Privacy Policy
Cushyfy Solutions Inc ("we", "us", "our") operates the Flinkee platform. This Privacy Policy explains how we collect, use, store, and protect your personal information in compliance with the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.
What Data We Collect
Account Information
- Email address and name (provided during registration)
- Password (stored as a one-way bcrypt hash — we cannot read your password)
- Organization/workspace name
Messages from Connected Channels
When you connect messaging channels to Flinkee, we collect and process:
- WhatsApp: Group messages, sender names, timestamps
- Viber: Group messages, sender names, timestamps
- Gmail: Email subject, body, sender, timestamps (for monitored labels only)
- Slack: Channel messages, sender names, timestamps
- Telegram: Group/channel messages, sender names, timestamps
- Other channels: Discord, MS Teams, Instagram, Facebook Messenger — same data types as above
We do not collect messages from channels you have not explicitly connected.
Usage Data
- Briefing generation timestamps and delivery status
- Login timestamps and IP addresses (for security purposes)
- Feature usage within the admin portal
How We Use Your Data
Your data is used exclusively for the following purposes:
- AI Briefing Generation — Messages are sent to our AI provider to generate structured briefings and summaries. This is the core function of Flinkee.
- Briefing Delivery — Generated briefings are sent to your designated email addresses.
- Service Operation — Account management, authentication, and platform functionality.
- Security — Detecting unauthorized access and preventing abuse.
We do not use your messages for advertising, marketing profiling, or any purpose other than generating your briefings.
Data Retention
Message data is retained according to your subscription plan:
| Plan | Message Retention | Briefing Retention |
|---|---|---|
| FREE | 7 days | 7 days |
| STARTER | 30 days | 90 days |
| PRO | 90 days | 1 year |
| ENTERPRISE | Custom | Custom |
After the retention period, messages are permanently deleted from our systems. Account information is retained for the duration of your account and deleted within 30 days of account closure.
Third-Party Processors
We share your data with the following third-party service providers, strictly for operating the Service:
All third-party processors are bound by data processing agreements and are required to handle your data in accordance with applicable privacy laws.
Cross-Border Data Transfers
Your data is transferred to and processed in the United States by our third-party processors. These transfers are conducted with appropriate safeguards as required by the Philippines Data Privacy Act, including contractual protections ensuring an adequate level of data protection.
Data Security
We implement the following security measures:
- Encryption in transit (TLS/HTTPS for all connections)
- Encryption at rest (database-level encryption)
- Passwords hashed with bcrypt (10 salt rounds)
- JWT-based authentication with short-lived access tokens (15 minutes)
- Workspace-level data isolation (multi-tenant architecture)
- CORS restrictions and security headers (Helmet)
- Rate limiting on authentication endpoints
Philippines Data Privacy Act (RA 10173)
As a Personal Information Controller registered with the National Privacy Commission (NPC), Cushyfy Solutions Inc complies with Republic Act No. 10173 and its Implementing Rules and Regulations.
Lawful basis for processing: Consent (you connect channels and authorize processing) and Contract (we process data to deliver the Service you subscribed to).
Data Protection Officer: Jim Morris, Owner — dpo@flinkee.ai
Data breach notification: In the event of a personal data breach, we will notify the NPC and affected data subjects within 72 hours, as required by NPC Circular 16-03.
Your Rights
Under the Philippines Data Privacy Act, you have the following rights:
- Right to Access — Request a copy of all personal data we hold about you and your workspace.
- Right to Correction — Request correction of inaccurate or incomplete personal data.
- Right to Erasure — Request deletion of your personal data. We will delete all messages, briefings, and account data within 30 days of a verified request.
- Right to Data Portability — Request an export of your data in a machine-readable format (JSON).
- Right to Object — Object to processing of your personal data on legitimate grounds.
- Right to File a Complaint — File a complaint with the National Privacy Commission if you believe your rights have been violated.
To exercise any of these rights, contact us at privacy@flinkee.ai. We will respond within 15 business days.
Children's Privacy
Flinkee is not intended for use by individuals under 18 years of age. We do not knowingly collect personal data from minors. If we learn that we have collected data from a minor, we will delete it promptly.
Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email to all registered users at least 14 days before taking effect. The "Last updated" date at the top of this page will be revised accordingly.
Contact Us
For privacy-related inquiries:
Cushyfy Solutions Inc
Data Protection Officer: Jim Morris
Email: privacy@flinkee.ai
Website: flinkee.ai
National Privacy Commission: www.privacy.gov.ph