Privacy Policy

Effective: Jan 31, 2019

In this Privacy Policy, Flair, Inc. and Flair Portal, LLC together refer to “Flair”, “Company”, “we,” “us” or “our”. Flair operates flairexchange.com (the “Site”). This is a formal agreement and it governs your participation in and/or use of those services or benefits available at Flair also known as Flair Exchange. By participating in or using the services or features of Company, or by uploading any content or using any of our other services, you are agreeing to be bound by the terms described below and our Terms of Service. If you do not wish to become bound by this Privacy Notice and the Terms of Service, do not access the Company’s Site and do not use any of our services.

Privacy Notice

Flair is committed to safeguarding the personal information of individuals. This privacy statement outlines the practices we follow in protecting personal information and applies to Flair and to any person providing services on our behalf. However, this policy does not apply to the practices of third parties that Flair does not own or control, or to individuals that Flair does not employ or manage.

Collection of Personal Information

We collect only the personal information that we need for the purpose of providing our services, including personal information needed to deliver requested products and services and send out information relating to Flair. We normally collect personal information directly from the individual to whom it pertains. We may collect your information from third-party services for the purpose of verifying your identity. We may provide certain information for service providers.

Sharing your Personal Information

Users may see your public profile. Flair will not share your personal Non-Public Information (“NPI’) and non-related third party. We may share your information with businesses that you invested in and we may share certain information with service providers for fraud detection, and payment processing. We may disclose NPI to our employees and affiliated entities for everyday business purposes or for marketing purposes to offer our products and services to you. Flair will not share your creditworthiness to affiliated entities.

We may disclose personal information to third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers. We will not share your NPI with non-affiliates to advertise to you.

Transfers of Personal Information

The personal information we collect, including NPI, is stored and processed in the United States, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

Any successor in interest to our business would acquire the information we maintain, including your NPI. You acknowledge that such transfers may occur and that any parties who acquire us may continue to use your personal information according to this Privacy Notice.


In order for you to use Flair services, you must register to the Site. We require select personal information (including your full name, and e-mail address) as part of the form to enable proper operation of Flair.  If you decided to register using an integrated third-party social network, such as Facebook or LinkedIn, we will collect certain personal information from, such as your name, email address, authentication token, and other information you make available in the social network. You can revoke our access to your account on the social network at any time by updating your preferences in your account in the social network. You understand that we might not be able to perform some tasks and certain features will not be available to you if you remove our access to your account with the social network.

Regulatory Disclosures

We may disclose information about you to third parties to comply with any applicable law, regulation, or governmental request.

E-mail Communications

Flair will send you emails relating to updates on your investments and general Flair notifications. You can opt out of certain promotional emails at any time by clicking unsubscribe in the email that you received from us.


We make a reasonable effort to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information. We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records. However, we cannot warrant or guarantee the security of your information obtained through our Site.

Your Flair account information is protected by a password for your privacy and security. Protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer. We make every reasonable effort to ensure that personal information collected by us is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases, we may ask for a written request for correction.

Conditions of Use

If you decide to visit Flair Site, your visit and any possible dispute over privacy is subject to this Privacy Notice and our Terms of Service, including limitations on damages, arbitration of disputes, and application of Delaware State law. People under the age of 18 are not permitted to use Flair on their own, and so this Privacy Notice makes no provision for their use of the site.

Use of Photos

Flair and its partner organizations maintain the right to use voluntarily uploaded photographs, video recordings, and names in promotion of Flair offerings without further notice or compensation. Flair strives to include source credits on all photographs and video recordings where credits have been provided. User-generated content that violates copyrights laws will be removed promptly by Flair when notified.

Cookies and other Analytics Tools

Flair collects personal information passively and your interaction with our Site, by using tracking tools, cookies & IP addresses to track traffic analytics, to monitor visitors to our Site and to prevent fraud. This information is also used to improve the Site. We also use third party utilities like Google analytics on the Site.

Changes to this Privacy Notice

At our discretion, we may change our Privacy Notice to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our Site. Your continued use of our Site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this Privacy Notice, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended Privacy Notice.

Questions and Complaints

If you have a question or concern about any collection, use, or disclosure of personal information by Flair, or about a request for access to your own personal information, please contact us using the contact form or send us email to info@flairexchange.com.