FlipMole Privacy Policy

Version 1.0 (draft) · Effective [EFFECTIVE DATE] · Last updated November 7, 2026

This policy explains how [COMPANY LEGAL NAME] ("FlipMole", "we") collects, uses, shares and protects personal information when you use the FlipMole website, web app and related services (the "Service"), and the choices and rights you have. It's written to match how the Service actually works today; where something depends on a decision we haven't made yet, it's marked in brackets.

1. Who we are and how to reach us

Controller / organization responsible: [COMPANY LEGAL NAME], [REGISTERED ADDRESS]. Privacy officer (person in charge of the protection of personal information): [NAME, TITLE], [PRIVACY EMAIL]. FlipMole is offered only in Canada and the United States, and this policy is written for people there.

2. The information we collect

2.1 Account information (from you): email address; optional display name; your password, stored only as a salted one-way hash; whether and when you confirmed your email and accepted our Terms (with the version); your plan; and, if you sign in with Google or Apple, the account identifier that provider gives us and the email and name it shares (with Apple you may share a private relay email instead).

2.2 Payment and subscription information: payments are processed by Stripe, which collects your card details directly; we never receive or store your full card number or security code. Stripe gives us: a customer identifier, a payment-method identifier, the card brand, last four digits and expiry date, a fingerprint of the card that we store only in hashed form (to stop one card claiming multiple free allowances), and your billing country and address where needed for tax. We keep records of your plan, billing interval, currency, renewal dates, payments, refunds, purchases of additional analyses, your analysis balances and a record of how each analysis was used.

2.3 What you submit to analyze (Your Content): listing text and links you paste, photos and screenshots you upload, prices, locations you type, notes, flip and inventory records, receipts and other attachments, saved searches and alert settings. Listings and photos can contain personal information about other people (for example a seller's name, face, phone number, address or neighbourhood). Please only submit what you need; see Section 4.

2.4 Information created by the Service: the analyses and recommendations generated for you, the AI cost of each analysis, which mode it ran in, usage counts, and team activity (for Business teams, which member did what, e.g. "analysis", "joined team").

2.5 Technical and security information: we don't use third-party analytics or advertising trackers, and we don't share usage data with ad networks. We do process: - our own product usage records, kept only on our servers: a dated note when certain things happen, such as the homepage or pricing page being viewed (no account or IP address attached for visitors who aren't signed in), and, for signed-in accounts, sign-up, onboarding steps, a first analysis, a saved deal or search, an upgrade prompt viewed, checkout started or completed, a plan change or cancellation, a deal report shared and a referral, and which share or copy button you used on Refer & Earn (the button and time only, never who you shared with). We use these counts to see which parts of the Service are used and where people get stuck [retention: [ ] months]; - wording tests: now and then we show two versions of a button or a line of text on our public pages to see which is clearer. Which version you see is decided from the keyed, one-way hash of your network address described below (not the address itself), and we count how many visitors who saw each version signed up. No price, plan or feature ever differs between versions; - a record of the summary and product-news emails we sent you (which kind and when), so we don't send them too often; - your IP address, to deliver the Service and to rate-limit abuse; for sign-up protection we store only a keyed, one-way hash of it, not the address itself; - a random device identifier in a cookie (Section 9), also stored only as a hash on our side; - server and security logs kept by our hosting provider (which may include IP addresses, browser type, times and pages requested) [retention: [ ] days]; - login attempts and lockouts, and one-time email links (stored as hashes).

2.6 Location: we don't ask for your device's location. We process locations you type (for example an item's location) and locations that appear in listings you submit. We don't derive a location from your IP address.

2.7 Communications: emails you send us and our replies; messages you send from the Help page; whether you've agreed to receive product news (optional, off by default); and how often you've asked for the activity summary (a factual recap of your own account, which you can change or turn off on the Notifications page or from the link in each email).

2.8 Information from others: Google or Apple (if you use them to sign in), Stripe (payment status and card details above), and Have I Been Pwned (only whether a password you chose appears in known breaches; see Section 6).

3. Why we use it, and our legal bases

In Canada we rely on your consent, which is implied for uses that are necessary to provide the Service you've asked for, and express for optional uses (product news). You can withdraw consent subject to legal or contractual limits; some withdrawals mean we can't provide the Service.

Automated decisions. Recommendations (BUY/ASK/AVOID, max offer) are produced automatically for you to consider; they don't produce legal effects for you. Our anti-abuse checks may automatically decide that a new account doesn't get a free allowance (for example, the same card already had one); you can contact us to have a person review it.

4. AI processing

To produce an analysis we send the listing text, photos and details you submitted, and our instructions, to our AI provider, Anthropic, PBC (USA), which runs the Claude models and performs web searches related to the item (search queries are derived from the item, not from your account details). Under Anthropic's commercial terms, data sent through its API is not used to train its models, and it is retained by Anthropic for a limited period (currently up to [30] days [CONFIRM against Anthropic's current commercial terms and DPA]) for trust-and-safety purposes, unless a longer period is required by law. We don't send your name, email or payment details to Anthropic. Anthropic acts as our service provider/processor.

5. Public marketplace information

When you submit a listing, we process the listing's title, description, price, photos, location and identifiers, and use public web results about comparable items. This is mostly information about products, but it can include personal information about sellers. We use it only to provide the analysis you asked for and keep it in your account until you delete it. We don't build profiles of sellers. [If we later add features that monitor listings for you, we'll update this section before launching them.]

Same seller, several listings. So we can show "More from this seller" inside your own account, we store a scrambled code with each analyzed listing, made one-way from a phone number written in the listing, or failing that from the seller's public profile details shown on the listing (the site, the year they joined, their number of ratings and average, and the town). The phone number and profile details themselves aren't stored, the code can't be turned back into them, and it is only compared with other listings in the same account. It is kept and deleted with the listing. [LAWYER: confirm this fits PIPEDA / Quebec Law 25 as listing information processed for the user's own purpose, and whether it needs mention in the marketplace terms review (open question 27/28)]

What you like to flip. To order your deals "For you", we work out which categories and brands you tend to watch, track, buy, sell or hide, from your own actions in your account. Nothing else goes into it, it isn't shared, and you can switch it off in Settings ("Learn what I like").

6. Who we share information with

We don't sell personal information, and we don't share it for cross-context behavioural advertising. We share it only with: - Service providers (processors) acting on our instructions: Stripe (payments; Stripe is also an independent controller for some purposes, see its privacy policy), Anthropic (AI analysis), [HOSTING PROVIDER] (hosting and backups), [EMAIL PROVIDER] (sending email), and Have I Been Pwned (we send only the first 5 characters of a hash of a new password to check it against breach lists; the password and full hash never leave our server). - eBay, to search for listings and read listings for you: when you use "Found for you" or analyze an eBay link, we send eBay your saved search words, your postal or ZIP code and search distance, or the eBay item number. We don't send your name, email or account details. eBay is an independent controller (see its privacy policy). We don't keep eBay sellers' usernames. [LAWYER: confirm under eBay's API License Agreement] - Sign-in providers (Google, Apple), only if you choose to use them; they're independent controllers. - Your team: on a Business plan, the team owner and members can see the team's shared deals, flips, saved searches, analysis usage and member activity. - Professional advisers, authorities and others where required by law, to protect rights, safety and security, to investigate fraud, or with your consent. - Business transfers: a buyer or successor in a merger, acquisition, financing, reorganization or sale of assets, subject to this policy.

7. International transfers

We're based in Canada [CONFIRM]. Our providers process data in the United States (Stripe, Anthropic, eBay, Google, Apple) and [HOSTING REGION]. Information may therefore be stored and processed outside your province or country, where local law may differ and authorities may be able to access it. We use contracts with our providers to protect it, and for Quebec residents we assess transfers as required by Quebec law.

8. How long we keep it

You can download a copy of your data at any time from Manage account → Email and privacy → Download my data.

9. Cookies and similar technologies

We use only cookies needed to run the Service and keep it secure (no analytics or advertising cookies; the usage records in Section 2.5 are kept on our servers and set no cookie). Details are in our Cookie Policy: - session: keeps you signed in and protects forms (session, or up to [31] days if you choose "keep me signed in"); - dm_dev: a random device identifier to stop free allowances being farmed (2 years); - dm_oauth: holds the security values for a Google or Apple sign-in (10 minutes); - fm_ref: set only if you open a friend's referral link. It holds the referral code and the time, so the referral is recognized if you sign up within the referral window ([30] days), and is removed when you create an account. See the Referral Program Terms.

10. Your rights

Depending on where you live, you may have the right to: access your personal information and get a copy (portability); correct it; delete it; restrict or object to some processing (including processing based on legitimate interests); withdraw consent; and complain to a regulator. You can update your name, password, sign-in methods and subscription in Manage account, delete your account there, and contact [PRIVACY EMAIL] for anything else. We'll verify your identity, respond within the time the law requires (generally 30 days in Canada, and 45 days under US state laws such as California's), and won't discriminate against you for exercising your rights. You may use an authorized agent where the law allows.

Regulators include the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, provincial commissioners and, in the US, your state attorney general or the California Privacy Protection Agency.

11. United States state privacy disclosures (including California)

In the last 12 months we've collected these categories of personal information (CCPA categories): identifiers (email, account and device identifiers, hashed IP); customer records and commercial information (subscriptions, purchases, analyses); internet or other electronic activity (usage of the Service, security logs); and inferences (our analysis recommendations about items, not about you). We collect them from you, your devices, and the providers in Section 2.8, for the purposes in Section 3, and disclose them for business purposes to the service providers in Section 6. We don't sell or share personal information as those terms are defined by California law, and we don't use or disclose sensitive personal information for purposes that require a right to limit (card details are handled by Stripe; account passwords are used only to sign you in). You may request to know, delete or correct personal information, and won't be discriminated against for doing so. Retention: Section 8. [Review list of other US state laws (e.g. Virginia, Colorado, Connecticut, Texas, Oregon); many apply only above revenue or volume thresholds.]

12. Security

We use reasonable administrative, technical and physical safeguards, including: encryption in transit (HTTPS) [CONFIRM at deployment]; salted password hashing; hashed storage of email-link tokens, device and network identifiers and card fingerprints; HttpOnly, SameSite and Secure session cookies; protection against cross-site request forgery; login lockouts and rate limits; checking new passwords against breach lists; least-privilege access; and daily backups of the account and customer databases [CONFIRM: copied off the server at deployment]. [Encryption at rest: depends on hosting; don't claim until confirmed.] No method of transmission or storage is completely secure, and we can't guarantee absolute security.

13. Breaches

If a breach of security safeguards involving personal information under our control creates a real risk of significant harm (Canada), or a breach US state law requires us to report, we'll notify affected individuals and the relevant regulators as required by law, keep records of breaches, and take steps to reduce harm.

14. Children

The Service is for adults (18+). We don't knowingly collect personal information from children. If you believe a child has given us information, contact [PRIVACY EMAIL] and we'll delete it.

15. Third-party sites

Marketplaces, Stripe, Google, Apple and other sites have their own privacy policies; we don't control them. Review their policies before using them.

16. Changes

We'll post updates here with a new date and version. For material changes we'll notify you by email or in the Service before they take effect and, where the law requires, ask for your consent again.

17. Contact

[PRIVACY EMAIL] · [COMPANY LEGAL NAME], Attn: Privacy Officer, [REGISTERED ADDRESS].

Version 1.0-draft · Last updated 2026-11-07