This Privacy Policy explains how Fusion Atelier BV (“we”, “us”, “the Provider”), established in the Netherlands, processes personal data in connection with the Fluidis mobile application (the “App”). We are the data controller for the processing described here under the EU General Data Protection Regulation (GDPR) and applicable Dutch law (UAVG).
Fluidis addresses mature themes and carries a 16+ App Store age rating. You must be at least 16 years old (or the minimum age required by the App Store rating in your country, if higher) to use the App. In addition, where the law requires a minimum age for a service to process your personal data on the basis of your own consent (the “age of digital consent”, which is 16 in the Netherlands and between 13 and 16 across the EU), you must meet that age, or have a parent or guardian provide consent. We do not knowingly collect personal data from children below these ages. In line with the U.S. Children’s Online Privacy Protection Act (COPPA) and the GDPR’s protections for minors, if we learn that a person under the applicable age has provided us data, we will delete it. You can reach us using the details in the Contact section below.
| Context | Data | Leaves your device? | Purpose & legal basis |
|---|---|---|---|
| Exploring spectrums (core app) | Your answers and computed spectrum results; app settings. | No. Stays on your device. | Provide the core functionality. Legal basis: performance of our agreement with you (Art. 6(1)(b)); for data that reveals sexual orientation/sex life, your explicit consent to on-device processing (Art. 9(2)(a)). |
| AI Guidance (optional, opt-in) | Your anonymous spectrum results (no name, no email) are sent to generate a written reflection. | Yes. Secured cloud (to generate your guidance). | Generate the guidance you requested. Legal basis: explicit consent (Art. 6(1)(a) & Art. 9(2)(a)), given when you choose to unlock guidance. |
| Encrypted Vault (optional, opt-in) | An email address (which may be an alias you choose), an authentication password, and your synced spectrum progress. | Yes. Secured cloud storage (EU region). | Create your account and back up/restore your progress across devices. Legal basis: performance of our agreement (Art. 6(1)(b)); explicit consent for special-category content (Art. 9(2)(a)); security (legitimate interests, Art. 6(1)(f)). |
| Security & abuse prevention | Limited technical data needed to operate the Vault (e.g., authentication tokens, timestamps). | Yes. Secured cloud. | Keep accounts secure. Legal basis: legitimate interests (Art. 6(1)(f)). |
| Rewarded ads (optional to watch) | Device/region signals Google needs to serve an ad and prevent fraud. The advertising identifier (IDFA) and personalization are used only if you allow tracking via the App Tracking Transparency prompt; if you decline, ads are non-personalized. | Yes. Google AdMob (ad delivery). | Show an optional rewarded ad you can watch to unlock the Deep Dive reflection. Legal basis: legitimate interests for non-personalized ads (Art. 6(1)(f)); your consent for personalized ads (Art. 6(1)(a)), given via the ATT prompt and the in-app consent notice. |
We do not sell your personal data or share it with data brokers, and ads are personalized only if you have allowed tracking.
Information about gender identity, sexual orientation, or sex life is “special category” data requiring heightened protection. We process such data only where you have given explicit consent, by choosing to use the App, to unlock AI Guidance, and/or to save your results to the Vault. You can withdraw consent at any time (see “Your rights”); withdrawal does not affect processing that already took place.
When you request guidance, your de-identified spectrum results are sent to our AI provider (Google’s Generative Language / “Gemini” service) to produce a written reflection, which is returned to your device. We instruct the provider to process this data solely to generate your response. The guidance is generated by a language model, may be imperfect, and is not professional, medical, or psychological advice.
We share data only with service providers that process it on our behalf under contract:
| Provider | Service | Data |
|---|---|---|
| Google Firebase (Google Ireland / Google LLC) | Authentication & Realtime Database (Vault) | Email, password, synced progress |
| Google (Generative Language / Gemini) | AI guidance generation | Anonymous spectrum results |
| Google AdMob | Non-personalized ad delivery & fraud prevention | Coarse device/region signals; no IDFA, no cross-app profile |
| Apple | App distribution & (if used) crash reporting | As per Apple’s policies |
We aim to keep Vault data in the EU (europe-west1). Some providers (e.g.,
Google) may process data outside the European Economic Area. Where that occurs, transfers
are protected by appropriate safeguards such as the European Commission’s Standard
Contractual Clauses and/or an adequacy decision. You can request a copy of the relevant
safeguards from us.
We use industry-standard measures including encryption in transit (TLS), managed authentication, and access controls that restrict Vault data to the corresponding authenticated user. No method of transmission or storage is 100% secure, but we work to protect your data appropriately given its sensitivity.
Subject to the GDPR, you have the right to: access your data; request rectification or erasure; restrict or object to processing; request data portability; and withdraw consent at any time. You can erase your data directly in the App (Settings → erase), or contact us using the details in the Contact section below. We respond within one month. You also have the right to lodge a complaint with your supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).
If you are a California resident, you have rights under the CCPA/CPRA (to know, delete, correct, and opt out of “sale”/“sharing”). We do not sell or share personal information as those terms are defined. To make a request, use the details in the Contact section below.
We may update this policy to reflect changes in the App or the law. Material changes will be indicated by updating the “Last updated” date and, where appropriate, by an in-app notice.
Fusion Atelier BV
Amsterdam, the Netherlands
KvK: 96067977
Email: office@fusionatelier.nl