Privacy Policy – Annex 1: Controllers

Last updated: July 17, 2026

Who controls your data

Two Flipper companies are responsible for different parts of the BUSY service. Each is independently responsible for the activities listed below. We coordinate among ourselves under an internal Intra-Group Cooperation Agreement (ICA). You may contact any of them through the channels in “How to exercise your rights” and we will route your request to the responsible entity.

This page is the structural reference for our Privacy Policy. The full Privacy Policy is at busy.app/legal/privacy/.

Entity table

Supervisory authority – how to read this column

If you are in the EU or EEA, you may lodge a complaint with the data protection authority of your country of habitual residence, place of work, or place of the alleged infringement (Art. 77 GDPR). In the UK, the competent authority is the Information Commissioner's Office (ICO).

A non-exhaustive list of EU/EEA supervisory authorities is published by the EDPB at edpb.europa.eu/about-edpb/about-edpb/members_en.

EU and UK representatives (Art. 27 GDPR / Art. 27 UK GDPR)

Flipper Devices, Inc. and Flipper FZCO are not established in the EU or UK. In accordance with Art. 27 GDPR and Art. 27 UK GDPR, each has appointed the following representatives, who may be contacted on all issues related to the processing of personal data:

• EU Representative: Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria

• UK Representative: Prighter Ltd, 20 Mortlake High Street, London, SW14 8JN, United Kingdom

Joint controllerships

This section lists joint controllerships under Art. 26 GDPR where Flipper jointly determines purposes and means with a third party for a specific processing operation.

• Meta Platforms Ireland Limited – for the collection and transmission of personal data via Meta Pixel and Conversions API on busy.app (joint controllership scope per CJEU Fashion ID C-40/17 and EDPB Guidelines 08/2020). The Meta Controller Addendum is incorporated by reference into Meta’s Business Tools Terms and was accepted upon integration of Meta Pixel.

Independent controller disclosures

The following third parties receive personal data from our website or app and process it as independent controllers for their own purposes. There is no Art. 26 joint controllership arrangement with these parties.

• Microsoft Ireland Operations Limited – independent controller for website-interaction data collected via the Microsoft Clarity script on busy.app. Flipper and Microsoft are each independent controllers for their respective purposes: Flipper for website analytics, Microsoft for product improvement, machine learning, and advertising. Microsoft’s processing is governed by the Microsoft Clarity Terms of Use and the Microsoft Products and Services DPA. See: privacy.microsoft.com/privacystatement.

How to exercise your rights

Regardless of which entity controls a specific processing activity, you can use a single intake channel:

• Email: privacy@busy.app

We will route your request internally to the responsible entity and respond within the statutory deadlines applicable to your jurisdiction (e.g. one month under GDPR / UK GDPR, extendable by two further months where necessary, taking account of complexity and number of requests, Art. 12(3) GDPR; 45 days under CCPA, extendable by 45 days where permitted).

You also retain the right to contact each controller directly through its respective supervisory authority (see entity table above).