1. Introduction
FlashList is a mobile application available on both Android and iOS platforms. Given that FlashList collects and processes personal user data, it must comply with the General Data Protection Regulation (GDPR), also known as Datenschutz-Grundverordnung (DSGVO) in Germany. GDPR is a legal framework that sets guidelines for the collection and processing of personal information from individuals within the European Union (EU).
This document outlines the compliance measures FlashList will adopt to ensure full adherence to GDPR standards, safeguarding user data and maintaining transparency regarding data usage, storage, and protection.
2. User Rights & Data Management
Under GDPR, users have specific rights regarding their personal data. FlashList is committed to providing clear mechanisms for users to exercise their rights efficiently.
2.1 Right to Access (Article 15 GDPR)
Users have the right to request access to all personal data that FlashList has collected about them. To facilitate this:
A dedicated section within the app settings will allow users to generate and download their data in a structured, machine-readable format (e.g., JSON or CSV).
Users may request access to their data via customer support, and responses will be provided within 30 days.
2.2 Right to Rectification (Article 16 GDPR)
Users have the right to correct or update their personal data if it is inaccurate or incomplete. FlashList will ensure:
Users can modify their name, email, and phone number directly within the app.
Any additional data corrections must be submitted via a support request and processed within 30 days.
2.3 Right to Erasure (‘Right to be Forgotten’) (Article 17 GDPR)
Users can request the deletion of their personal data. FlashList will provide:
An in-app deletion request option for users to remove their accounts.
Automatic deletion of associated user data from Firebase, RevenueCat, and other third-party integrations within 30 days.
Confirmation of data deletion via email to users upon completion.
2.4 Right to Data Portability (Article 20 GDPR)
Users have the right to receive their personal data in a commonly used format to transfer it to another service. To comply:
A data export feature will be available within the app.
Data will be provided in a standardized format such as CSV or JSON.
2.5 Right to Restrict Processing (Article 18 GDPR)
Users can request temporary restriction of data processing under specific circumstances, such as:
Disputing the accuracy of personal data.
Objecting to processing methods.
2.6 Right to Object (Article 21 GDPR)
Users can object to certain types of data processing, such as direct marketing and behavioral tracking. FlashList will:
Provide opt-in/opt-out options for targeted advertisements.
Allow users to disable tracking and analytics.
3. Consent Management
Consent plays a crucial role in GDPR compliance. FlashList will implement explicit consent collection mechanisms for various features:
User Registration & Authentication: Users must explicitly accept the Privacy Policy and Terms of Service during account creation.
Subscription Payments: Payments processed via RevenueCat will comply with Apple Pay and Google Pay policies, ensuring informed consent before transactions.
Push Notifications & Analytics: Users will have the option to enable or disable notifications and tracking in their settings.
Revoking Consent: Users will be able to withdraw consent for data processing at any time.
4. Third-Party Compliance & Data Security
FlashList integrates various third-party services, each of which complies with GDPR:
Firebase Authentication: Secure login with Google, Apple, and Email sign-in.
Firebase Firestore: Secure encrypted database storage.
Firebase FCM: Push notifications with user opt-in.
RevenueCat: Subscription management for Apple & Google Pay.
All data transfers between FlashList and these services are encrypted and comply with GDPR standards.
5. Security Measures
FlashList will implement robust security measures to protect user data:
Data Encryption: All stored data will be AES-256 encrypted.
Secure Authentication: Multi-factor authentication (MFA) will be required for administrators.
Access Controls: Strict role-based access for handling user data.
Data Minimization: Only essential data will be collected.
6. Data Breach Response Plan
In case of a data breach, FlashList will follow GDPR Article 33 requirements:
Identify and Contain the Breach: Immediate action will be taken to stop unauthorized access.
Notify Affected Users: Affected users will be informed within 72 hours of detection.
Report to Authorities: The breach will be reported to the relevant Data Protection Authority.
Implement Corrective Actions: Steps will be taken to prevent future breaches.
7. GDPR Compliance in the Admin Panel
A dedicated admin panel will provide tools to manage GDPR requests efficiently:
View and manage user data access requests.
Track and log data deletion/modification actions.
Manage consent preferences.
Generate compliance reports.
8. Privacy Policy & Terms of Service
FlashList will include comprehensive legal documents covering:
Data Collection Policies: What data is collected and why.
User Rights: How users can exercise GDPR rights.
Third-Party Services: Explanation of external integrations.
Security Measures: Description of protection methods in place.
9. Implementation Plan & Next Steps
To ensure compliance, FlashList will implement the following:
Develop API Functions: Enable automated handling of data requests.
User Interface Enhancements: Integrate GDPR compliance features into the app settings.
Admin Panel Deployment: Provide tools for managing user requests efficiently.
Legal Review: Ensure Privacy Policy & Terms of Service meet GDPR requirements.
Ongoing Monitoring: Regularly audit compliance and make necessary updates.