Privacy Policy

Effective Date: September 3, 2025

Flywheel Dynamix, Inc. ("Flywl," "we," "us," or "our") is committed to protecting the privacy of our users, partners, and customers. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including our cloud meta marketplace platform, website, and related services.

Information We Collect

We may collect the following types of personal data:

• Contact Information: Name, email address, phone number, and company information. Limited to the users who are registered from a company to access our service
• Account Information: Username, password, and account preferences.
• Transaction Data: Details of the products or services you purchase, including transactional details related to cloud marketplace activities.
• Usage Data: Data on how you interact with our platform, including login details, access times, pages visited, and features used.
• Technical Data: Information on your device (e.g., IP address, browser type, operating system) and platform performance metrics.
• Marketing and Communications Data: Preferences in receiving marketing materials and communications with us.

How We Use Your Information

We use the personal data collected for the following purposes:

• Platform Functionality and Optimization: To provide, maintain, and improve our cloud meta marketplace services, enabling buyers and sellers to interact effectively.
• Transactional Purposes: To process transactions, manage payments, and provide customer support related to cloud purchases and marketplace activities.
• Personalization and User Experience: To tailor our services based on user interactions, preferences, and feedback.
• Marketing and Communication: To send relevant information, promotional materials, and updates on new features or services, with your consent where required.
• Compliance and Legal Obligations: To comply with applicable laws, regulations, and contractual obligations.

Legal Basis for Processing Personal Data

Our processing of personal data is based on the following legal grounds:

• Performance of a Contract: Necessary to fulfill contractual obligations related to your use of our services.
• Legitimate Interests: To improve our services, secure our platform, and enhance user experience.
• Consent: Where required by law, we obtain your consent for specific processing, such as direct marketing.

International Data Transfers

As an organization headquartered in the United States with offices worldwide, we may transfer personal data to countries outside your country of residence. When transferring data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or other lawful mechanisms, to protect your data.

Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined in this policy, comply with our legal obligations, and resolve disputes. The specific retention period depends on the nature of the data and legal requirements.

Your Rights Under GDPR

If you are a resident of the European Economic Area (EEA), you have certain rights concerning your personal data, including:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Erasure: Request deletion of your data, subject to certain conditions.
• Right to Restrict Processing: Request limited processing of your data.
• Right to Data Portability: Receive your data in a structured format.
• Right to Object: Object to data processing based on legitimate interests or direct marketing.
• To exercise these rights, please contact us at info@flywl.com.

Privacy Rights for California Residents

If you reside in California, then in addition to the rights described above, you have been provided certain additional rights with respect to your Personal Information under the California Consumer Privacy Act (“CCPA”).

Right to Know

You have a right to request and know the following information about you in writing:

• Categories of Personal Information that we collect about you.
• The specific pieces of Personal Information we have collected about you.
• Purposes for which we collect your Personal Information.
• Sources from which we collect your Personal Information.
• Categories of Personal Information we have disclosed about you.
• Categories of third parties with whom we share your Personal Information.
• The categories of Personal Information we have sold and the categories of third parties to whom the information was sold (for clarity, we do not sell any Personal Information that we collect).

Right Against Discrimination

You have a right to receive the same services and price as other Users and cannot be discriminated against for exercising any of the rights.

Right to Access Your Personal Information

You have the right to request access to the categories of Personal Information that we have collected about you in the last twelve (12) months. We can provide you with a copy of your Personal Information (whole or part) within forty-five (45) days of receiving a written request from you.

Right to Ask for Deletion of Your Personal Information

You have the right to ask us to delete any Personal Information that we have collected about you without any additional cost by sending a written request. This right is subject to certain exceptions, and we may retain your Personal Information where we cannot verify your request, or where we need to retain the Personal Information to comply with legal obligations under the Applicable Data Protection Laws, etc.

Right to Correct

You have the right to request us to correct any inaccuracy or outdatedness of your Personal Information without any additional cost by sending a written request.

Right to Obtain a Copy

You have the right to request us to provide you with a copy of the Personal Information that you have previously shared with us.

Right to Opt-Out of Having Your Personal Information Sold

You have the right to opt-out of having your Personal Information sold. To clarify, we do not sell your Personal Information.

Shine the Light

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

Financial Incentives

We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s Personal Information.

How Do You Exercise Your Rights?

Users residing in California may exercise these rights by reaching out to us at Contact Details. Please note that we may ask you for proof of account ownership and/or identity before completing your request. We will only use such information to verify your identity, and for fraud prevention or security purposes.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this Section.

Security Measures

We employ technical and organizational measures to protect your personal data against unauthorized access, disclosure, or destruction. These measures are regularly reviewed to ensure data security and compliance with applicable data protection laws.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the revised policy on our website and updating the "Effective Date." Continued use of our services following the posting of changes indicates your acceptance of these changes.

Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Flywheel Dynamix, Inc.

39 Saddleback Place, Danville, CA 94506

info@flywl.com