Privacy Policy

Effective Date: April 19, 2026

1. Introduction

This Privacy Policy explains how Flappd Tech Inc., doing business as Gluten App (also known as Gluten.App) ("Gluten App," "we," "us," or "our"), collects, uses, discloses, and protects personal information when you use our website and related web-based services available at https://gluten.app and our related subdomains (collectively, the "Service").

This Privacy Policy applies to our website and subdomains. If we launch or provide separate mobile application experiences, we may provide additional or supplemental privacy disclosures for those services.

By using the Service, you acknowledge that your personal information will be handled as described in this Privacy Policy.

2. Who We Are

Controller / Business: Flappd Tech Inc. doing business as Gluten App (also known as Gluten.App)

Privacy Contact: Email: support@gluten.app Phone: (623) 302-6232 Address: 114 William Booth Ave, Newmarket, ON L3X 3B2, Canada

3. Scope of This Policy

This Privacy Policy applies to personal information we collect through:

• https://gluten.app and our subdomains • Account creation and account use • Favorites, reviews, listings, and submissions • Claim and verification flows for businesses • Support, waitlist, and contact forms • Newsletters and marketing communications • Location-based website features • Any other web-based interactions with the Service

4. Personal Information We Collect

A. Information You Provide Directly

Depending on how you use the Service, you may provide: first name and last name, email address, password or authentication credentials, city, country, and postal code, phone number, physical address, business name, profile photo, saved preferences including dietary preference, reviews, ratings, comments and other user-generated content, information submitted through support or contact forms, and information submitted when claiming or verifying a business profile.

B. Information Related to Dietary Preferences

You may choose to provide dietary preference or similar information through profile settings, saved preferences, submissions, reviews, or support interactions. Saved dietary information is private by default unless you choose to make it publicly visible.

C. Information Collected Automatically

When you use the Service, we may automatically collect: IP address, approximate location inferred from IP address, device, browser, operating system and related technical information, referral URLs and campaign parameters, pages viewed and browsing patterns within the Service, on-site search history and interactions, cookie, local storage, and similar technology data, and analytics and measurement data.

D. Information Related to Public Profiles and Contributions

If you post reviews or otherwise interact publicly, some information may be visible to others, such as username, display name, profile photo, city and country, reviews and ratings, and any saved dietary information you choose to display publicly.

E. Information from Business Owners and Representatives

If you claim, verify, or manage a business listing, we may collect: name and contact details of the owner or representative, business name and related details, gluten-free or related operational practices, owner notes and offerings, uploaded images and media, consent preferences relating to marketing, and verification materials.

F. Information from Third Parties

We may receive information from service providers and partners such as authentication and hosting providers, analytics providers, payment processors, and communications, mapping, fraud prevention, and support providers.

5. How We Use Personal Information

We may use personal information to:

• Provide, operate, maintain, and improve the Service • Create and manage accounts and authenticate users • Provide favorites, saved preferences, search, and related features • Publish and manage reviews, ratings, submissions, and listings • Personalize the website experience, content, and recommendations • Send transactional, service, and account-related communications • Send newsletters and marketing communications where you have consented or where otherwise permitted by law • Understand website traffic, engagement, and user needs • Respond to support requests, inquiries, and feedback • Process business listing claims and verification submissions • Protect the Service, users, and the public • Detect, investigate, prevent, and address fraud, abuse, and security issues • Comply with legal, tax, accounting, and regulatory obligations • Establish, exercise, or defend legal claims

6. Legal Bases for Processing (EEA, UK, and Similar Jurisdictions)

Where required by applicable law, we process personal information on one or more of the following legal bases:

• Consent — for marketing emails, certain cookie-based analytics, and certain optional profile or visibility settings • Performance of a contract — providing your account, favorites, reviews, search, business tools, and related Service functionality • Legitimate interests — improving the Service, understanding usage, supporting security, preventing fraud, and maintaining platform integrity • Legal obligations — compliance with applicable laws, regulations, legal requests, tax obligations, and recordkeeping requirements • Establishment, exercise, or defense of legal claims — where relevant

7. Cookies and Similar Technologies

We use cookies, local storage, pixels, tags, scripts, and similar technologies to operate the Service and understand how it is used.

Depending on the configuration of the Service and your choices, we may use categories such as: Necessary, Analytics & Measurement, Replay & User Experience Insights, Functional, and Advertising & Retargeting.

We use a consent mechanism that allows users to manage non-essential technologies where required by law. You can update your preferences at any time through Your Privacy Choices or a similar cookie/settings link we make available on the Service.

Non-essential technologies may be disabled by default for certain users or regions unless and until consent is provided, where required by law.

8. Analytics, Replay, and Future Advertising Tools

We may use analytics, measurement, replay, and similar tools to understand website traffic, user interactions, and service performance.

We may also, now or in the future, use advertising and retargeting technologies to measure campaign performance, improve marketing relevance, and support our business operations. The specific providers and technologies we use may change over time as the Service evolves.

Where required by law, such tools will be subject to user choice through our consent and privacy controls.

9. How We Disclose Personal Information

We may disclose personal information to:

• Service providers and vendors that support hosting, infrastructure, authentication, analytics, communications, payments, maps, fraud prevention, and related operations • Employees, personnel, and advisors who need access for legitimate business purposes • Business owners or representatives in connection with claim, verification, or listing-management features • Law enforcement, regulators, courts, or other authorities when required by law or reasonably necessary to protect rights, safety, or security • A buyer, investor, successor, or other relevant party in connection with a merger, acquisition, reorganization, or similar transaction, subject to appropriate protections

We do not sell personal information for money in the traditional sense.

10. International Transfers

We may process and store personal information in the United States and other jurisdictions where we or our service providers operate.

As a result, your information may be transferred to and processed outside your country, province, state, or region of residence, including in jurisdictions that may not provide the same level of data protection as your home jurisdiction. Where required by law, we will use appropriate safeguards for such transfers.

11. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Service, maintain account functionality, preserve public content, comply with legal obligations, resolve disputes, and enforce our terms.

For example: • Account and support information may be retained while your account is active and for a reasonable period afterward • Reviews, submissions, listings, media, and other public content may remain available after account deletion where necessary to preserve the integrity or historical record of the Service • Analytics and technical logs may be retained in aggregated or de-identified form • Legal, tax, accounting, fraud, and dispute-related records may be retained for longer periods where required or permitted by law

12. Account Deletion and Public Content

You may request account deletion through your account settings or by contacting us at support@gluten.app. Deletion requests may be handled in scheduled processing cycles.

Even after account deletion, we may retain certain information where reasonably necessary to: comply with legal, tax, accounting, and regulatory obligations; protect against fraud, abuse, or security threats; maintain records relating to disputes or enforcement; preserve public reviews, ratings, listings, media, and other content that supports the Service; and maintain platform integrity and moderation records.

13. Public Content and User-Generated Content

If you submit reviews, ratings, comments, images, listings, business content, or other user-generated content, that content may be publicly displayed on the Service and may remain publicly accessible even after your account is deleted or deactivated, subject to our rights, legal obligations, moderation decisions, and operational needs.

Please do not submit information you do not want to be public.

14. Business Owners and Representatives

If you are a business owner or representative and submit claim, verification, listing, or promotional information to us:

• We may use that information to verify your relationship with the business • We may display business information, operational details, media, owner notes, menus, or offerings on the Service • We may use communications and submitted materials to support listing management, editorial review, business verification, and platform operations • Where you separately consent, we may use submitted business content for marketing, promotional, or editorial platform purposes • By submitting content, you represent that you have the necessary rights or permissions to submit it

15. Your Rights and Choices

Depending on where you live and subject to applicable law, you may have rights to:

• Access personal information we hold about you • Request correction of inaccurate information • Request deletion of your personal information • Object to or restrict certain processing • Withdraw consent where processing is based on consent • Request portability of certain information • Opt out of certain marketing communications • Manage cookies and similar technologies through Your Privacy Choices • Exercise applicable state, provincial, national, or regional privacy rights

To exercise your rights, contact us at support@gluten.app. We may need to verify your identity before processing certain requests. Marketing emails also include an unsubscribe link you can use at any time.

16. California Privacy Notice

If you are a California resident, you may have rights under applicable California privacy law, including the right to:

• Know what personal information we collect, use, disclose, or otherwise process • Request deletion of certain personal information • Request correction of inaccurate personal information • Opt out of certain processing that may constitute a sale or sharing of personal information under California law • Limit the use or disclosure of certain sensitive personal information, where applicable • Not be discriminated against for exercising applicable privacy rights

We do not sell personal information for money in the traditional sense. If we use advertising or retargeting technologies in a way that constitutes "sharing" under California law, we will provide notice and a method to opt out through Your Privacy Choices.

You may submit California privacy requests by contacting support@gluten.app.

17. Do Not Track

Our website does not currently respond to browser Do Not Track signals. Where required by law, we will honor privacy choices made available through our consent and privacy controls.

18. Children

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from an individual under 18, we will take reasonable steps to delete it.

19. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no website, system, storage environment, or method of internet transmission is completely secure, and we cannot guarantee absolute security.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the Effective Date above. If required by law, we will provide additional notice of material changes.

21. Contact Us

If you have questions, concerns, or privacy requests, please contact:

Gluten App Team Email: support@gluten.app Phone: (623) 302-6232 Address: 114 William Booth Ave, Newmarket, ON L3X 3B2, Canada