1. Controller
Masis Martirosyan, a private individual (“we”), is the controller of personal data processed through flipauto.online and the Telegram Mini App @flipautoapp_bot (the “Platform”). The Platform is intended for users in the United Arab Emirates. This Policy is prepared in line with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).
For privacy matters, contact us via the contact form (choose “Request about my data”) or via Support in the Mini App.
2. Data we collect
| Category | Examples | Source |
|---|---|---|
| Telegram profile data | Telegram user ID, first and last name, username, interface language | Telegram, when you open the Mini App or the bot |
| Listing data | Vehicle details, photos, price, description, location (emirate / area) | You |
| Car search requests | Desired make and model, budget, requirements | You |
| Support requests and complaints | Your messages and attachments, the reason of a complaint about a listing | You |
| Contact form | Name, e-mail or Telegram username for our reply, message, link to a listing | You |
| Consent record | Version of the Terms and Privacy Policy you accepted, date and time, language | You, when you tap “Continue” or “OK” in the Mini App |
| Technical data | IP address, device and browser type, access and error logs | Automatically, from our servers |
| Cookie | Language preference only | Your browser |
We do not ask for your phone number, Emirates ID or payment details. In the contact form we ask for an e-mail or a Telegram username only so that we can reply to you. Please do not include such data, or personal data of other people, in listings or photos. We do not knowingly collect data of persons under 18.
3. Why we use data and on what basis
| Purpose | Data | Legal basis (PDPL) |
|---|---|---|
| Create and run your account; publish, display and extend listings | Telegram profile, listing data | Performance of the contract (Terms of Use) |
| Let buyers contact sellers via Telegram | Username / Telegram ID | Performance of the contract |
| Car search requests, support, complaints and the contact form | Request, support and contact form data | Performance of the contract; your request |
| Service notifications via the bot (listing expiry reminders, archive deletion notices, moderation, matching cars, replies) | Telegram ID | Performance of the contract |
| Record that you accepted the Terms and this Policy | Consent record | Compliance with law; proof of acceptance |
| Moderation, fraud prevention, security | All categories | Compliance with law; protection of users |
| Responding to authorities and legal claims | As required | Legal obligation; legal proceedings |
The bot sends service notifications only. We do not send news or promotional messages.
We do not sell personal data, do not use it for automated decisions with legal effect, and do not use it to train AI models.
4. What is public
Published listings, including photos, description and the button to contact the seller in Telegram, are visible to all users of the Platform and may be indexed by search engines on flipauto.online.
5. Retention
- Account data — while your account is active; deleted when you delete your account in the Mini App.
- Listings — published for 60 days and can be extended without limit. Expired or unpublished listings are kept in the archive for 90 days and are then deleted together with their photos; we notify you via the bot 3 days before.
- Car search requests — 60 days from creation, then deleted automatically.
- Support requests, complaints and contact form messages — up to 12 months after the request is closed.
- Consent records — while your account exists.
- Server logs — up to 14 days.
- Backups — only as long as needed to restore the service.
We may keep minimal data longer where required by law or to handle a dispute or a report of fraud (e.g. the ID of a banned account to prevent repeat abuse).
6. Who receives data
- Telegram — the Mini App and the bot run on Telegram; Telegram processes your data under its own privacy policy.
- Hosting provider — Hostinger, data centre in the Netherlands, acting on our instructions.
- Other users — the content of your listings (see section 4).
- Authorities — where required by applicable law or a valid order.
- Successor — if the Platform is sold or reorganised, subject to this Policy.
7. International transfers
Our servers are located in the Netherlands (Hostinger), and Telegram processes data in its own infrastructure outside the UAE. This means your data is transferred outside the UAE. We protect it through our hosting provider’s data processing terms, access controls and encryption in transit (HTTPS). By accepting this Policy when you first open the Platform, you give your explicit consent to such transfer, which is also necessary to provide the service you request.
8. Your rights
Subject to the PDPL, you have the right to:
- get information about and a copy of your data;
- correct inaccurate data;
- delete your data;
- restrict or object to processing;
- withdraw consent at any time (this does not affect earlier processing);
- complain to the UAE Data Office.
How to exercise them: delete your account in the Mini App (Profile → Delete account) — this deletes your profile, listings, photos and search requests. For other requests, use the contact form (“Request about my data”) or Support in the Mini App. We will verify that the request comes from the Telegram account concerned and reply within 30 days.
9. Security
We use HTTPS, restricted staff access, validation of Telegram authorisation data, and regular backups. No system is fully secure; if a breach affects your data, we will notify you and the competent authority as required by law.
10. Cookies
On flipauto.online we use one strictly necessary cookie to remember your interface language. We do not use analytics or advertising cookies.
| Cookie | Purpose | Type | Lifetime |
|---|---|---|---|
| site_lang | Remembers your interface language (EN / RU / AR) | Strictly necessary, first-party | 12 months |
This cookie does not identify you and is not shared with anyone. You can delete it in your browser settings; the site will then show the default language. If we ever add analytics or advertising cookies, we will ask for your consent before setting them.
11. Children
The Platform is intended for users aged 18 and over. If you believe a minor has provided us data, contact us and we will delete it.
12. Changes
We will publish any update with a new date. For material changes, the Mini App will ask you to accept the new version the next time you open it.
13. Contact
Masis Martirosyan. Contact form: flipauto.online/contact. In the Mini App: Profile → Support.