Privacy Policy

Introduction

This Privacy Policy explains how Flockpass collects, uses, stores, shares, and protects personal data when Users access or use the Flockpass application, website, services, Creator tools, booking tools, advertising tools, and related features available through flockpassapp.com.

This Privacy Policy applies to Users, Creators, Creator applicants, visitors, and any person who interacts with Flockpass.

Data Controller

The data controller is:

Federico Del Prato
Via Zuretti 9
20125 Milan, Italy

Official domain: flockpassapp.com

Privacy contact: privacy@flockpassapp.com

Minimum Age

Flockpass is intended for Users aged 16 and above.

Users under 16 are not permitted to create an account or use the Application.

Users aged 16–17 are subject to additional protections described in the Minor Safety Policy.

Categories of Personal Data Collected

Flockpass may collect and process the following categories of personal data.

Account data:

name;
username;
email address;
phone number;
password or authentication credentials;
account settings;
profile photo;
profile information.

Creator application data:

Instagram handle;
follower count;
public Creator profile information;
identity verification information;
application review information;
content quality assessment;
safety and compliance assessment;
approval, rejection, suspension, or revocation status.

Booking and Event data:

Events viewed, saved, booked, or attended;
booking details;
Event date, time, location, and price;
attendance-related information;
cancellation, refund, dispute, or support information.

Payment-related data:

transaction amount;
payment status;
payment method type;
payment provider identifiers;
payout status;
refund status;
chargeback information;
tax or billing information where required.

Flockpass does not directly collect or store full payment card details. Payments are processed by third-party payment providers, including Stripe where available.

Safety and moderation data:

reports submitted by Users;
reported content or behavior;
blocked Users;
moderation notes;
account restrictions;
Event restrictions;
payout holds;
fraud checks;
safety investigations;
communications with support or safety teams.

Technical and device data:

IP address;
device type;
operating system;
app version;
browser type;
log data;
crash data;
approximate location derived from technical data;
security and fraud prevention signals.

Advertising, analytics, and marketing data:

advertising identifiers;
device identifiers;
app interactions;
ad impressions;
ad clicks;
video ad views;
campaign performance data;
attribution data;
analytics events;
consent status;
advertising preferences;
cookie or tracking preferences;
fraud prevention signals;
diagnostic information.

Communication data:

support requests;
legal notices;
safety reports;
feedback;
messages sent to Flockpass;
communications related to bookings, Events, refunds, disputes, or Creator applications.

Notification data:

push notification tokens;
notification preferences;
communication preferences.

Purposes of Processing

Flockpass processes personal data for the following purposes:

to create and manage User accounts;
to provide access to the Application;
to allow Users to discover, book, and attend Events;
to allow Creators to apply, create listings, receive bookings, and receive payouts;
to process payments, refunds, payouts, disputes, and chargebacks;
to verify Creator eligibility and identity;
to enforce age restrictions and minor safety protections;
to moderate content, Events, Users, and Creators;
to investigate reports, fraud, abuse, safety concerns, or violations;
to provide customer support;
to send service communications and notifications;
to send marketing communications where permitted;
to display personalized or non-personalized ads;
to measure advertising performance and campaign effectiveness;
to perform analytics and understand how Users interact with the Application;
to improve, secure, and maintain the Application;
to comply with legal, tax, accounting, regulatory, and law enforcement obligations;
to protect the rights, safety, and interests of Flockpass, Users, Creators, and third parties.

Legal Bases for Processing

Where applicable law requires a legal basis, Flockpass may process personal data on the following bases:

Contract:

to provide the Application, manage accounts, process bookings, enable Creator services, process payments, and deliver requested services.

Legal obligation:

to comply with tax, accounting, consumer protection, safety, regulatory, law enforcement, and other legal obligations.

Legitimate interests:

to protect platform safety, prevent fraud, moderate content, improve services, manage disputes, enforce policies, secure the Application, operate advertising and analytics where permitted, and protect Flockpass, Users, Creators, and third parties.

Consent:

where Flockpass relies on consent for specific processing activities, such as certain marketing communications, cookies, advertising identifiers, personalized advertising, or tracking technologies.

Vital interests or public interest:

where necessary to protect the safety of Users or others, report serious safety risks, or cooperate with competent authorities.

Advertising, Analytics, and Tracking Technologies

Flockpass may use advertising, analytics, attribution, measurement, and tracking technologies in connection with the Application, including Google AdMob, the Google Mobile Ads SDK, Google advertising services, analytics providers, advertising partners, mediation partners, cookies, pixels, SDKs, device identifiers, advertising identifiers, and similar technologies.

These technologies may collect, process, or share certain personal data and technical data, including, where applicable:

IP address;
device information;
operating system and app version;
advertising identifiers, including mobile advertising IDs where available;
device or account identifiers;
approximate location derived from IP address or device data;
app interactions, including launches, taps, views, ad impressions, ad clicks, video views, and other product interactions;
diagnostic information, including crash data, performance data, latency, app launch time, errors, and SDK-related information;
advertising performance data;
fraud prevention and security signals;
consent status and advertising preference information.

Flockpass may use this information for the following purposes:

to display ads within the Application;
to provide personalized or non-personalized advertising;
to measure ad performance and campaign effectiveness;
to prevent fraud, abuse, invalid traffic, and security incidents;
to perform analytics and understand how Users interact with the Application;
to improve the Application, advertising experience, and platform performance;
to comply with applicable laws, platform rules, and advertising partner requirements.

Flockpass may share or allow the collection of such data by Google, including through Google AdMob and the Google Mobile Ads SDK, and by other advertising, analytics, attribution, measurement, mediation, or technology partners used in connection with the Application.

Where required by applicable law or platform rules, Flockpass will request the User’s consent before using certain cookies, local storage, advertising identifiers, tracking technologies, personalized advertising tools, or cross-app/cross-site tracking technologies.

For Users located in the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions where consent is required, Flockpass may use a consent management platform or similar consent mechanism to collect, store, and manage the User’s advertising and privacy choices.

On iOS devices, where Flockpass or its partners engage in tracking as defined by Apple, Flockpass will request permission through Apple’s App Tracking Transparency framework before accessing the device’s advertising identifier or conducting tracking that requires such permission.

Users may manage, withdraw, or modify their consent and advertising preferences, where available, through the Application, consent banner, privacy settings, device settings, browser settings, Google advertising settings, Apple tracking settings, or other platform-level privacy controls.

If a User withdraws consent or disables certain tracking permissions, Flockpass may continue to show non-personalized ads or contextual ads where permitted by applicable law and platform rules.

Flockpass may apply additional restrictions to advertising personalization for Users aged 16–17, where required by applicable law, platform rules, advertising partner requirements, or the Minor Safety Policy.

Marketing Communications

Flockpass may send marketing communications, promotional messages, product updates, Creator updates, Event recommendations, or commercial communications where permitted by applicable law.

Where required, Flockpass will request the User’s consent before sending marketing communications.

Users may opt out of marketing communications by using unsubscribe tools, notification settings, device settings, or by contacting privacy@flockpassapp.com.

Service-related communications, safety notices, legal notices, booking updates, payment notices, and account-related messages may still be sent where necessary.

Sharing of Personal Data

Flockpass may share personal data with:

payment processors, including Stripe where available;
identity verification providers;
hosting and cloud infrastructure providers;
analytics and crash reporting providers;
advertising partners, including Google AdMob and Google Mobile Ads SDK-related partners;
attribution and measurement providers;
mediation partners;
customer support providers;
fraud prevention and security providers;
legal, accounting, tax, and compliance advisors;
app stores and platform providers;
competent authorities, regulators, courts, or law enforcement where required or permitted by law;
other Users or Creators where necessary to provide booking, Event, support, or safety features.

Google Play Store and Apple App Store Privacy Declarations

Flockpass may be distributed through third-party app stores, including Google Play Store and Apple App Store.

Flockpass is responsible for providing privacy and data-use declarations in Google Play Console, App Store Connect, and any other applicable store submission system.

These declarations must accurately reflect the actual behavior of the Application, including:

personal data collected directly by Flockpass;
personal data collected, processed, or shared by third-party SDKs integrated into the Application;
the presence and use of advertising SDKs, including Google AdMob and the Google Mobile Ads SDK;
the purposes of data collection and processing, including app functionality, analytics, advertising, personalized advertising, ad measurement, fraud prevention, security, support, and legal compliance;
whether data is shared with Google, advertising partners, analytics providers, payment providers, verification providers, hosting providers, or other third parties;
whether data is used for tracking, personalized advertising, analytics, attribution, or measurement;
whether data is encrypted in transit or otherwise protected through appropriate security measures;
whether Users may request access, correction, deletion, or other privacy rights;
whether Users may manage or withdraw consent for advertising, tracking, or marketing where required by law or platform rules.

Flockpass will use reasonable efforts to ensure that the privacy information published on Google Play Store, Apple App Store, and other distribution channels remains consistent with this Privacy Policy and with the actual data practices of the Application.

If Flockpass changes its use of advertising SDKs, analytics tools, tracking technologies, third-party partners, or data processing practices, Flockpass may update this Privacy Policy and the relevant store privacy declarations accordingly.

Creator and Event Visibility

Certain Creator profile information and Event listing information may be visible to Users of the Application.

Creators acknowledge that public-facing Creator information may include their name, profile photo, social media handle, Event descriptions, pricing, availability, and other information they choose to publish.

Safety, Reports, and Moderation

Flockpass may process reports, complaints, blocked-user information, moderation information, and safety-related data to protect Users, enforce policies, investigate violations, prevent fraud, and comply with legal obligations.

Where appropriate, Flockpass may retain safety and moderation records even after account deletion where necessary for legal, safety, fraud prevention, dispute resolution, or enforcement purposes.

International Transfers

Flockpass may process and store personal data in countries other than the User’s country of residence.

Where required by applicable law, Flockpass will use appropriate safeguards for international transfers, such as standard contractual clauses, adequacy decisions, or other legally recognized mechanisms.

Data Retention

Flockpass retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Application, manage accounts, process bookings and payments, resolve disputes, comply with legal obligations, enforce policies, prevent fraud, and protect safety.

Different retention periods may apply depending on the type of data.

Flockpass may retain certain records after account deletion where necessary for legal, tax, accounting, fraud prevention, chargeback, dispute, safety, or regulatory purposes.

User Rights

Depending on applicable law, Users may have the right to:

access their personal data;
request correction of inaccurate data;
request deletion of personal data;
request restriction of processing;
object to processing;
request data portability;
withdraw consent where processing is based on consent;
lodge a complaint with a competent data protection authority.

Requests may be submitted to privacy@flockpassapp.com.

Account Deletion

Users may request deletion of their account through the Application, where available, or by contacting privacy@flockpassapp.com.

Account deletion may not immediately delete all data where Flockpass must retain information for legal, tax, accounting, dispute, chargeback, fraud prevention, safety, or regulatory reasons.

Security

Flockpass uses reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

No system can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality of their login credentials.

Push Notifications and Communications

Flockpass may send service-related communications, booking updates, safety notices, policy updates, Event updates, support messages, and marketing communications where permitted.

Users may control optional push notifications through device settings or in-app settings where available.

Changes to this Privacy Policy

Flockpass may update this Privacy Policy from time to time.

Where required by law, Flockpass will notify Users of material changes.

Continued use of the Application after the effective date of the updated Privacy Policy indicates acknowledgment of the updated policy.

Contact

For privacy-related questions or requests, contact:

privacy@flockpassapp.com

DOCUMENT 3
MINOR SAFETY POLICY OF FLOCKPASS

Introduction

This Minor Safety Policy explains the additional safety rules and protections that apply to Users aged 16–17 on Flockpass.

This policy forms part of the Flockpass Terms and Conditions.

Minimum Age

Flockpass is intended for Users aged 16 and above.

Users under 16 are not permitted to create an account, access the Application, book Events, attend Events through the Application, or otherwise use Flockpass.

Flockpass may suspend or delete accounts where it reasonably believes that the User is under 16 or has provided false age information.

Users Aged 16–17

Users aged 16–17 may use Flockpass only subject to additional safety and privacy protections.

Flockpass may restrict features, visibility, communication tools, bookings, Event access, advertising personalization, or interactions for Users aged 16–17.

No Private Messaging between Adults and Users Aged 16–17

Private messaging between adults and Users aged 16–17 is not permitted.

Flockpass may disable, restrict, filter, monitor, or block messaging or interaction features where necessary to protect Users aged 16–17.

Adult-Only Events

Adult-only Events are hidden from Users aged 16–17.

Creators must clearly mark Events that are adult-only or otherwise unsuitable for Users aged 16–17.

Flockpass may remove, restrict, or reclassify Events that are not properly marked.

Minimum Age for Events

Creators must clearly indicate the minimum age required to attend each Event.

Creators are responsible for ensuring that Events are appropriate for the stated age group and comply with applicable laws, venue rules, access restrictions, alcohol rules, nightlife rules, safety requirements, and age restrictions.

Creator Responsibility toward Minors

Creators must not create, promote, or accept bookings for Events involving Users aged 16–17 where the Event would be inappropriate, unsafe, unlawful, misleading, or inconsistent with this Minor Safety Policy.

Creators must take reasonable steps to ensure that Event information, access rules, and age requirements are accurate and clear.

Prohibited Conduct

Flockpass has zero tolerance for:

child sexual abuse material;
grooming;
exploitation of minors;
coercion;
trafficking;
sexualized interactions involving minors;
harassment of minors;
stalking;
threats;
intimidation;
requests for sexual content from minors;
attempts to move minors to unsafe external communication channels;
any conduct that endangers or may endanger minors.

Any violation may result in immediate account suspension, account deletion, Event removal, booking cancellation, payout suspension, report to authorities, or other appropriate action.

Advertising and Minors

Flockpass may apply restrictions to personalized advertising, tracking, profiling, or advertising personalization for Users aged 16–17 where required by applicable law, platform rules, advertising partner requirements, or this Minor Safety Policy.

Reporting and Blocking

Users may report safety concerns, suspicious behavior, inappropriate content, unsafe Events, or violations of this Minor Safety Policy through the Application or by contacting safety@flockpassapp.com.

Flockpass may provide blocking or restriction tools to help Users limit interactions with other Users.

Moderation and Enforcement

Flockpass may review reports, restrict content, remove Events, suspend accounts, delete accounts, block payouts, cancel bookings, restrict visibility, or take any other action it considers appropriate to protect minors and platform safety.

Flockpass may prioritize reports involving minors.

Parent or Guardian Contact

Parents or guardians who believe that a person under 16 has created an account, or that a minor is at risk on Flockpass, may contact safety@flockpassapp.com.

Flockpass may request information necessary to verify and process the request.

Changes to this Policy

Flockpass may update this Minor Safety Policy from time to time.

Where required by law, Flockpass will notify Users of material changes.

DOCUMENT 4
CREATOR TERMS OF FLOCKPASS

Introduction

These Creator Terms apply to Users who apply for, obtain, or use Creator status on Flockpass.

These Creator Terms form part of the Flockpass Terms and Conditions.

By applying to become a Creator, publishing an Event, receiving bookings, or receiving payouts, the Creator agrees to these Creator Terms.

Creator Eligibility

To apply to become a Creator on Flockpass, Users must currently meet the following minimum requirement:

have at least 50,000 followers on Instagram at the time of application.

Having 50,000 Instagram followers is only a minimum eligibility threshold.

It does not guarantee approval.

Creator Application Review

All Creator applications are subject to manual review by the Flockpass team.

Flockpass evaluates applications based on factors including:

identity verification;
follower count;
content quality;
public profile review;
community safety;
platform fit;
compliance with Flockpass policies;
legal and safety considerations.

Flockpass reserves the right to approve, reject, suspend, or revoke Creator status at its sole discretion, even if the minimum follower requirement is met.

Approved Creators

Only approved Creators may create paid Events, receive bookings, and receive payouts through the Application.

Creator status is personal and may not be sold, assigned, transferred, rented, or shared without Flockpass’s written permission.

Flockpass may require additional verification, documentation, tax information, payment provider onboarding, or compliance checks before allowing a Creator to publish paid Events or receive payouts.

Independent Organizer Status

Creators are independent organizers.

Creators are not employees, agents, representatives, partners, joint venturers, or contractors of Flockpass.

Flockpass does not organize, host, supervise, manage, or control Creator Events.

Creators are solely responsible for the Events they create, publish, promote, sell, organize, manage, and carry out through Flockpass.

Creator Event Obligations

For each Event, Creators must provide accurate, complete, and up-to-date information, including where applicable:

Event title and description;
date, time, duration, and location;
minimum age requirement;
access requirements and entry rules;
expected activity or experience;
any relevant risks, restrictions, or safety information;
cancellation, rescheduling, or location-change information where applicable;
any rules imposed by the venue or applicable law.

Creators must ensure that Event descriptions are not false, misleading, incomplete, unsafe, unlawful, or deceptive.

Minimum Age for Events

Creators must clearly indicate the minimum age required to attend each Event.

Creators are responsible for ensuring that each Event is appropriate for the stated age group.

Adult-only Events must be clearly marked as adult-only and may be hidden from Users aged 16–17.

Safety and Legal Compliance

Creators are solely responsible for:

planning their Events safely;
managing participants;
complying with applicable laws and regulations;
complying with venue rules;
obtaining permits, licenses, authorizations, and approvals where required;
obtaining insurance where required or appropriate;
ensuring that the Event is lawful and suitable for the stated audience;
handling incidents, disputes, or issues that occur before, during, or after the Event.

Flockpass does not verify, guarantee, supervise, or assume responsibility for the legality, safety, quality, accessibility, or suitability of any Event, venue, Creator, or participant.

Prohibited Events

Creators must not create, promote, or organize Events that are unlawful, unsafe, fraudulent, misleading, exploitative, discriminatory, sexually exploitative, harmful to minors, or otherwise inconsistent with Flockpass policies.

Flockpass may remove Events, suspend Creator accounts, cancel bookings, block payouts, or take any other appropriate action where it believes that an Event may violate these Creator Terms or applicable law.

Payments and Platform Fee

Flockpass applies a platform fee equal to 15% of the relevant Creator Event transaction, unless otherwise stated in the Application or in a separate agreement with the Creator.

The platform fee is retained by Flockpass in consideration for access to the Application, marketplace tools, booking infrastructure, payment facilitation, moderation tools, platform services, and related operational services.

Payment Processing Fees and Taxes

Payments on Flockpass are processed through third-party payment providers, including Stripe where available.

Unless otherwise stated during checkout, any payment processing fees charged by Stripe or any other payment provider, as well as any applicable local taxes, duties, levies, or similar charges, shall be borne by the User and may be added to the final amount payable at checkout.

The User will be informed of the total amount payable before submitting the order, where required by applicable law.

Creator Tax Responsibility

Creators are solely responsible for determining, declaring, invoicing, collecting, reporting, and paying any taxes, duties, social security contributions, permits, licenses, or other fiscal obligations arising from their activity on Flockpass.

Creators are also responsible for issuing any invoices, receipts, tax documentation, or other documents required under applicable law.

Flockpass does not provide tax, accounting, or legal advice to Creators and shall not be responsible for any Creator’s tax position, reporting obligations, invoices, permits, licenses, or declarations.

Payouts

Only approved Creators may receive payouts through Flockpass.

Flockpass may delay, suspend, withhold, offset, or cancel payouts where necessary due to refunds, chargebacks, fraud checks, legal compliance, suspected violations of these Terms, User disputes, safety concerns, inaccurate Creator information, or requests from payment providers or competent authorities.

Creators acknowledge that payouts may be subject to payment provider requirements, identity verification, anti-fraud checks, anti-money laundering checks, tax documentation, and any other compliance measures required by Flockpass or its payment partners.

Content and Intellectual Property

Creators are responsible for ensuring that all content they upload, publish, or use in connection with their Events is lawful and does not infringe third-party rights.

Creators grant Flockpass the right to host, display, moderate, promote, and process Creator content as necessary to operate and promote the Application and related services.

Reviews, Reports, and Moderation

Flockpass may review Creator activity, Event listings, User reports, safety concerns, payment activity, and compliance information.

Flockpass may remove content, restrict Events, suspend accounts, revoke Creator status, block payouts, or take any other action it considers appropriate to protect Users, minors, Flockpass, or third parties.

Relationship with Other Policies

Creators must comply with:

the Terms and Conditions;
these Creator Terms;
the Privacy Policy;
the Minor Safety Policy;
the Refund & Cancellation Policy;
the Community Guidelines;
any other applicable Flockpass policy.

Changes to these Creator Terms

Flockpass may update these Creator Terms from time to time.

Continued use of Creator features after the effective date of updated Creator Terms constitutes acceptance of the updated terms.

DOCUMENT 5
REFUND & CANCELLATION POLICY OF FLOCKPASS

Introduction

This Refund & Cancellation Policy applies to bookings and purchases made through Flockpass.

This policy forms part of the Flockpass Terms and Conditions.

Role of Flockpass

Flockpass is a creator event platform and operates as an intermediary between Users and independent Creators.

Flockpass does not organize, host, supervise, manage, or control the Events listed on the Application.

Creators are independent organizers and are responsible for their own Events.

Refunds and Cancellation Rights

Refunds, cancellations, withdrawal rights, cancellation rights, right of regret, and any exceptions are governed by the Terms and Conditions of Flockpass, including the section titled “User Rights”.

Due to the nature of the offering, including access to creator-led Events and experiences, Users acknowledge and accept that withdrawal, cancellation, or refund rights may not apply in all cases, except where mandatory applicable law provides otherwise.

Mandatory Consumer Rights

Nothing in this Refund & Cancellation Policy limits any mandatory consumer rights that cannot be excluded under applicable law.

Users may have different mandatory rights depending on their country of residence, including in the European Union, United Kingdom, Brazil, Australia, or other jurisdictions.

If applicable consumer law grants Users higher mandatory protection than this policy, such mandatory protection shall prevail.

Case-by-Case Review

Flockpass may review refund or cancellation requests on a case-by-case basis where required by:

applicable law;
payment provider rules;
fraud prevention requirements;
safety concerns;
chargeback management;
platform integrity reasons;
legal or regulatory obligations.

Payment Provider Processing

Refunds may be affected by payment provider processing times, payment method limitations, taxes, currency conversion, chargebacks, or other technical factors outside Flockpass’s direct control.

Flockpass is not responsible for delays caused by payment providers, banks, card networks, app stores, or other third-party services.

Contact

For refund or cancellation questions, Users may contact:

support@flockpassapp.com

Privacy Policy

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