Flybi — Terms of Service / End User Licence Agreement (EULA)

Appropriate for the current closed-beta scale. This document grounds each obligation in the source instrument (Regulation (EU) 2022/2065 — the Digital Services Act ("DSA"), the Apple App Store Review Guidelines, and the Google Play Developer Program Policies) and cites the relevant article/section inline. It is not legal advice and is not a substitute for a professional review — a lawyer review is recommended as the user base and data processing grow, and is advisable before enabling ID/biometric verification.

Service: Flybi — a mobile social-connection / anti-loneliness application for adults aged 18–35, in which "the people are the content": a finite feed of real personalities near you, with no posts to publish and nothing to chase. Provider: Nicholas Gerster Toft Simonsen, operating Flybi as a registered Danish enkeltmandsvirksomhed (sole proprietorship), a micro-enterprise within the meaning of Commission Recommendation 2003/361/EC, established in Aarhus, Denmark (EU). Postal address: The registered business address is on file with the Danish Business Authority (Erhvervsstyrelsen) under CVR 46574184; contact is by email at the address below. Business registration / CVR number: CVR 46574184 (registered Danish enkeltmandsvirksomhed; VAT-registered (MOMS, quarterly returns) since 19 June 2026). Contact: support@flybi.app (canonical value: LegalLinks.supportEmail in lib/core/constants/legal_links.dart) Privacy Policy: https://flybi.app/privacy Version: Terms version 1 (corresponds to kCurrentTermsVersion in lib/core/constants/legal_links.dart). Last updated: 20 September 2026 — Sections 4.3 and 6.1 now describe the automatic photo check (#1635) and what a report about one photo does: enough different people reporting the same photo hides that photo while a person decides, temporarily and reversibly, without restricting the account (#1651). Section 6.1 and Section 7.2 add the cooldown, a stated number of days without posting that ends by itself. Section 4 links the plain-language Community Guidelines. Sections 4.1, 6 and 6.2 no longer promise a review within 24 hours: the commitments to review every report, to remove upheld content and eject the user, and to handle child-safety and imminent-harm reports first are unchanged and unconditional — what has gone is a speed we could not guarantee. The terms version is unchanged (kCurrentTermsVersion), so acceptance is not re-collected: no version has yet bound anyone, because Flybi has not launched publicly. Before that, 7 August 2026.

These Terms are presented in clear, plain, intelligible, user-friendly and unambiguous language and are published in an easily accessible and machine-readable format (Markdown / HTML), in accordance with DSA Art 14(1).

1. Acceptance of these Terms

1.1 By creating a Flybi account you enter into a binding agreement with the Provider. During registration you must tick the acceptance checkbox confirming that you have read and agree to these Terms (incl. this EULA) and have read the Privacy Policy. The version you accept and the time of acceptance are recorded against your account (termsAcceptedVersion / termsAcceptedAt).

1.2 If you do not agree to these Terms, do not create an account or use Flybi.

1.3 Significant changes. We will inform you of any significant change to these Terms (DSA Art 14(2)). When the legally binding terms change, the terms version is incremented and your acceptance is re-collected before continued use. Continuing to use Flybi after a change takes effect means you accept the updated Terms.

1.4 App-store EULA. Flybi is distributed via the Apple App Store and Google Play. Where you obtained Flybi through Apple, Apple's standard Licensed Application End User Licence Agreement also applies and, to the extent of any conflict on app-licence matters, supplements these Terms; the App-Store-specific provisions in Section 11 form part of this agreement.

2. Eligibility — 18+ only

2.1 Flybi is strictly for adults aged 18 and over. You must be at least 18 years old to create an account or use the service. This is enforced by an in-app age gate based on a self-declared date of birth captured during onboarding (stored as dateOfBirth). We describe this accurately so you know what it is: it is self-declaration, not documentary or biometric age verification. We do not currently check identity documents, run age-estimation, or verify your age against any third-party source, and we do not claim to. (Apple App Store Review Guideline 1.2; Google Play Target Audience & Content policy, answer 9867159 — apps in our Play category must target 18-and-over only; Google Play content-rating / IARC questionnaire, answer 9859655.)

2.2 If we determine that you are under 18, or that you provided a false date of birth, we will suspend or terminate your account and erase associated personal data, subject to any legal retention obligation.

2.3 You must provide accurate registration information, keep your credentials secure, and you are responsible for activity under your account. Sign-in is via email, Google, or Apple.

2.4 Flybi launches in the Aarhus, Denmark area and expands geographically over time. Availability in your area is not guaranteed.

3. The licence we grant you

3.1 Subject to your compliance with these Terms, the Provider grants you a personal, limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to install and use Flybi on a device you own or control, for your own personal, non-commercial use.

3.2 You must not: copy, modify, reverse-engineer, decompile or disassemble the app except as permitted by applicable law; rent, lease, lend, sell, redistribute or sublicense it; remove proprietary notices; circumvent security, rate-limiting, App Check, or access controls; use bots, scrapers or automated means to access the service or harvest other users' data; or use Flybi to build a competing product.

4. Acceptable use — community rules

You are solely responsible for the content you provide — your display name, bio, profile photos, interest "tags" (including secret tags), and chat messages ("User Content"). It is the Provider's responsibility to remove content that violates these Terms or our community standards (Apple App Store Review Guideline 1.2). The same rules are published in plain language, with what leads to what, as our Community Guidelines — they are part of these Terms, and where the plainer wording and this Section differ, this Section governs.

4.1 Zero-tolerance for objectionable content and abusive users

There is zero tolerance for objectionable content and for abusive users on Flybi. This is an absolute rule, not a target. (Apple App Store Review Guideline 1.2 — the de-facto reviewer requirement that a UGC app's EULA contain a zero-tolerance clause for objectionable content and abusive users, agreed to before a user can participate.)

By accepting these Terms you accept, and we commit to, the following:

• We filter. Display names, bios, tag titles, tag descriptions and room names are screened by an automated filter at the point of submission, before they are published (Section 4.3). Chat messages are not filtered; in chat, reporting and blocking (below) are the controls.
• You can report. Every user and every non-user can report objectionable content and abusive behaviour (Section 6.2).
• You can block. Every user can block another user directly in the app (Section 6.3).
• We act. Every report of objectionable content is reviewed by a person and, where the report is upheld, we remove the offending content and eject the user who provided it. Reports involving child safety, threats to life or safety, and other imminent harm are handled ahead of everything else (Section 6.1). We do not publish a time by which a report is reviewed: we would rather commit to what we do than to a speed we cannot guarantee as a one-person team, and the commitments in this Section are not conditioned on one.

You agree not to create, upload, transmit, display or share any content, and not to engage in any conduct, that:

• is sexually explicit, pornographic, or sexually objectifies others (rating, ranking or scoring people on their appearance is prohibited);
• harasses, bullies, threatens, stalks, intimidates or defames any person;
• is hateful or discriminatory on the basis of race, ethnicity, national origin, religion, disability, sex, gender identity, sexual orientation, age or any other protected characteristic;
• depicts, promotes or facilitates violence, self-harm, or threats to the life or safety of any person;
• constitutes child sexual abuse and exploitation (CSAE) in any form, including child sexual abuse material (CSAM) — strictly prohibited and reported to the authorities (see the dedicated statement below and Sections 7 and 8);
• is illegal under EU or applicable national law, or facilitates illegal acts (incl. fraud, the sale of illegal or regulated goods, or infringement of intellectual-property or privacy rights);
• impersonates any person or misrepresents your identity or affiliation;
• is spam, a scam, a solicitation, or off-platform commercial advertising;
• discloses another person's private or identifying information without consent ("doxxing"), including precise location;
• contains malware, or attempts to compromise, overload or interfere with the service or other users' devices.

Child sexual abuse and exploitation (CSAE) — explicitly and absolutely prohibited. Flybi prohibits child sexual abuse and exploitation without exception. Specifically, you must not use Flybi to create, upload, transmit, store, share, request or solicit any content or conduct that: depicts, describes, promotes or facilitates the sexual abuse or sexual exploitation of a minor; constitutes child sexual abuse material (CSAM) in any form; sexualises a minor; or grooms, lures, sexually extorts, trafficks or otherwise endangers a minor, or attempts to make or arrange contact with a minor for any of those purposes. Breach results in immediate removal of the content, permanent termination of the account, preservation of evidence, and reporting to law enforcement (Section 8). Our full child-safety standards, including how to report a child-safety concern and our designated child-safety point of contact, are published at Flybi Child Safety Standards. (Google Play Child Safety Standards policy — the app must explicitly prohibit CSAE in publicly accessible standards, of which these Terms are one.)

4.2 No prohibited app-category behaviour

Flybi is not, and may not be used as, a platform for pornography, random/anonymous/"Chatroulette"-style chat, appearance-rating or objectification of people, physical threats, or bullying. Such uses are not permitted and are grounds for immediate removal of the offending content and account (Apple App Store Review Guideline 1.2).

4.3 Automated input filter

To enforce these rules, Flybi applies an automated disallowed-language text filter to display names, bios, tag titles, tag descriptions and room names at the point of entry, which blocks the worst-offending content before it is published. Chat messages are not screened by this filter; in chat, the controls are reporting (Section 6.2) and blocking (Section 6.3). This is a content-moderation tool within the meaning of DSA Art 14(1) and is described further in Section 6. Photos are not screened by this text filter; they are moderated on report and on review (Section 6).

Automated photo check. Your profile photo and the photos on your tags are checked automatically after upload by an image classifier (Google Cloud Vision SafeSearch) that rates how likely a photo is to be sexually explicit or violent. The check does not block or remove a photo for what it shows. A photo it marks stays up and is reviewed by a person, who decides whether it breaches these Terms (Section 4.1); only then is it removed, and the app tells you why, where the photo was, and by notification if you allow them. Separately, a photo link that does not point at a photo uploaded through the app (for example, a link to another website) is removed automatically, with no person involved; this is a technical rule about where the link points, not a judgement about what the photo shows, and you can upload the photo in the app instead. Like the text filter, the check is a content-moderation tool within the meaning of DSA Art 14(1) (Section 6.1). If you think a photo was removed by mistake, write to support@flybi.app. Photos sent in chat are not checked by it; in chat, reporting and blocking are the controls.

Reports about one photo. You can report a single photo, from the photo itself. A report about one photo acts on that photo, not on the account behind it. Where several different people report the same photo, that photo is hidden while a person looks at it — how many people it takes depends on what the automatic photo check had already said about it, and it is never fewer than two. A hide is temporary and reversible: the photo is not deleted, nothing about the reported account changes, and a person then decides whether the photo goes back up or is removed under Section 4.1, with a statement of reasons either way (Section 6.4). Hiding a photo makes its existing link stop working, so a saved copy of that link stops resolving and a restored photo carries a new one. We do not state a time by which a hidden photo is looked at; what we state is that a person decides, and that the photo is hidden rather than deleted until they do.

4.4 Genuine, accurate participation

Because "the people are the content," you must represent yourself authentically. Provide a genuine profile; do not create accounts for others, operate multiple accounts to evade enforcement, or use another person's likeness.

5. Location data and the "hot / cold" game (consent and minimisation)

5.1 Flybi processes location to power discovery and certain features. Our handling is designed to minimise what is collected and stored (Google Play minimum-scope and prominent-disclosure rules, answers 17033915 and 11150561; Apple Guideline 5.1.1(iii) data minimisation):

• For discovery, your location is stored as two coarse geohash cells (a ~39 km geohash4 and a finer ~1.2 km geohash6) and as the precise latitude/longitude point they are derived from, which is kept so we can compute exact distances to the people in your ring. It is not a continuously broadcast position, and other people are never shown your exact coordinates or address — only a rough distance. The Privacy Policy §3.4 sets out exactly what is stored and where.
• You can erase your stored location at any time, in Profile → Location → "Erase my stored location". That deletes the stored latitude/longitude and both geohash cells everywhere they are held. Turning the location switch off in the same screen withdraws your consent and erases the same fields, so nothing is left behind from before you switched it off.
• Live, fine-grained GPS location is only processed during an active mutual "hot / cold" game between two users who have both consented to play (one user invites; the other must accept before the game becomes active). Live location during the game is used solely to power the warmer/colder proximity signal and is cleared when the game ends or is quit. It is not retained as a location history.

5.2 Before any device location permission is requested, the app shows an in-context disclosure explaining why location is used, what is collected, and how it is used — and you can decline (Google Play prominent-disclosure & consent, answer 11150561). Declining location does not bar you from the service except for features that inherently require it.

5.3 Full details of location and all other processing — categories, purposes, retention and your rights — are in the Privacy Policy, which forms part of your relationship with us. These Terms do not replace it.

6. Content moderation — rules, tools and procedures (DSA Art 14)

This section states, in clear and plain language, the restrictions we impose on the content you provide and the policies, procedures, measures and tools we use for content moderation — including algorithmic decision-making and human review, as required by DSA Art 14(1). It also describes the voluntary review route we offer if you disagree with a decision (Section 6.5).

How we apply these rules. We apply and enforce these restrictions diligently, objectively and proportionately, and with due regard to the fundamental rights — including the freedom of expression and information — of all parties involved (DSA Art 14(4)). In practice this means: we act on the rules written in Section 4 and not on personal taste; we take the least restrictive measure that addresses the problem (a warning or the removal of one field or message before a suspension, and a suspension before a permanent ban), reserving immediate termination for egregious or repeated breaches; we treat like cases alike; we record the reason for every action; and we tell you what we did and why (Section 6.4) so you can contest it (Section 6.5).

The operational detail of how reports are triaged and actioned is maintained in our internal Moderation Runbook (referenced, not duplicated here): a notice-and-action workflow under which each report is reviewed, an action is taken or declined, and a statement of reasons is recorded. We hold ourselves to internal working targets for that review; they are ours to manage and are deliberately not published as a promise to you.

6.1 What we moderate and the tools we use

• What is restricted. The content and conduct rules are in Section 4. They apply to everything you provide: display name, bio, profile photos, interest tags (including secret tags), and chat messages.
• Automated input filtering (algorithmic decision-making). A disallowed-language text filter automatically screens display names, bios, tag titles, tag descriptions and room names at the point of submission and blocks content that breaches Section 4. Chat messages are not screened by it. This is an automated decision taken without human involvement, applied before publication, and is disclosed here per DSA Art 14(1). It is a keyword-based filter: it is deliberately narrow, it will miss things, and it can occasionally block wording that was not meant to breach the rules. It is a first line of defence, not a judgement about you.
• Human review. Every decision that restricts an existing account or an existing item of content — hiding or removing content, suspending an account, or terminating an account — is taken by a human moderator (in practice, the founder), with two exceptions, both stated in the bullets below and both about content rather than about an account: a photo link that does not point at a photo uploaded through the app is removed automatically, which is a technical rule about where a link points; and a photo that several different people report is hidden automatically while a person looks at it, which is temporary, reversible, confined to that one photo, and always followed by a person's decision. We do not otherwise rely solely on automated tools to decide these outcomes. Where an automated tool has been involved in a decision at any stage, we say so in the statement of reasons (Section 6.4, DSA Art 17(3)).
• Automated photo check (automated detection, human decision). Profile and tag photos are checked automatically as described in Section 4.3 (chat photos are not). The check only detects: it marks photos for review. Every decision to remove a photo for what it shows is taken by a person, like every other restriction above, and we tell you in the app, and by notification if you allow them. The one removal made without a person is of a photo link that does not point at a photo uploaded through the app: that link is removed automatically, as a technical rule about where a link points, never as a judgement of the photo — and you can upload the photo in the app instead. You can ask for a person to look at any removal at support@flybi.app (Section 13.2).
• Reports on one photo, and the temporary hide (automated measure, human decision). A report can name a single photo. The reports are counted per photo and per reporter, so one person cannot hide a photo by reporting it repeatedly, and reports from an account whose reports have repeatedly been dismissed as unfounded stop counting towards the hide (they are still read). When enough different people — never fewer than two — report the same photo, the photo is hidden pending review. This is an automated measure, so we say so here and in the statement of reasons (DSA Art 17(3)(c)): its duration is "until a person decides", its scope is that one photo, and it does not restrict the account in any way. A person then either restores the photo, in which case the same reporters cannot trigger a second hide, or removes it under Section 4.1 with a statement of reasons. We publish no target for how quickly a hidden photo is looked at, here or anywhere else; the hide is what protects other users while a person gets to it.
• No general monitoring, no automated profiling for moderation. Apart from the automated input filter and the automated photo check described above, we do not proactively scan or monitor user content, and we do not use profiling or automated risk-scoring of users to make moderation decisions. Moderation is triggered by a report under Section 6.2, by an order from a competent authority, or by something we notice in the ordinary course of running the service (DSA Art 8 — no general monitoring obligation). Counting reports per photo is part of acting on those reports; it is not monitoring of content we were not told about.
• Prioritisation. Reports are handled in the order received, except that reports involving child safety, threats to life or safety, and other imminent harm are triaged ahead of everything else.
• Available actions. Following review, a moderator may: dismiss a report (no action); warn a user; hide content (e.g. clear an offending name/bio field, or remove an offending chat message, or restore or remove a photo that reports have hidden); place an account in a cooldown for a stated number of days (you can still sign in and read, but not post; it ends by itself when the stated period is over, without anyone having to lift it); or suspend / ban an account (blocking posting, which removes the user from discovery and chat, and which nothing but us lifts). Repeated or egregious violations result in immediate account termination. Where a report of objectionable content is upheld, the content is removed and the responsible user is ejected (Section 4.1).
• Records. The action taken, who took it, when, and the statement of reasons are recorded against the report (actionTaken, actionedBy, actionedAt, statementOfReasons).

6.2 Reporting illegal content and violations — notice-and-action (DSA Art 16; Apple 1.2; Google Play UGC, answer 9876937)

Anyone may notify us — you do not need a Flybi account. The notice-and-action mechanism required by DSA Art 16(1) is open to any individual or entity, including people who do not use Flybi, organisations, and non-governmental bodies. There are two routes:

• In the app. Any signed-in user can report a person or content using the Report action, available from a profile and from chat. This is an easy-to-access, user-friendly mechanism allowing electronic submission of a notice (Apple Guideline 1.2 — a mechanism to report offensive content; Google Play UGC policy — in-app reporting of content and of users).
• By email, without an account. Anyone can send a notice to support@flybi.app. No Flybi account, app installation or sign-in is required.

Anonymous notices about child sexual abuse. For notices concerning offences under Articles 3 to 7 of Directive 2011/93/EU (child sexual abuse and exploitation), you may submit anonymously: you do not have to give your name, your email address, or any other contact details, and we will act on the notice all the same (DSA Art 16(2)(c)). The only consequence of staying anonymous is that we cannot send you an acknowledgement or tell you what we decided.

To help us act, a notice should include (DSA Art 16(2)): - (a) a sufficiently substantiated explanation of why the content or conduct is considered illegal or in breach; - (b) a clear indication of the precise location of the content (e.g. the user, profile field, or chat concerned — the in-app report flow captures this automatically, including recent shared chat context where relevant); - (c) the name and email of the notifier, except for notices concerning offences under Directive 2011/93/EU (child sexual abuse); and - (d) a good-faith statement that the notifier believes the information in the notice to be accurate and complete.

A notice that contains the elements above and concerns the legality of content is deemed to give us actual knowledge or awareness of that content for liability purposes (DSA Art 16(3)).

How we handle notices: - Where the notifier provides contact details, we send confirmation of receipt without undue delay (DSA Art 16(4)). - We process all notices in a timely, diligent, non-arbitrary and objective manner (DSA Art 16(6)). We provide timely responses to concerns (Apple App Store Review Guideline 1.2) and act on user reports (Google Play UGC policy, answer 9876937). We work to internal targets, and we do not publish them as a commitment to you: a number we cannot guarantee would be worth less to you than the duties above, which are not conditioned on it. Where automated means are used in processing a notice, we disclose this (DSA Art 16(6)). - We notify the notifier of our decision without undue delay and provide information on the redress possibilities available, which are those set out in Section 6.5 (DSA Art 16(5)).

6.3 Blocking other users

Independently of reporting, you can block any user from within the app. Blocking removes that user from your discovery feed and prevents them from contacting you (Apple Guideline 1.2 — the ability to block abusive users; Google Play UGC policy — in-app user blocking for apps with 1:1 interaction).

6.4 Statement of reasons to affected users (DSA Art 17)

If we restrict your content or your account on the ground that it is illegal or incompatible with these Terms, we will provide you with a clear and specific statement of reasons, at the latest from the time the restriction is imposed, where we have your electronic contact details (DSA Art 17(1)). The restrictions covered by Art 17(1) are the removal, disabling or demotion of content, the suspension or termination of the provision of the service, the suspension or termination of the account, and the suspension or termination of any monetisation of content. Flybi users do not earn money from their content (advertising and Premium are how Flybi is funded, not income from what you post — see Section 10), so the monetisation limb does not apply; the actions you may actually receive are content hiding/removal and account suspension/termination. The statement will include (DSA Art 17(3)):

• (a) whether the restriction is a removal, disabling, demotion of content, or suspension/termination of the account, and its territorial scope and duration;
• (b) the facts and circumstances relied on, including whether the decision was triggered by a notice submitted under Section 6.2 or by our own investigation;
• (c) whether automated means were used in taking the decision — including where content was blocked or hidden by the automated filter described in Section 6.1, in which case we say so expressly;
• (d) the contractual ground (the clause of these Terms relied on) or, for illegal content, the legal ground and an explanation of why the content is considered illegal; and
• (e) clear, user-friendly information about the redress options available to you (see Section 6.5).

This information will be as precise and specific as reasonably possible (DSA Art 17(4)). The action and the statement of reasons are recorded against the relevant report (actionTaken, actionedBy, actionedAt, statementOfReasons).

Scope note (DSA Art 17(2)): a statement of reasons is not required where the content is deceptive high-volume commercial content, or where we are acting on an order under DSA Art 9. Note on the DSA Transparency Database. The Art 24(5) Transparency-Database submission duty sits in Section 3 of the DSA and is therefore within the Art 19 micro-enterprise exemption, so we do not currently submit statements of reasons to the Commission's database. (Current position; to be confirmed in a professional review as the project grows.)

6.5 Appeals and redress

If you believe a moderation decision about you was wrong, you may contest it. We want to be precise about what we do and do not offer, so that you are not sent down a route that does not exist:

• Ask us to look again (a voluntary review). Reply to the statement of reasons, or write to support@flybi.app, and ask us to reconsider. A human will re-examine the decision and respond. This route is offered voluntarily. It is not the internal complaint-handling system required by DSA Art 20, because Art 20 does not apply to Flybi (see the note below): there is no guaranteed handling deadline and no formal appeal tier. We nevertheless aim to answer within a reasonable time and to reverse decisions we got wrong.
• Judicial redress — the Danish courts. You can bring the matter before a competent court. For Flybi that means the Danish courts (Flybi is established in Aarhus, Denmark), without prejudice to any right you have as a consumer under EU rules to sue, or be sued, in the courts of your country of residence. This is the redress route referred to in DSA Art 17(3)(f) and Art 16(5).
• Out-of-court dispute settlement (DSA Art 21): not available. We do not point you to a certified out-of-court dispute settlement body, for two independent reasons. First, Art 21 does not apply to Flybi (Art 19 micro-enterprise exemption). Second, Denmark's Digital Services Coordinator has certified no out-of-court dispute settlement body under Art 21 — so there is no such body for a Danish provider to name. If that changes, we will update these Terms. (Position as at the "Last updated" date above.)
• Other complaint routes that are unaffected. Nothing here limits your right to complain to the Danish Digital Services Coordinator (Digitaliseringsstyrelsen), to a data-protection authority about your personal data, or to any other competent authority.

Micro-enterprise exemption. As a micro-enterprise under Commission Recommendation 2003/361/EC, Flybi is exempted by DSA Art 19(1) from the whole of DSA Section 3 (Arts 20–28), except Art 24(3) — including the formal internal complaint-handling system (Art 20), out-of-court dispute settlement (Art 21), trusted flaggers (Art 22), measures against misuse (Art 23), dark patterns (Art 25), advertising (Art 26), recommender-system transparency (Art 27) and online protection of minors (Art 28). The voluntary review path above is offered by choice, not under Art 20, and we do not claim to operate any of the Section 3 mechanisms listed here. This exemption does not touch Arts 11, 12, 14, 16, 17 or 18, which apply in full (DSA Sections 1 and 2). The exemption is lost if Flybi is ever designated a Very Large Online Platform (DSA Art 19(2)), and a 12-month grace period applies if Flybi outgrows micro/small status. Even under the exemption, Art 24(3) still requires reporting average monthly active recipients to the Digital Services Coordinator / Commission on request. Flybi is currently within micro-enterprise size at this beta scale. (Current status; to be confirmed in a professional review as the project grows.)

6.6 Content for minors

Flybi is an 18+ service and is not targeted at or intended to be used by minors; accordingly the minor-comprehension obligation in DSA Art 14(3) is addressed by the 18+ eligibility gate in Section 2 rather than by minor-specific phrasing.

7. Suspension and termination

7.1 By you. You may stop using Flybi at any time. You can deactivate your account (a reversible self-service toggle that hides your profile from discovery while preserving your data) or permanently delete your account from within the app at any time (see Section 9).

7.2 By us. We may warn, hide content, place your account in a time-limited cooldown, suspend, or terminate your account and licence, in whole or in part, where you breach these Terms — in particular the acceptable-use rules in Section 4 — or where required to comply with law or a competent authority's order. Enforcement is applied diligently, objectively and proportionately (DSA Art 14(4)).

7.3 Immediate termination. Egregious or repeated violations — including the prohibited behaviour in Sections 4.1–4.2 — are grounds for immediate removal of content and termination of your account (Apple App Store Review Guideline 1.2).

7.4 Statement of reasons. Where we impose a restriction, suspension or termination on the grounds in Section 7.2, you receive a statement of reasons and may seek redress as set out in Sections 6.4–6.5 (DSA Art 17).

7.5 Effect of termination. On termination your licence ends and your access is withdrawn. Sections that by their nature should survive (e.g. Sections 4, 8, 10, 12, 13) survive termination.

8. Reporting serious criminal offences to authorities (DSA Art 18)

Where we become aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of one or more persons has taken place, is taking place, or is likely to take place, we will promptly inform the relevant law-enforcement or judicial authorities and provide all relevant available information (DSA Art 18(1)). Where the Member State concerned cannot be identified with reasonable certainty, we will notify the law-enforcement authorities of Denmark (our Member State of establishment), and/or Europol (DSA Art 18(2)). In Denmark that means Politiet — 112 where there is an immediate threat, 114 otherwise — and, for online child sexual abuse, the specialist unit NSK/NC3. Suspected child sexual abuse material is preserved and reported to the competent authority without delay; our full child-safety process, including our designated child-safety point of contact, is published at Flybi Child Safety Standards. The operational escalation steps are set out in our internal Moderation Runbook.

9. Account deletion and data

9.1 In-app deletion. You can delete your account from within the app (account settings). Deletion is not merely a deactivation: it triggers a server-side cascade erasure of your account record and associated personal data, subject to any data we are legally required or permitted to retain (Apple Guideline 5.1.1(v) and Apple's Offering account deletion in your app guidance — temporary deactivation alone is insufficient; Google Play account-deletion policy, answer 13327111). Where you signed in with Apple, the relevant Sign in with Apple tokens are revoked on deletion.

9.2 Web deletion request. A publicly reachable web page at https://flybi.app/delete-account lets you request account and data deletion without reinstalling the app (Google Play account-deletion policy, answer 13327111). The page prominently features the deletion pathway, names "Flybi" / the developer as shown on the store listing, and is declared in the Google Play Data safety form (live and published — #725).

9.3 Retention. Certain data may be retained where necessary for security, fraud prevention, legal compliance, or to maintain the integrity of moderation/audit records — including a record of moderation actions and statements of reasons. Retention periods are set out in the Privacy Policy and are kept consistent with the Data safety / App Privacy disclosures. (Current periods; to be confirmed in a professional review as the project grows.)

9.4 The categories of personal data we process — account (email; authentication via email/Google/Apple), profile (display name, bio, photos), interest tags (including secret tags), coarse location (geohash) and transient live location during a hot/cold game, chat messages, user reports, and date of birth (required at signup) for the 18+ gate — and how to exercise your data-protection rights, are described in the Privacy Policy.

10. Premium, advertising, and third-party services

10.1 Premium subscriptions. Flybi offers an optional Premium subscription, for 1, 3 or 12 months, that removes ads and unlocks the features listed on the subscription screen. You buy it through the App Store or Google Play, and the purchase is also governed by Apple's or Google's terms.

• Price and renewal. The price is the one the store shows you before you confirm, in your currency and including any taxes. The subscription renews automatically, at the same price and for the same period, until you cancel.
• Cancelling. Cancel at any time in your App Store or Google Play subscription settings; Premium continues until the end of the period you have paid for. Deleting your Flybi account does not cancel the subscription in the store — cancel it there as well.
• Refunds and withdrawal. Apple or Google takes the payment and handles refunds and any statutory right of withdrawal, under their terms and the consumer law that applies to you.
• Changes to Premium. If we change what Premium includes in a way that materially reduces it, we will tell you in advance, and you can cancel before your next renewal.

10.2 Advertising. People on the free plan may see a small number of ads in the discovery feed and the chat list, each marked as an ad and served by Google AdMob. Ads are never full-screen and never block or limit the app. Venue suggestions that businesses pay for are marked as paid placements. How ad data is handled, and how to refuse personalised ads, is set out in the Privacy Policy. On iOS we ask for App Tracking Transparency permission before any tracking as defined by Apple (Apple Guidelines 5.1.2(i) and the App Privacy "Tracking" definition; Google Play Data safety, answer 10787469). We will not require you to enable tracking, push, or location to access core functionality (Apple Guideline 5.1.2(i)).

10.3 Third-party infrastructure. Flybi runs on Google Firebase (Firestore, Authentication, Storage, Cloud Functions in region europe-west1, Cloud Messaging for push, Remote Config, and App Check). Use of these services is also subject to the applicable third-party terms. We disclose data sharing with third parties in the Privacy Policy and the store privacy disclosures (Apple Guideline 5.1.2(i); Google Play Data safety).

11. App Store and Google Play provisions

11.1 Apple-distributed copies. These Terms are between you and the Provider, not Apple. Apple has no obligation to provide maintenance or support for Flybi. Apple is not responsible for any product warranties, claims of non-conformity, product-liability, third-party intellectual-property claims, or for addressing your or any third party's claims relating to Flybi, except as set out in Apple's standard EULA. Apple and its subsidiaries are third-party beneficiaries of these Terms and may enforce them against you. You represent that you are not located in a country subject to a U.S. Government embargo or designated a "terrorist supporting" country, and that you are not on any U.S. Government list of prohibited or restricted parties. (These provisions reflect the minimum terms Apple requires of apps that do not use Apple's standard EULA — see the Apple Developer Program License Agreement, Schedule 1; Apple standard EULA.)

11.2 Reviewer access. A demo/reviewer account and any demo mode are provided to the app stores for review, and such accounts are excluded from production analytics and the best-fit pipelines (Apple Guideline 2.1(a); the isDemoAccount flag). Demo/reviewer credentials are supplied directly to App Store Connect / Play Console at submission time and are never placed in this public document.

11.3 Google Play-distributed copies. Your use is additionally subject to Google Play's terms. Flybi targets the 18-and-over audience only, with Restrict Minor Access and an accurately completed IARC content rating, and does not opt into the Families programme (Google Play, answers 9867159, 9859655).

12. Disclaimers and limitation of liability

12.1 No vetting guarantee. Flybi facilitates connections between real people. We apply the moderation measures in Section 6, and an optional identity/trust verification signal may be shown for some users, but we do not conduct background checks and cannot guarantee any user's identity, intentions, or conduct. Use common sense and caution when meeting or communicating with anyone, and prioritise your safety.

12.2 "As is". To the maximum extent permitted by law, Flybi is provided "as is" and "as available" without warranties of any kind, express or implied, including fitness for a particular purpose and non-infringement. We do not warrant that the service will be uninterrupted, error-free, or secure.

12.3 Limitation. To the maximum extent permitted by law, the Provider is not liable for indirect, incidental, special, consequential or punitive damages, or for the acts or content of other users. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law — including your mandatory rights as a consumer under Danish and EU law. (Current position; the liability wording is to be confirmed for Danish/EU consumer-protection law and the relevant app-store agreements in a professional review as the project grows.)

13. Governing law, contact points, and general

13.1 Governing law and forum. These Terms are governed by the laws of Denmark, without prejudice to the mandatory consumer-protection rules of your country of residence in the EU. (Current position; to be confirmed in a professional review as the project grows.)

13.2 Point of contact for users (DSA Art 12). You can communicate with us directly and rapidly by electronic means, in a user-friendly manner, at support@flybi.app. This channel does not rely solely on automated tools — a human is reachable (DSA Art 12(1)–(2)).

13.3 Single point of contact for authorities (DSA Art 11). For Member State authorities, the European Commission, and the European Board for Digital Services, the electronic point of contact is support@flybi.app. Communications may be conducted in Danish and English (incl. at least one official language of our Member State of establishment, Denmark) (DSA Art 11(2)–(3)).

13.4 Data protection / GDPR contact. Because the Provider is established in the EU (Denmark), no GDPR Art 27 EU representative and no DSA Art 13 legal representative is required (both apply only to providers without an EU establishment). No Data Protection Officer is appointed under GDPR Art 37; one is not legally required at the current scale, and this is re-assessed if scale grows or biometric/ID verification is enabled. The contact for privacy matters is Nicholas Gerster Toft Simonsen at support@flybi.app. The Privacy Policy is the canonical source for the data-protection contact and your data-protection rights.

13.5 Severability. If any provision is held unenforceable, the remaining provisions stay in effect.

13.6 Entire agreement. These Terms, together with the Privacy Policy and (for Apple-distributed copies) Apple's standard EULA, constitute the entire agreement between you and the Provider regarding Flybi.

13.7 Assignment. You may not assign these Terms; the Provider may assign them in connection with a merger, acquisition, or sale of assets, on notice to you.

References cited inline: Regulation (EU) 2022/2065 (Digital Services Act), Arts 8, 9, 11, 12, 14, 16, 17, 18, 19, 20–28 (exempted), 24 — canonical text at EUR-Lex CELEX 32022R2065 (verify final wording against EUR-Lex); Directive 2011/93/EU (combating child sexual abuse); Commission Recommendation 2003/361/EC (micro/small-enterprise definition); Apple App Store Review Guidelines §§1.2, 2.1, 5.1.1, 5.1.2, the Apple "Offering account deletion in your app" guidance, and the Apple Developer Program License Agreement (Schedule 1) / Apple standard EULA; Google Play Developer Program Policies — UGC (answer 9876937), account/data deletion (13327111), Data safety (10787469), prominent disclosure & consent (11150561), foreground-location minimum scope (17033915), target audience (9867159), content rating / IARC (9859655), and the Child Safety Standards policy applicable to our Play category. Operational moderation detail is maintained in our internal Moderation Runbook.