Privacy Policy – Annex 1: Controllers
Last updated: 3 June 2026
Who controls your data
Three 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/policies/privacy-policy.
Entity table
| # | Scope / Purpose | Entity | Address | Supervisory Authority |
|---|---|---|---|---|
| 1 | Hardware sales, checkout and payments, order fulfilment, warranty and returns (busy.app storefront) | Flipper Devices, Inc. (Delaware, USA) | 2803 Philadelphia Pike, Suite B #551, Claymont, DE 19703, USA | US: California Privacy Protection Agency and state Attorneys General (as applicable to your state of residence); FTC for federal unfair/deceptive practices. EU: the supervisory authority of your country of residence. UK: ICO. |
| 2 | Customer support tied to orders, RMA processing, account-related communications | Flipper Devices, Inc. | as above | as above |
| 3 | Web analytics and marketing on flipper.net and cdn.flipperzero.one (legacy domains) | Flipper Devices, Inc. | as above | as above |
| 4 | Marketing email (Brevo) and paid acquisition (Meta Ads, Google Ads) – transitional, see Note A | Flipper Devices, Inc. | as above | as above |
| 5 | BUSY app account, BUSY Cloud sync, device pairing, push notifications | Flipper FZCO (Dubai Silicon Oasis, UAE) | Dubai Silicon Oasis, P.O. Box 451495, Dubai, UAE | UAE: UAE Data Office. EU: the supervisory authority of your country of residence. UK: ICO. |
| 6 | Web analytics on busy.app and in-app analytics in the BUSY app | Flipper FZCO | as above | as above |
| 7 | Product telemetry, crash reporting, diagnostics (self-hosted Sentry / PostHog) – provisional, see Note B | Flipper FZCO | as above | as above |
| 8 | Google Calendar integration (BUSY app) | Flipper FZCO | as above | as above |
Notes
- Note A – Marketing controller allocation may shift as we evolve our marketing infrastructure.We review this Annex periodically and on material change.
- Note B – Telemetry controller – telemetry infrastructure (PostHog, Sentry) is self-hosted by FZCO. If a joint determination by Inc. and FZCO is later confirmed for any telemetry processing, an Art. 26 joint controllership notice will be added.
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). Flipper Technologies Ltd has its establishment in the UK (8 Soames Walk, London, England, SE10 0AX), where the Information Commissioner's Office (ICO) is competent.
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 / UK GDPR)
| Entity | EU Art. 27 Representative | UK Art. 27 Representative |
|---|---|---|
| Flipper Devices, Inc. | [TBD]¹ | Flipper Technologies Ltd² |
| Flipper FZCO | [TBD] | Flipper Technologies Ltd |
| Flipper Technologies Ltd | n/a – UK establishment | n/a – UK establishment |
- ¹ External Art. 27 representative engagement is being finalised. Until appointment, EU data subjects may use the contact channels in Section 12 of the Privacy Policy.
- ² Ltd acts as UK Art. 27 representative for Inc. and FZCO for UK personal data.
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. Each arrangement below was accepted when we began using the respective platform’s business tools.
- Meta Platforms Ireland Limited – for the collection and transmission of personal data via Meta Pixel and Conversions API on busy.app and busy.app (joint controllership scope per CJEUFashion 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.
- TikTok Technology Limited – for the collection and transmission of engagement data via the TikTok Pixel and Events API on busy.app (joint controllership scope per CJEU Fashion ID C-40/17, formalized by TikTok’s published Joint Controller Addendum). The joint controller arrangement is incorporated into TikTok’s Business Products (Data) Terms and Jurisdiction-Specific Terms, accepted upon registration in TikTok Ads Manager.
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@flipper.net
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).