Flip Privacy Policy

We use the information we collect to provide our Service to all Users, including for the following purposes: 

• To provide, maintain, and improve the Service, including updating, securing, troubleshooting, and providing support;

• To authenticate Educators and Students who access the Service using a third-party account, such as their Microsoft, Apple or Google account;

• To improve and develop the Service;

• To respond to User comments and questions and provide customer service;

• To communicate with Users, other than Student Members, about Microsoft or Flip products, services, and events, new Flip features and other news and information we think will interest Educators (see the Your Choices section below for information about how to opt out of these communications at any time).

• To send Users information including confirmations, technical notices, updates, security alerts, and support and administrative messages.

• To monitor and analyze trends, usage, and activities in connection with the Service. Information about Students used for this purpose is de-identified or aggregated so that it cannot reasonably be used to identify any individual Student. 

• To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Flip and others.

• To debug to identify and repair errors in our Service. 

• To facilitate the creation and management of accounts on our Service.

• To comply with our legal and financial obligations.

• To create de-identified, anonymized, or aggregated information. 

• For any other purpose described to you at the time information is collected or with your permission.

When you use the Service, Flip does not use your personal information to market or advertise non-Microsoft products or services to you. When you use the Service, Flip also does not use your personal information to track and target advertisements on third-party websites or services.

Flip does not sell User personal information. We share personal information in the following circumstances or as otherwise described in this Privacy Policy:  

• When you use the Service, your personal information and content may be shared with other Users who you interact with on the Service. 

• We share User personal information with vendors, consultants, and other third-party service providers who need access to such information to perform services for us, such as companies that assist us with web hosting and customer service. 

• We may share User personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may share personal information if we believe that your actions are inconsistent with our agreements, policies, or terms of use, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Flip, our employees and agents, our Users, the public, or others. 

• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests. 

• We may disclose or transfer your personal information in connection with, or during negotiations concerning, any sale, merger, bankruptcy, sale of assets, financing, acquisition, or reorganization, in whole or in part, of our company. 

• We may share personal information between and among Flip and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership. 

4.1 Sharing to other Users

When you share content to a Group or Topic, that content is accessible by any User who has permission to access the Group or Topic, subject to the Educator’s ability to deactivate, moderate, or hide Groups, Topics, and the content within them. The Educator, not Flip, sets the Group or Topic access permissions and privacy settings, including access permissions for content within a Group or Topic. 

 4.2 Sharing to Recipients Outside the Service  

You can share the content you submit to a Group or Topic with your friends or others who do not use the Service via a link (a “Content URL”). If the recipient of a Content URL sends the Content URL to other people, those other people will also be able to access your content on the Service. 

Depending on the permissions set by your Group or Topic Educator, you may also be able to invite your friends or others who do not use the Service to access a Group or Topic via a link (a “Group/Topic URL”). Educators, not Flip, set the access permissions and privacy settings that determine whether a Group/Topic URL will work for recipients. 

Flip does not, and cannot, control how Users share Content URLs or Group/Topic URLS outside the Service, how Educators set Group/Topic URL access permissions, or how recipients of Content URLs or Group/Topic URLs will view, use, or reshare such URLs and the content made accessible through them. 

The Service may link to third-party sites, services, plug-ins, and applications that are not operated or controlled by Flip (each a “Third-Party Service”). Educators, and not Flip, determine whether such Third-Party Services are accessible to Users on their Groups and Topics. Third-Party Services are governed by their respective privacy policies. This Privacy Policy does not apply to such Third-Party Services, and we cannot take responsibility for the content, privacy policies or practices of third-party services.

We use cookies and similar technologies to collect information about your use of the Service in order to analyze and track data and determine the popularity of certain content on our Service. Cookies are small data files stored on your hard drive or in device memory that help us provide and improve the Service and your experience, collect data about the Service and how it is used, and to share information about Flip and its features and functionalities to Educators. For example, cookies allow you to log in to secure areas of the Service and help the content of the pages load quickly. We use cookies to provide you with a more personal, useful, and interactive experience with our Service. We also use web beacons (also known as “pixel tags” or “clear GIFs”) to help deliver cookies and gather usage and performance data. 

In addition to the cookies we set, we allow other third-parties to provide analytics services on our behalf. These third-parties can set cookies when you use the Service to collect information about you. For example:

• Companies we hire to provide services that help us offer our Service, such as site analytics providers, may place cookies when you visit our sites.

• Companies that deliver content, such as videos an Educator links to or embeds, place cookies on their own. These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps, or online services.

Each User has a variety of tools to control cookies, web beacons, and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. User browser settings and other choices may impact the functionality of the Service. 

7.1 Personal Information and User Content 

Users may opt out of providing personal information to the Service at any time by ceasing to use the application. Users (and their parents, if applicable) may also request deletion of their personal information, including content, by going to Flip Help or, in some cases, contacting the relevant Group/Topic Educator. We may ask you for certain information about yourself or about your content to validate your request. If we cannot validate your request, we may not be able to remove the content. Learn more about the choices Users have with respect to access and deletion of their information here. 

If you request deletion of your account or content, please note that we may still retain certain information as required by law or for our legitimate business purposes as outlined in Section 10 of this Policy.

7.2 Communications Preferences

We may send Educators emails regarding events, news, and other topics, as described in the Use of Personal Information section above. Educators can opt out of receiving such emails by following the instructions provided in those emails. Note that if an Educator opts out of such emails, we may still send them operational emails that pertain to the Educator’s account and notifications regarding our Service.

This section of the Privacy Policy applies to information we collect from Users under the age of 13 or the age where Parental consent is required for use of the Service under applicable law (individually, a “Child,” and collectively, “Children”). With consent from a parent or legal guardian (a “Parent”) obtained by their School Educator, Children can use the Service as Student Members. In certain cases, and only after providing Parental consent in compliance with applicable law, Children can use the Service as Educators. Please contact Flip at flipsupport@Microsoft.com if you have further questions. 

If we learn that we have collected a Child’s personal information without legally required Parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their Child has submitted personal information to us and would like to have it deleted may contact us at Flip Help. 

 8.1 Collection, Use and Disclosure of Children’s Information 

Under the United States Children’s Online Privacy Protection Act (“COPPA”), verifiable Parental consent is needed to collect, use, or disclose personal information (e.g., full name and email address) from each User under 13 years old.

 a) Information Collected from Children. We obtain verifiable Parental consent before collecting, using, or disclosing information from a Child, including as described in Section 8.2 for Student Members. We collect the same types of personal information from Children as we do from other Members, as described in Section 1 above. We will not knowingly require any Child to disclose more information than is reasonably needed to participate in the Service. 

b) Use and Sharing of Children’s Information. Once we obtain verifiable Parental consent, we may use and share personal information collected from Children for the same purposes applicable to other Members, except as otherwise described in Sections 2 through 6 above. As with other Users, we do not sell Children’s personal information or use Children’s personal information to market or advertise to Children, nor do we permit third-parties to do so. 

c) As described in Section 4.1, content Children post to Groups and Topics may be visible to other Users of the Service. As described in Section 4.2, content Children post to the Service may also be accessible to individuals outside the Service who receive a Content URL and/or Group/Topic URL containing a Child’s content. We encourage Parents to monitor their Children’s use of the Service, including the content and personal information they submit. Flip is not able to control or monitor all personal information or content Children may submit to the Service, nor what Users or recipients of a Content URL or Group/Topic URL may ultimately do with any information or content they have access to from the Service. 

d) Parental Rights. Parents have certain rights with respect to our collection, use, retention, and disclosure of their Child’s information. This includes the right to review, update, or delete personal information about their Child, as well as to prohibit our sharing of personal information about their Child with certain third-parties. Parents can exercise these rights by contacting their Child’s School Educator or by sending requests directly to us at Flip Help. Please note that if a Parent requests deletion of his/her Child’s personal information or content, we may still retain certain information as required by law or for our legitimate business purposes as outlined in Section 10. Children and their Parents can learn more about the choices Users have with respect to their information here. 

8.2 Notice to Schools and Student Members

In accordance with COPPA, a teacher, such as a School Educator, may act as the agent of the Parent of a student and provide consent on behalf of the Parent for Flip’s collection, use, and disclosure of the student’s personal information. As such, by enrolling a Student under 13 to use the Service, the School Educator provides such consent to us and agrees that the Student's activities while on the Service are subject to our Terms, including but not limited to our Code of Conduct. Please see the Parent Consent Form for guidelines on how teachers and Schools may provide consent on behalf of Parents.

This Privacy Policy does not govern any School’s collection, use, or disclosure of a Student’s personal information through the Service, and we are not responsible for any such collection, use, or disclosure. 

We use security technologies and procedures to help protect your personal information. While we take efforts to protect your personal information, please remember that no transmission of information on the Internet is 100% secure, and we cannot guarantee or be responsible for absolute security of your information. You can learn more about our information security practices here. 

We store the information we collect for as long as you have an account (if you are an Educator), or for up to 30 days in our archives when you ask for data to be deleted. Additionally, we may retain User information to resolve disputes, enforce our policies, and to comply with the law. 

Personal information collected by Flip may be stored and processed in your region, in the United States, and in any other country where Flip or our affiliates, or service providers operate facilities. We take steps to ensure that the personal information we collect under this privacy policy is processed according to the provisions of this policy and the requirements of applicable law wherever the data is located. We transfer personal data from the European Economic Area, the United Kingdom, and Switzerland to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal information, and this section applies to you.

12.1 Legal Basis for Processing

 When we process your personal information, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., providing the products and services you requested). 

• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).

• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).

• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal information, you may withdraw such consent at any time.

12.2 Data Retention

Please refer to Section 10 of this Privacy Policy to learn about our retention periods for personal information we collect.

 12.3 Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal information we hold about you and to receive your data in a portable format, the right to ask that your personal information be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at Flip Help. 

12.4 Questions or Complaints

If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

 For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

 For individuals in the UK: https://ico.org.uk/global/contact-us/

 For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

13.1 California Consumer Privacy Act

If you are a California resident, we process your personal information in accordance with the California Consumer Privacy Act (CCPA). If you are a California resident, this section may apply to you and supplements our Privacy Policy.

Sale. We do not sell your personal information. We do not knowingly sell personal information about consumers under the age of 16.

Rights. Subject to certain limitations, you have the right to: (i) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (ii) correct inaccuracies in your personal information; (iii) request deletion of your personal information; (iv) opt out of any “sales” of your personal information that may be occurring; (v) limit the use and disclosure of your sensitive personal information; and (vi) not be discriminated against for exercising these rights. 

Exercising Your Rights. You may exercise your rights by contacting us at flipsupport@microsoft.com,  filling out the form at Flip Help, or by taking the steps described here. If you contact us to make a request to exercise your rights, we may ask for additional information to validate your identity before honoring the request.

You may make these requests through an authorized agent. If you use an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. We may also request information from you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please send an email to flipsupport@microsoft.com.

If you wish to appeal our response to a consumer rights request, please contact us at flipsupport@microsoft.com, or make an inquiry at Flip Help.

 We will not discriminate against you if you exercise your CCPA rights. 

 Personal Information Processing. In the preceding 12 months, we have collected the following categories of personal information: personal identifiers, information subject to Cal. Civ. Code § 1798.80(e), characteristics of protected classifications under California or U.S. law, commercial information, Internet or other electronic network activity information, professional or employment-related information, audio, electronic, visual or similar information and inferences drawn about you and other categories of personal information that relate to, describe or are reasonably capable of being associated with you. 

For details about the precise data points we collect and the categories of sources of such collection, please see the Information Flip Collects section above. We collect personal information for the business and commercial purposes described in the Use of Personal Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients: 

13.2 How We Respond to Do Not Track Signals

We do not currently respond to "do not track" signals or other mechanisms that might enable consumers to opt out of tracking on our website.

When you use the Flip Camera, you can choose to enhance your video and audio with Flip Lenses. For example, Flip Lenses can show you wearing a party hat, have your backdrop appear as though you are on the moon, help you learn sign language, or alter your voice into a chipmunk-style high pitch. Depending on which Flip Lens you choose, your video and audio may be processed to extract information about your voice and about the location of different areas on your face and hands (collectively, “Extracted Data”).

Some of this Extracted Data may be considered biometric data in certain jurisdictions. None of this Extracted Data is used to personally identify you. Extracted Data is used for the sole purpose of providing Flip Lenses to you. Extracted Data is processed for the duration of the session on your device only then deleted. The Extracted Data is not sent to Flip or any third party. 

Processing of Extracted Data is subject to this notice only. For information on how Flip handles your video, audio and any personal information see the Use of Personal Information section in the Flip Privacy Policy. 

If you have any questions about this Privacy Policy or wish to contact us, please contact us at Flip Help.

You can reach Flip by mail or phone at:

Flipgrid, Inc.

Microsoft Corporation

One Microsoft Way

Redmond, Washington 98052, USA

Telephone: +1 (425) 882 8080.