Legal · Русская версия
Privacy Policy
In short
- FLARIO COSMETICS TRADING L.L.C, a company registered in Dubai, is responsible for your personal data.
- The flario.ae website does not use accounts, forms, advertising or analytics.
- In the Blissko Circle app we process pregnancy and health information only with your separate, explicit consent and only to run the features you use.
- We never sell personal data and never use health data for advertising.
- You can download, correct or delete your data at any time. To delete your account, see flario.ae/delete-account.
- Questions: [email protected].
1. Who we are and what this policy covers
The controller of your personal data is FLARIO COSMETICS TRADING L.L.C (Arabic: فلاريو لتجارة مستحضرات التجميل ذ.م.م), a limited liability company registered in Dubai, United Arab Emirates, trade licence no. 1044975 issued by the Department of Economy and Tourism, registered office: Office 1905, Al Shafar Tower 1, Barsha Heights (TECOM), P.O. Box 416107, Dubai, UAE ("Flario", "we", "us").
This policy applies to:
- the website flario.ae;
- our mobile and web applications published by FLARIO COSMETICS TRADING L.L.C, currently Blissko Circle (iOS, Android and web) and, when released, Limba Pro (the "Apps");
- our communications with customers, wholesale buyers, salons, suppliers and other business partners.
It does not apply to third-party websites and services that we link to, such as Amazon, noon, online stores of retailers or the Ivideon camera service. Their own privacy policies apply.
We process personal data in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and, where it applies to you, the EU General Data Protection Regulation ("GDPR") and other data protection laws of your country of residence.
2. Personal data we collect
2.1. When you visit flario.ae
The website has no user accounts, contact forms, advertising or analytics. Our hosting and security provider Cloudflare processes technical data that every browser sends, such as IP address, browser type, the page requested and the time of the request, to deliver the site and protect it from attacks. Our pages load fonts from Google Fonts, so your browser also sends your IP address to Google when you open them.
2.2. When you contact us or do business with us
Name, company, position, email, phone number, messenger contact, the content of your messages, and for orders: delivery address, order contents, invoices, payment records and VAT details.
2.3. When you use Blissko Circle
| Category | Examples | Source |
|---|---|---|
| Account data | Email address, one-time sign-in codes, name or nickname, profile photo, city, your stage (planning, pregnant or mother), estimated due date or your baby's date of birth, interests you select | You |
| Health and pregnancy data (special category, see section 4) | Pregnancy week and due date, cycle and conception information you enter, wellbeing check-ins, symptoms, blood pressure, pulse, weight, fetal movement counts, appointments, birth plan, pregnancy diary entries and photos, questions you ask doctors and their answers | You; doctors who answer your questions |
| Community content | Posts, comments, reactions, goals and pledges, contest entries and votes, meetings you create or join (including the meeting address), doula requests and reviews | You; other members |
| Linked accounts | Telegram user ID, username and name if you sign in with or link Telegram; your Instagram username if you add it to your profile | You; Telegram |
| Rewards and invitations | In-app coins, badges, gift redemptions and the delivery details you give us for a gift, invitation links and who invited you | You; the app |
| Technical and usage data | Device and browser type, IP address, sign-in session data, a random user ID, records of actions in the app (for example "check-in completed" or "question to a doctor sent"), error logs | Your device; the app |
We do not access your phone contacts, precise location, camera roll (except photos you choose to upload), microphone or health records stored in Apple Health or Google Health Connect.
2.4. Limba Pro
Limba Pro is in development. It will process business data of partner salons (salon name, contact person, contact details, orders and trade prices). We will update this policy before it is released.
3. Why we use personal data and our legal grounds
| Purpose | Data | Legal ground |
|---|---|---|
| Create and run your account, sign you in, provide the features of the App | Account, technical data | Performance of our contract with you (the Terms of Use) |
| Provide health features: pregnancy calendar, diary, check-ins, vitals, safety prompts, questions to doctors | Health and pregnancy data | Your explicit consent |
| Form your Circle and show your content to the people you choose | Account, community content, pregnancy week | Contract; your explicit consent for the pregnancy week |
| Send reminders in Telegram | Telegram ID, reminder settings | Your consent (you switch reminders on yourself) |
| Keep the community safe: moderation, preventing abuse, fraud and security incidents | Account, community content, technical data | Our legitimate interests; legal obligations |
| Understand which features are useful and fix errors | Usage and technical data linked to a random ID | Our legitimate interests or, where the law requires, your consent |
| Answer your questions and support requests | Contact data, messages | Contract; our legitimate interests |
| Send news and offers | Contact data | Your consent, which you can withdraw at any time |
| Process orders, invoices, deliveries and taxes for business customers | Business contact and order data | Contract; legal obligations under UAE commercial and tax law |
| Comply with the law and establish, exercise or defend legal claims | Any relevant data | Legal obligations; our legitimate interests |
Where we rely on consent, you can withdraw it at any time in the App or by writing to us. Withdrawal does not affect processing carried out before it.
4. Health and pregnancy data
Information about pregnancy, your body and your wellbeing is a special (sensitive) category of personal data. We apply the following rules to it:
- Explicit consent. We ask for separate consent before you enter health information. Without it you can still use the community features that do not need health data.
- Purpose limitation. We use health data only to provide the features you use. We do not use it for advertising, do not build advertising profiles, do not sell it and do not share it with insurers, employers or data brokers.
- Limited visibility. Your health entries are visible only to you unless you decide otherwise. A question to a doctor is visible to you and to verified doctors who answer questions in the App. A question and answer are published in the App in anonymised form only if you tick the corresponding box.
- Analytics. Our analytics receive only a random user ID and the type of action (for example "vitals saved"), never the values you enter or the texts you write.
- Withdrawal. If you withdraw consent, health features stop and we delete your health data within 30 days. Your account and community content remain unless you delete them too.
- Not a medical service. The App does not diagnose or treat. See the medical disclaimer in the Terms of Use.
5. Who can see your information in the App
| Who | What they see |
|---|---|
| Members of your Circle | Your name or nickname, profile photo, stage and pregnancy week or baby's age, your posts, comments and reactions in the Circle, goals and pledges you share |
| Other members of the App | Your name or nickname and profile photo where you take part in shared spaces, such as contests or public answers |
| Participants of a meeting | The exact meeting address is shown only to members who sign up for that meeting |
| Verified doctors in the App | The text of your question, your pregnancy week or stage and city. Not your email. |
| Doulas you contact | Your request and the contact details you choose to share |
| Our authorised staff and moderators | Only what they need for support, moderation and safety, under confidentiality obligations |
Doctors and doulas are independent professionals, not our employees. They must keep your information confidential and use it only to answer you.
6. Service providers and other recipients
We use the following providers ("processors") who process personal data on our behalf under written data processing agreements:
| Provider | Service | Location of processing |
|---|---|---|
| Supabase Inc. | App database, sign-in, file storage | European Union (Ireland) |
| Vercel Inc. | Hosting and delivery of the App | European Union (Ireland), global delivery network |
| Cloudflare, Inc. | Hosting of flario.ae, DNS, protection against attacks | Global network, including the UAE |
| PostHog, Inc. | Product analytics (random ID, action type) | European Union (Germany) |
| Google LLC | Delivery of sign-in code emails; website fonts | United States and other countries |
| Telegram | Sign-in and reminders, only if you link Telegram | Telegram's global infrastructure |
| AE Server (aeserver.com) | Our business email at flario.ae: requests, support, account deletion | European Union (Germany, Frankfurt) |
We may also disclose personal data:
- to companies of FLARIO Group that manufacture our products, when this is needed to handle a business order, a product enquiry or a complaint. App and health data are not shared with them;
- to delivery services, when you redeem a gift or place an order;
- to public authorities, courts and advisers when the law requires it or to protect rights, safety and property;
- to a buyer or successor in a merger, acquisition or sale of assets, under the same protections as in this policy.
We do not sell personal data and do not share it for cross-context behavioural advertising.
7. International transfers
App data is stored mainly in the European Union. Some providers listed above may process data in other countries, including the United States. When personal data leaves the UAE or the European Economic Area, we transfer it only to recipients that provide an adequate level of protection or under appropriate safeguards, such as data processing agreements with standard contractual clauses approved by the European Commission, as permitted by the PDPL and the GDPR. You can ask us for a copy of these safeguards.
8. How long we keep data
| Data | Retention period |
|---|---|
| Account data and community content | While your account exists. After you delete your account, within 30 days; removed from backups within a further 35 days |
| Health and pregnancy data | While your account exists and your consent is valid; deleted within 30 days after you delete it, withdraw consent or delete your account |
| Anonymised questions and answers you agreed to publish | May remain in the App after account deletion because they no longer identify you |
| Analytics events (random ID) | Up to 12 months |
| Server and security logs | Up to 30 days, longer only to investigate a specific incident |
| Support correspondence | Up to 2 years after the last message |
| Business orders, invoices and accounting records | 5 years after the end of the tax period, or longer if UAE law requires |
| Data needed for a legal claim | Until the claim is resolved and the limitation period expires |
9. Security
We use appropriate technical and organisational measures. These include encryption in transit (TLS) and at rest, access control at database-row level so that each member can reach only her own private data, the principle of least privilege for staff, sign-in by one-time codes instead of passwords, and confidentiality obligations for staff, doctors and providers. No system is completely secure. If a personal data breach is likely to put your rights at risk, we will notify you and the competent authority as required by law.
10. Your rights
Subject to the conditions of the law that applies to you, you have the right to:
- be informed about and get access to your personal data and receive a copy;
- have inaccurate data corrected and incomplete data completed;
- have your data deleted;
- restrict or object to processing, including processing based on our legitimate interests;
- receive your data in a structured, commonly used, machine-readable format and transfer it to another controller;
- withdraw consent at any time;
- not be subject to a decision based solely on automated processing that has legal or similarly significant effects;
- lodge a complaint with a supervisory authority (see section 17).
To exercise your rights, write to [email protected] from the email address linked to your account. We may ask you to confirm your identity. We answer within 30 days. If a request is complex, we may extend this period where the law allows and will tell you why. Exercising your rights is free unless a request is manifestly unfounded or excessive.
11. Deleting your account and data
You can delete your Blissko Circle account and the related data at any time. Instructions and the list of data we delete or keep are on flario.ae/delete-account. You do not need to install the App to make a request.
12. Age limits and children
Blissko Circle is intended only for adults aged 18 and over. Our website and Apps are not directed at children, and we do not knowingly collect personal data of children. If you believe a child has given us personal data, contact us and we will delete it. Information you enter about your baby, such as a date of birth or name ideas, is processed only to provide the features you use and is deleted together with your account.
13. Cookies and similar technologies
flario.ae does not set its own cookies. Cloudflare may set a strictly necessary security cookie to tell people from bots.
Blissko Circle uses:
- strictly necessary cookies and local storage that keep you signed in (up to 400 days or until you sign out);
- an analytics identifier stored in a cookie and local storage by PostHog, used to count visits to screens. We do not record sessions or screen content. Where the law requires consent for analytics, we ask for it, and you can withdraw it at any time.
You can delete cookies and local storage in your browser or device settings. If you remove the sign-in cookie, you will need to sign in again.
14. Automated safety prompts
If you enter blood pressure, symptoms or similar data, the App may automatically show a prompt, for example to contact a doctor today. These prompts follow fixed rules, are for information only, do not make decisions about you and have no legal or similarly significant effect. They are not a diagnosis.
15. Marketing messages
We send news and offers by email, messenger or SMS only if you have agreed. Every message explains how to unsubscribe. Reminders in Telegram are service messages that you switch on and off in the App.
16. Changes to this policy
We may update this policy. The date at the top shows the current version. If changes are significant, we will notify you in the App or by email before they take effect and, where the law requires, ask for your consent again.
17. Contact us and complaints
FLARIO COSMETICS TRADING L.L.C
Office 1905, Al Shafar Tower 1, Barsha Heights (TECOM), P.O. Box 416107, Dubai, United Arab Emirates
Email: [email protected] · Phone: +971 50 960 4276
If you are not satisfied with our answer, you may complain to the UAE Data Office or to the data protection authority of your country of residence. If you live in the European Union, you can contact your national supervisory authority.
This policy is published in English and Russian. If there is any discrepancy, the English version prevails.