Privacy Policy

This Privacy Policy explains how ClutterFly (“ClutterFly,” “we,” “our,” or “us”) collects, uses, discloses, and protects personal information when you use the ClutterFly mobile application and related services (collectively, the “Application” or “Services”).

This Policy is intended to comply with applicable privacy laws including the GDPR (EU/UK), CCPA/CPRA (California), VCDPA (Virginia), CPA (Colorado), LGPD (Brazil), and applicable platform requirements including Apple App Store and Google Play policies.

1. Categories of Personal Data We Collect
We collect the following categories of personal data:
A. Device and Identifier Information

  • Device model
  • Operating system version
  • Application version
  • IP address
  • Device identifiers, including advertising identifiers (such as IDFA on iOS or GAID on Android)
B. Usage and Interaction Data
  • Application feature usage
  • App interaction events
  • Advertising interactions (impressions, clicks)
C. Diagnostics Information
  • Crash logs
  • Performance data
  • Technical diagnostic information
We use Firebase Analytics to measure marketing effectiveness and understand application usage patterns.
D. Media Access (Photos & Videos)
ClutterFly requests permission to access photos and videos in order to:
  • Identify duplicate media
  • Detect similar or blurry photos and videos
  • Share files selected by the user
  • Mark files as Favorites
  • Move files to Trash
  • Permanently delete files using “Delete from Device”
Media analysis:
  • Occurs locally on your device
  • Is not uploaded to our servers
  • Is not stored remotely
  • Is not shared with third parties
This permission is limited to media files only.
E. Full Storage Access & File Management (Android Only)
On Android devices, ClutterFly may request “Manage Storage” (All files access / MANAGE_EXTERNAL_STORAGE) permission.
This permission is required because the Application provides full file management functionality beyond media-only access. MediaStore access alone is not sufficient for these features.
ClutterFly allows users to:
  • Create folders in device storage
  • Move files across storage directories
  • Access Downloads, Documents, system folders, and other storage areas
  • Manage non-media file types including APK files, documents, and audio
  • Use an in-app file explorer to browse all supported storage locations
  • Use an in-app file explorer
  • Move supported file types into the Lock Folder
All file operations:
  • Are initiated directly by the user
  • Occur locally on the device
  • Do not involve uploading files to our servers
  • Do not involve remote file access
  • Do not involve sharing file content with third parties
ClutterFly does not collect, transmit, or store user files externally.
F. Contact Information (If Provided)
We may collect:
  • Email address (when contacting support)
  • Phone number (if voluntarily provided in support communications or processed via integrated third-party SDKs)
We do not access or collect users’ phone contacts.
Phone numbers are used solely to respond to user inquiries or for services explicitly initiated by the user.
2. How We Collect Personal Data
We collect information:
  • When you voluntarily provide it (e.g., support email)
  • Automatically when you use the Application
  • Through integrated third-party advertising and analytics SDKs
3. Advertising and Cross-App Tracking
ClutterFly integrates third-party advertising services to support the free version of the Application.
Personalized Advertising
Where permitted by law and subject to your consent, advertising identifiers may be used to:
  • Deliver personalized advertisements
  • Measure advertising performance
  • Track interactions across apps and services owned by other companies
On iOS, we request permission through Apple’s App Tracking Transparency (ATT) framework before accessing tracking identifiers.
If you decline tracking permission, advertising identifiers will not be used for cross-app tracking in accordance with platform requirements.
Data Collected by Advertising Providers
Advertising providers may collect:
  • Advertising identifiers
  • Device information
  • IP address
  • Advertising interaction data
Such processing is governed by the providers’ own privacy policies.
ClutterFly does not sell personal data for monetary compensation.
However, under certain laws (including California CPRA), sharing identifiers for cross-context behavioral advertising may be considered “sharing.”
We do not use personal data for credit eligibility, employment decisions, housing decisions, insurance eligibility, or other legally significant profiling activities.
4. Third-Party Service Providers
We use third-party services for:
  • Advertising
  • Analytics (including Firebase Analytics)
These providers may process device identifiers, usage data, and diagnostic data according to their own privacy policies and contractual agreements.
We do not provide media file content to third parties.
5. Legal Bases for Processing (EU/UK Users)
If you are located in the EU or UK, we process personal data under:
  • Consent – For personalized advertising and tracking technologies where required.
  • Legitimate Interest – For functionality, diagnostics, security, and service improvement
  • Legal Obligation – Where required by law
You may withdraw consent at any time through device settings or by contacting us.
6. International Data Transfers
Personal data may be processed outside your country of residence.
Where required, we implement appropriate safeguards such as:
  • Standard Contractual Clauses
  • Legally recognized transfer mechanisms
  • Contractual data protection obligations
You may request additional information by contacting dataprotection@clutterflyapp.com.
7. Data Retention
We retain personal data only as long as necessary to fulfill the purposes described in this Privacy Policy or to comply with legal obligations.
Media files accessed for duplicate detection are not stored by us.
Retention of advertising and analytics data is governed by respective third-party providers.
8. Your Privacy Rights
Depending on your jurisdiction, you may have the following rights:
  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to withdraw consent
  • Right to opt out of sale or sharing
Right to Know About Data Sharing
You have the right to request information about:
  • Categories of personal data collected
  • Categories of personal data disclosed or shared
  • Categories of third parties receiving personal data
  • Business or commercial purposes for sharing
We disclose device identifiers, usage data, and advertising identifiers to advertising and analytics providers as described above.
We do not disclose media file content to third parties.
California (CCPA/CPRA)
California residents have the right to:
  • Know what personal information is collected
  • Request deletion
  • Opt out of sale or sharing
  • Limit use of sensitive personal information (if applicable)
  • Not be discriminated against for exercising rights
ClutterFly does not sell personal information for monetary compensation.
Opt-Out of Sale, Sharing, Targeted Advertising, and Profiling
Under applicable laws including the Virginia Consumer Data Protection Act (VCDPA), California CPRA, Colorado CPA, and similar state laws, you have the right to opt out of:
  • The sale of personal data
  • The sharing of personal data for cross-context behavioral advertising
  • Targeted advertising
  • Profiling in furtherance of decisions that produce legal or similarly significant effects
ClutterFly does not sell personal data for monetary compensation.
To exercise your opt-out rights, you may:
  1. Adjust your device settings:
    • Android: Reset or delete your Advertising ID in device privacy settings.
    • iOS: Disable tracking in Settings > Privacy > Tracking, or decline App Tracking Transparency (ATT) permission.
  2. Submit a request by emailing:
    dataprotection@clutterflyapp.com
    Subject line: “Opt-Out Request”
We will process opt-out requests within the timeframe required by applicable law.
We do not use personal data to make decisions that produce legal or similarly significant effects such as credit eligibility, employment decisions, housing decisions, or insurance eligibility.
EU & UK (GDPR)
EU and UK users may:
  • Access personal data
  • Correct inaccurate data
  • Request erasure
  • Restrict processing
  • Object to processing
  • Withdraw consent
  • Lodge complaints with supervisory authorities
9. How to Exercise Your Rights
To exercise your rights, contact:
Email: dataprotection@clutterflyapp.com
We will acknowledge requests within 10 business days and respond within legally required timeframes. Identity verification may be required.
10. Security Measures
We implement reasonable technical and organizational safeguards including encryption in transit and access controls.
No system can guarantee absolute security.
11. Children’s Privacy
ClutterFly is not directed to children under 16.
We do not knowingly collect personal data from children under 16.
12. Changes to This Privacy Policy
We may update this Policy periodically. Updates will be reflected by revising the “Last Updated” date.
Continued use of the Application after updates constitutes acceptance of the revised Policy.

Contact Information of Our DPO
Name: Aomata Data Dept
Email: dataprotection@clutterflyapp.com
Updated date: March 03rd 2026