Other information that may be linked to personal information

How we collect your personal information

Fleur collects personal information from you upon your registration for our Services and upon your log-in to or accessing of Fleur, our Website or Services. We collect any additional information about you when you interact with us electronically or in person, when you access Fleur, or our Website and when we provide our Services to you. It may not be readily apparent to you when such data is being collected. For instance, when you visit our Website or download or use Fleur, your IP address is collected so that we know where to send information you are requesting. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

AI Videos: In order to generate AI Videos, you have to upload 1-6 photos to Fleur. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, using these data, a GPT-image-1 and Neural Network models available in the Fal.AI service we generate the AI Video. Your purchased Videos are stored on our servers so that they remain accessible to you in Fleur until you decide to delete them.

How we process your photos

With regard to your photos, most processing activities take place on your device, however there are exceptions to this rule when you generate AI videos. When you generate AI videos, the photos that you have uploaded to Fleur or those selected by Fleur from your camera roll/library are stored on our servers (provided by Amazon Web Services (USA)). Then, using these data, a GPT-image-1 and Neural Network models available in the Fal.AI service we generate the AI Video. Your purchased Avatars are stored on our servers so that they remain accessible to you in Fleur at any time and from any device until you decide to delete them. Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

Why we collect your personal information

We process your personal information because we have a contractual obligation with you. When you create an account to use Fleur (required for any paid subscriptions), or our Website and Services, and agree to our Terms of Service, a contract is formed between you and us. In order to carry out our contractual obligations we need to process the information you provide, which also includes personal information. Even if there is no direct contractual obligation between us, we may process your information based on your explicit consent you have provided (to us or a third-party data controller) for the processing of that information.

How we use your personal information. We will use the personal information collected from you:

Additionally, we may use anonymized information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of personal information

We will not disclose your personal information to any third parties and we do not share, sell, rent, or trade your personal information with third parties for their commercial purposes, however, we reserve the right to disclose information about you to third parties to third-parties for assistance in improving the Fleur products and Services. Additionally, we may disclose personal and non-personally identifiable information with third parties service providers, engaged by us to provide technical support, hosting Services, testing, network security or statistical Services, any such disclosure will be subject to confidentiality obligations.

Fleur may also disclose information about you to third-parties where we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Fleur, our affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Fleur employees, owners, or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

Fleur may use third-party payment processor including Stripe, Plaid or other credit card provider platforms for payment transactions. Wherever you designate a payment source for transaction processing with us through any platform, you are responsible for visiting, understanding and abiding by all terms of such platforms and such payment sources.

How long we keep your information

We will keep your personal information for as long as you use Fleur, our Website and our Services. You have the right to request that your personal information is permanently removed from our system and database at any time. We will accommodate such requests within 45 (forty-five) days or less. You can e-mail such requests for permanent removal to contact@fleurlab.ai.

Right to access and control your data

We provide you with many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts and communication controls. We will provide you with access to your personal information that we store and allow you to:

You may send us an e-mail at contact@fleurlab.ai to request any or all of the above.

Cookies and tracking technologies

We collect information about you using "cookies." Cookies are small data files stored on your hard drive by a Website. The cookies that we use are for authentication purposes (to facilitate your log-in) and session cookies (to recognize your preferences while navigating through the Website). Usually the information that we collect automatically through cookies is statistical data and cannot be used to identify you as an individual. It helps us to improve our App(s), Website and Services and to deliver a better and more personalized service. Additionally, there might be third party cookies used on our Website by third party advertisers, those cookies are not related to your profile, they cannot identify who you are and therefore are not linked to your personal data. When you first visit our Website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our Website or Services.

Security of your personal information

Fleur is committed to ensuring that the information you provide to us is secure from accidental loss and from unauthorized access, use, alteration and disclosure. We have implemented suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorized access, modification and disclosure.

The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our App, Website or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website or our Apps or platforms that support or make them available or usable, including chats or message boards. The information you share in public areas may be viewed by any user of the Website or our Apps or Services.

Commercial and non-commercial communication

By providing information to the Website or through our App(s) or Services, such as signing up for a newsletter or an account, you have agreed to receive e-mail communication from us. However, you may unsubscribe from certain communications by notifying Fleur that you no longer wish to receive solicitations or commercial information. Fleur will remove you from the database, where you have the right to request this under the Privacy Policy, Terms of Use, or applicable law, or where Fleur voluntarily decides to grant the request.

Children's online privacy protection act

The Fleur Website, App(s) and Services are directed to persons over the age of 13. Fleur does not knowingly collect information from children under 13 years of age or have any reasonable grounds for believing that persons under the age of 13 are accessing the Website, or our Services or App(s). If Fleur discovers any inadvertently collected Personal Information of a person under the age of 13, that information will be swiftly deleted from its' records. If you believe that Fleur may have any information from a person under age 13, please contact Fleur at: contact@fleurlab.ai.

Your California privacy rights

Fleur welcomes residents of the State of California to use its App(s), Website and Services, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Please send a written request to contact@fleurlab.ai.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time. If we change our Privacy Policy, we will notify you via email sent to the email address you provide at the time of registration as well as post an updated version of this Privacy Policy on our Website, App pages/platforms or where Services under our control are otherwise made available, so that you and other users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Changes will not apply retroactively and changes addressing new functions for a service or changes made for legal reasons will be effective immediately. If you do not agree to the modified terms, you should discontinue your use of the Website and our App(s) and Services. Your continued use of the after any such changes constitutes your acceptance of the new Privacy Policy. You should also check back from time to time to ensure you are aware of any changes. Under the CCPA and the CPRA we will be reviewing this Privacy Policy every 12 months.

Contact information

If you have any questions, comments, complaints or concerns regarding this Privacy Policy, you can contact us anytime through at the following email: contact@fleurlab.ai. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

Privacy notice for california residents under the California Consumer Privacy Act

Effective date: July 26, 2025. Last Reviewed: July 26, 2025. This Privacy Notice for California residents supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act (CPRA) and any terms defined in the CCPA have the same meaning when used in this notice.

1. Categories of Information We Collect

Our Website, App(s) and Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our Website, Services and App(s) have collected the following categories of personal information from its consumers within the last twelve (12) months:

2. Under this Privacy Policy, personal information does not include:

3. We obtain the categories of personal information listed above from the following categories of sources:

4. Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

5. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties:

However, we don't explicitly share any information with web service provider. Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, Fleur has not explicitly disclosed personal information for a business purpose. Sales of Personal Information in the preceding twelve (12) months — Fleur has not sold personal information in the preceding twelve (12) months.

6. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

1) Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

2) Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

3) Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, you need to submit a verifiable consumer request to us by sending us a message to our customer service at contact@fleurlab.ai. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

4) Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7. Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at: contact@fleurlab.ai. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting our Website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

8. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. California's "Shine the Light" law (Civil Code Section §1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us at: contact@fleurlab.ai.

United Kingdom (UK GDPR) Compliance

1. UK GDPR Compliance: If you are located in the United Kingdom, we comply with the United Kingdom General Data Protection Regulation (UK GDPR). You have the right to access, rectify, erase, restrict, or object to processing of your data and to data portability. To exercise these rights, contact us at contact@fleurlab.ai. 2. International Data Transfers – UK: We may transfer your data outside the UK to the US. These transfers are protected using Standard Contractual Clauses approved by the UK ICO or other legally approved mechanisms. 3. Direct Marketing Opt-Out: You have the right to opt out of receiving direct marketing communications from us at any time. You can do so by clicking "unsubscribe" in marketing emails or contacting us at contact@fleurlab.ai. 4. Right to Withdraw Consent: You have the right to withdraw your consent to the processing of your personal data at any time. This will not affect the lawfulness of processing based on consent before its withdrawal. 5. Legal Basis of Processing: We process your personal data based on one or more of the following legal grounds: (a) your consent; (b) performance of a contract; (c) compliance with a legal obligation; or (d) our legitimate interests, provided they do not override your fundamental rights and freedoms.

Australian Privacy Law Compliance

1. Cross-Border Disclosure: We may disclose personal data to third-party service providers in the US. These disclosures are for operations, transactions, or support. We take reasonable steps to ensure compliance with the Australian Privacy Principles. 2. Access and Correction Rights: You have the right to request access to or correction of your personal data if it is inaccurate or outdated. Contact: contact@fleurlab.ai. 3. De-identification Statement: If we use de-identified data for analytics or improvement, we ensure that such data cannot be re-identified or associated with any individual. 4. Data Retention and Disposal: We retain personal information only as long as necessary for the purpose for which it was collected. When no longer required, data is either securely destroyed or de-identified, in accordance with APP 11.2. 5. Privacy Complaints: If you believe we have breached your privacy rights, contact contact@fleurlab.ai. We will respond within 30 days.

Canadian (PIPEDA) Compliance. 1. PIPEDA Compliance: Your data is processed in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). You have the right to access, correct, withdraw consent, and file complaints with https://www.priv.gc.ca. 2. Data Storage and Consent: Your data may be stored on servers in the US. By using our services, you consent to this cross-border transfer. 3. Full Purposes of Data Use: We collect your personal data for account registration, customer support, AI photo generation, analytics, and service improvement. Each purpose is limited, transparent, and communicated prior to use, as required under PIPEDA. 4. Consent Mechanisms: We obtain your informed consent before processing your photos, videos information for AI features. You may withdraw consent at any time via the app or by emailing us. 5. Designated Privacy Officer: Fleur has designated a Privacy Officer responsible for ensuring our compliance with Canadian privacy laws. You may contact this officer at contact@fleurlab.ai.

Enhanced Cookie Consent

Enhanced Cookie Consent – UK/AUS/CA: When you visit our site, a cookie banner will inform you of cookie usage and allow you to accept or reject non-essential cookies. Essential cookies are necessary for functionality. Disabling them may limit access to some site features.

AI, Biometric & Facial Data Protection

1. No Use of Biometric Identifiers: We do not extract, store, or analyze biometric identifiers such as faceprints or fingerprints from your images or videos. 2. No Facial Recognition: We do not perform facial recognition or identification on uploaded images or avatars. 3. Right to Object to AI Processing: You may object to the processing of your personal data for AI video generation. In such cases, we will not proceed unless required to fulfill a contractual service or your explicit consent is provided. 4. AI Content Disclaimer: AI-generated outputs (such as avatars) are artistic renderings generated based on your uploaded images. These do not constitute real-life representations and should not be used for identity verification, medical, or legal purposes.

Refund Saver and Data Sharing with Apple

Sharing of Consumption Data for Refunds: If you request a refund for an in-app purchase through Apple's App Store, we may provide Apple with certain information regarding your usage of the app and the specific in-app purchase. This information may include:

This data is shared solely to help Apple make informed refund decisions and is handled in compliance with applicable privacy laws. By continuing to use our app, you consent to this data sharing for refund handling purposes. If you wish to opt out of this data sharing, please contact us at contact@fleurlab.ai.

European Privacy Policy Compliance Addendum

The following sections supplement our Privacy Policy to ensure compliance with European data protection regulations. These provisions apply to users located in Italy, Spain, France, Germany, and Switzerland.

European Representatives and Supervision

Fleur is committed to data protection compliance and has appointed the following representatives:

Data Protection Officer (DPO)

Our Data Protection Officer can be contacted at:

Enhanced Data Protection Rights

In addition to the rights outlined in our main Privacy Policy, users in these countries have the following enhanced rights:

Right to Data Portability

You have the right to:

Right to Restrict Processing

You may request restriction of processing when:

Right to Object

You may object to:

Age Requirements and Parental Consent

We have specific age requirements for different countries:

For users below these ages, we require verifiable parental consent before processing personal data.

Cookie Management and Consent

Cookie Categories

1. Essential Cookies (No Consent Required)

2. Functional Cookies (Consent Required)

3. Analytics Cookies (Consent Required)

4. Marketing Cookies (Explicit Consent Required)

Cookie Controls

Data Retention Periods

We retain your data for the following periods:

1. Account Data

2. Usage Data

3. Communication Records

4. AI-Generated Content

Updates and Changes

We will notify you of any material changes to this Privacy Policy:

Contact for Privacy Matters

For privacy-related inquiries:

For urgent matters or data breaches:

This addendum forms an integral part of our Privacy Policy and should be read in conjunction with it.