Effective Date: March 10, 2025 | Version 1.0

1. Introduction

Flair Diffusers ("Flair", "we", "us", or "our"), through its technology partner ICASH Business Solutions Inc., is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the Flair Diffusers mobile application (the "App").

By using the App, you consent to the data practices described in this Privacy Policy. If you do not agree, please discontinue use of the App.

This policy is designed to comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Law 25 (Act respecting the protection of personal information in the private sector).

2. Information We Collect

2.1 Information You Provide

When you create an account or use the App, you may provide:

• Email address and password: Account credentials
• Diffuser names, assigned room locations, and selected fragrances: Device personalization
• Notification preferences, language settings, and scheduling configurations: App preferences

2.2 Information Collected Automatically

The App automatically collects certain technical and usage information, including:

• Device hardware information, including model, manufacturer, and operating system version
• Bluetooth device identifiers, including MAC address, of paired diffusers
• App usage data, including feature interactions and error logs
• Diffuser state data, including power status, intensity level, and oil level estimates
• Schedule configurations, including times, days, and intensity settings

2.3 Information We Do Not Collect

We do not collect:

• Payment or financial information, as there is no e-commerce in Phase 1
• Precise GPS location. Location permission on Android is used solely by the operating system for Bluetooth device discovery, and is not tracked or stored by us
• Audio, video, or camera data
• Contacts, calendar, or other app data from your device

3. How We Use Your Information

We use the information collected to:

• Provide and maintain App functionality, including Bluetooth device pairing and control
• Send push notifications for low oil alerts, schedule execution, and device connection status
• Authenticate users and ensure only authorized Flair devices connect to the App
• Improve and debug the App through anonymized error reporting and usage analytics
• Communicate important service updates or changes to this Privacy Policy
• Comply with applicable laws and legal obligations

We do not use your personal information for targeted advertising, and we do not sell your data to third parties.

4. Bluetooth and Local Device Communication

The App communicates with your diffuser hardware exclusively through Bluetooth Low Energy (BLE). All device control commands and data exchanges occur locally between your mobile device and your diffuser.

In Phase 1, no diffuser data is transmitted to remote servers or cloud infrastructure. Your device state, schedules, and oil level information remain stored locally on your mobile device.

Bluetooth device identifiers, including MAC addresses, are used solely to identify and maintain connections with your paired Flair diffusers and are not shared with third parties.

5. Data Sharing and Disclosure

5.1 Service Providers

We may share limited technical information with trusted service providers who assist in App development, maintenance, and error monitoring. These providers are bound by confidentiality obligations and may not use your data for their own purposes.

5.2 Legal Requirements

We may disclose your information if required to do so by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Flair Diffusers, our users, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction. We will notify you via the App or email prior to your data becoming subject to a different privacy policy.

5.4 No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for commercial purposes.

6. Data Retention

We retain your account information and associated App data for as long as your account remains active.

If you delete your account, we will delete or anonymize your personal information within 30 days, except where we are required to retain it for legal compliance purposes.

Anonymized and aggregated usage data that cannot be linked to an individual may be retained indefinitely for product improvement purposes.

7. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encrypted storage of account credentials
• Secure authentication mechanisms
• Access controls limiting who can access personal data
• Regular security reviews as part of our development process

While we strive to use commercially acceptable means to protect your information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal obligations
• Portability: Request that your data be provided in a structured, machine-readable format
• Objection: Object to certain types of processing, including for marketing purposes

To exercise any of these rights, please contact us using the information in Section 11. We will respond to your request within 30 days.

8.1 Notification Preferences

You may manage push notification preferences at any time through App Settings > Notifications or your device's system settings. Disabling notifications will not affect your ability to use core App features.

9. Children's Privacy

The App is not directed at children under the age of 13, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it promptly.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes through the App or by other appropriate means. The "Effective Date" at the top of this document indicates when the current version was last revised.

Your continued use of the App after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

11. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, please contact our Privacy Officer:

Flair Diffusers
Developed by: ICASH Business Solutions Inc.
Email: privacy@flairdiffusers.com
Phone: 418-572-7039
Website: https://flairdiffusers.com