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December 21, 2020

FLES Privacy Policy

We believe that transparency is the key to any healthy relationship. We appreciate that you are trusting us with information that is important to you, and we want to be transparent about how we use it.

Here we describe the privacy practices for FLES. You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe. Here are some key factors:

  • We may anonymize, de-identify     and/or aggregate the information that we collect and use such anonymized,     de-identified and/or aggregated data for commercial, statistical and     market research purposes, including sharing it with affiliates and     business partners.
  • You own your personal data, and     you’re always in control. Therefore we offer you several ways to control     the privacy of your personal information and we’re constantly striving to     improve the functions and features needed in order for you to be feel that     you’re in control.

Our privacy policy (the “Privacy Policy”) is here to give you all the information you need about what kind of information we collect, how we use, how we share it, how you control your data, and make sure you know your rights in connection to when you use our applications, software, websites, APIs and services (collectively,“FLES”).

When it comes to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with in or through FLES, this Privacy Policy does not apply to them, unless indicated otherwise.

ThisPrivacy Policy establishes a legal agreement between you, as the user of FLES.Throughout this Privacy Policy we will refer to you as “you”, and we will refer to FLES (as the developer behind FLES) as “we”, “us” or “FLES”.

If you have any questions, or feel you need any part of this document explained, please email us so we can assist you at team@fles.io


Processing of your information

FLES relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this PrivacyPolicy, including:

  • Where you have agreed to the     processing. For example, if you have entered your email upon registering     to our online backup service. Please note you can revoke this at any time.
  • To fulfill the contract of service     between FLES and you as a user of the application FLES.
  • Where necessary to comply with     legal obligation, a court order, or to exercise and defend legal claims.
  • Where you have made the     information available public.

Why we do this is, first and foremost, in order to provide and improve FLES services. In addition, it is also to enable us developing tailored offers to you as a user on a continuous basis. As well as, in order to keep FLES safe andsecure, protecting it against fraud, spam and abuse etc.

Information we collect

When you interact with our services, we collect information that, alone or in combination with other information, could be used to identify you. When you sign up for or use the Services, you voluntarily give us certain Personal Data, such as your email address. If you register for an account through your social media account (including Kakao and Google Sign-in), you may see which of your friends are using the Services. The information we get from these accounts depends on your settings and the privacy policies of the social media platforms, so please check those policies to understand the privacy practices of those platforms.

Account information

Some information is required to create an account on our Services, such as your email address and password. This is the only information you have to provide to create an account with us. We may also use your location in order to give you insights about how weather affects your water drinking.

How we use information


Using the information we collect, we are able to deliver the Services to you and honor our contract with you. For example, we may need to use your information to provide you with our online backup services, or to enable the community features of the Services; and to give you customer support.


We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys, and develop new features and Services.

Sharing content in FLES

TheServices may enable you to post content to social networking sites (“SNSs”,e.g., Facebook). If you choose to do this, we will provide information to suchSNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

Information from third-party services

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friend list. You may also choose to grant us access to your activity data from another service. You can stop sharing the information from the other service with us by removing our access to that other service. This information is collected by the Third-PartyAccount provider and is provided to FLES under their privacy policies.

Contact information

Shouldyou reach out to us via email to get help or ask a question we will respond tothe contact information that you provide. The contact information will be usedexplicitly to communicate with you based on your request/question. We may alsofollow up and ask for feedback about how we can improve our customer servicespreceding a closure of your ticket.

Use across our services

Someof our products can be used together using a linked account so that you’re ableto share information between our products. The purpose of doing so is todeliver even greater insights to you as you’re using our services. You cancontrol this to your own preference in our apps.


Whenyou access FLES, we collect technical information from the devices you use. Theinformation we collect includes IP addresses, timestamps, log files, devicetype and operating system. We use the information we collect to improve andpersonalize the Services and to develop new ones. For example, we use theinformation to troubleshoot and protect against errors; perform data analysisand testing; conduct research and surveys; and develop new features andServices.

How We Use Information

Weuse the information we collect for the following purposes:


Usingthe information we collect, we are able to deliver the Services to you andhonor our contract with you. For example, we need to use your information toprovide you with your online backup services; and to give you customer support.

Whenyou allow us to collect location information, we use that information toprovide and improve features of the Services.

FLESuses the information we collect to operate and improve FLES as otherwisedescribed in this Privacy Policy. For example, we may use your water drinkinginformation to provide you with “big data” statistics and key data points suchas average water drinking time in certain countries. At this point the datawill be aggregated and de-identified from any personal data.  


Inaddition, in order to analyze and improve our services, we sometimes use thirdparty providers to analyze and gain insight. The insights we look at aregenerally how FLES is used, in order to help us improve.  


Weuse your information when needed to send you Service notifications and respondto you when you contact us. If you have agreed to receiving emails from us, wemay use your email address to send you service and marketing related notices.If you want, you can unsubscribe to all our email at any point. The informationabout how you unsubscribe is always presented in the email you’ve received. Inorder to inform you on updates to our Privacy Policy or Terms of Use, we mayalso use your email address.

Sharing of information

Wemay share non-personal information that is aggregated or de-identified so thatit cannot reasonably be used to identify an individual. We may disclose suchinformation publicly and to third parties, for example, in public reports aboutwater drinking and activity, to partners under agreement with us, or as part ofthe community benchmarking information we provide to users of our subscriptionservices.

Onlyinformation needed to perform these specific actions will be shared withthird-party services, nothing more. We will never share more information thannecessary.

Service  and Hosting Providers

FLESmay share your personally identifiable information with third parties (likehosting and market analytics) for the purpose of providing services to you. Ifwe do this, such third parties’ use of your information will be bound byrestrictions consistent with this Privacy Policy. We may store personalinformation in locations outside the direct control of FLES (for instance, onservers or databases co-located with hosting providers).

Publicly available Information

ThisPrivacy Policy shall not apply to any information you post to the public areasof the Services. Comments posted to public areas may be viewed, accessed, andused by third parties subject to those parties’ privacy practices and policies.

Legal requirements

Wemay preserve or disclose information about you to comply with a law,regulation, legal process, or governmental request; to assert legal rights ordefend against legal claims; or to prevent, detect, or investigate illegalactivity, fraud, abuse, violations of our terms, or threats to the security ofthe Services or the physical safety of any person.

Ifwe are involved in a merger, acquisition, financing due diligence,reorganization, bankruptcy, receivership, sale of all or a portion of ourassets, or transition of a service to another provider, your Personal Data andother information may be transferred to a successor or affiliate as part of thattransaction. But all of this will be managed in correspondence to this privacypolicy.

Information Security

Pursuantto applicable Data Privacy laws and regulation, FLES maintains a reasonabletechnical and organizational measures to protect information against accidentalor unlawful destructions, or loss, alteration, unauthorized disclosure oraccess.

Wework hard to keep your data safe. We use a combination of technical,administrative, and physical controls to maintain the security of your data. Thisincludes using Transport Layer Security (“TLS”) to encrypt our Services.

Your Rights

Youcan at any time contact our support at team@fles.io to get your personal data deleted.You may also export your personal data to a CSV file either from inside the appor through our web service. If you are not a subscriber to our online backupservices you can simply just uninstall the app in order to remove any storeddata. If you need any further assistance regarding your rights, feel free tocontact us at team@fles.io

Notifications and Email Preferences

Itis our policy to provide notifications, whether such notifications are requiredby law or are for marketing or other business related purposes, to you viaemail notice. If you inform us that you wish to cancel email newsletters orpromotional materials by selecting unsubscribe at the bottom of suchcommunication or by emailing us at team@fles.io, we will remove you from our mailing list.If you no longer wish to receive push notifications, you may turn them off atthe device level. Administrative or service-related emails (to confirm apurchase, updates to Privacy Policy, etc.) generally do not offer an option tounsubscribe as they are necessary to provide the services you requested.

Youcan stop receiving certain notifications by disabling notifications for FLES ondevice level. You may also unsubscribe by following the clear instructionscontained at the bottom of each email. Administrative or service-related emails(to confirm a purchase, updates to Privacy Policy, etc.) generally do not offeran option to unsubscribe as they are necessary to provide the services yourequested.

Managingyour personal data

Ifyou do not have an account, no personal information whatsoever willbe stored outside the device you use. But if you create an account and log in,the information will be backed up and you can access your information acrossdevices.

Deleting Your data

Youcan delete specific recorded activities, for example water drinking sessions orcomments posted by yourself.

Torequest the deletion of your personal data that we have, please email usat team@fles.io

Ifyou choose to delete your account, please note that while most of yourinformation will be deleted within a few days, it may take up to 30 days todelete all of your information, like the data stored in our backup systems. Wemay also preserve data for legal reasons or to prevent harm.

Objecting to Data Use

Ifyou have a FLES account, you can still prohibit FLES from uploading your datato our servers by disabling the Online Backup feature in FLES.

Ifyou have participated in the anonymous global Water drinking Survey you may, atany time, stop participating by disabling the “Participate in survey” optionunder the Settings -> Advanced -> Profile menu in FLES.

Usersof iOS 8+ have the ability to share data from Apple Health with our Service.You have control over what data is stored and accessed between Apple Health andour Service and can modify these settings at any time via Apple Health.

Data Retention

Wekeep your account information, such as your email address, and password, for aslong as your account is in existence because we need it to operate youraccount. We keep other information, like your activity data, until you use yourtools to delete the data or contact us for a full erasure, because we use thisdata to provide you with your personal statistics and other aspects of theServices. We also keep information about you and your use of the Services foras long as necessary for our legitimate business interests, for legal reasons,and to prevent harm. If you wish to cancel your account or request that we nolonger use your personal information to provide you the Service, you may deleteyour account by sending a request to delete your account to support@waterdrinkingcycle.com. We may also delete your account if it has been inactive fora certain amount of time. Preceding the delete request it may take up to 30days to fully delete your personal information from our systems.

Informationabout you that is no longer necessary and relevant to provide our services maybe de-identified and aggregated with other non-personal data to provideinsights, such as statistics of the use of FLES.

Our Policies for Children

We appreciate the importance of taking additional measures to protect children’sprivacy.

FLESdoes not knowingly collect Personal Data from children under the age of 16. Ifyou have reason to believe that a child under the age of 16 has providedPersonal Data to FLES through the Services please contact us and we willendeavour to delete that information from our databases.

Changes to this privacy policy

FLESreserves the right to change this Privacy Policy from time to time. We willinform you of any changes by posting the updated Privacy Policy through themobile applications. If we make any material changes to our Privacy Policy, wewill post a notification through the mobile applications and/or by asking youto review the changes to the Privacy Policy the next time you access theServices. Your continued use of the Services after the changes are made willindicate your consent to our use of your information consistent with thisPrivacy Policy, including those changes.

Personal Data Controller

The company responsible for the processing of your personal data is:








7, Teheran-ro 5-gil, Gangnam-gu


South Korea




This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls.

This policy was last modified on Dec 20, 2020


Vlad Magdalin

Passionate reader | People person | The one behind All dad jokes
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