Version 1.0 of August 17, 2026
In short, as before: we collect the bare minimum of data, use it only to run the day on November 21, 2026, never sell it, never use it for advertising, and delete it no later than December 31, 2026 – or earlier, as soon as you ask. Below is the full legal text. This summary does not replace the full text: in case of any discrepancy, the full text prevails.
The controller (operator) of personal data processed in connection with the World Connection Day website is:
Fleamily Inc., a Delaware corporation (USA), registration number 10632227
Address: 228 Park Ave S, PMB 85451, New York, NY 10003, United States
E-mail for data matters: legal@fledge.love (subject line: “WCD – personal data”)
Referred to below as “we”, the “Operator” or the “project”. World Connection Day (WCD) is a non-commercial campaign run by the Operator; the “World Connection Day project” is not a separate legal entity.
An additional contact channel is Instagram @valklimoff. We do accept data rights requests sent via Instagram, but for legally significant requests (access, deletion, withdrawal of consent, complaints) e-mail is the primary channel: it lets us reliably identify the request and record the applicable deadlines.
This Policy applies to the website worldconnectionday.fledge.love and all of its language versions (the “Website”).
The Policy does not apply to the Fledge mobile app or the main Fledge website (fledge.love) – those are covered by the separate Fledge Privacy Policy – nor to third-party websites and services linked to from the Website (including Instagram and the websites of participating venues and ambassadors).
Depending on where you are, the processing of your data is governed, in particular, by: Regulation (EU) 2016/679 (GDPR) and the UK GDPR – for users in the EEA and the United Kingdom; Federal Law of the Russian Federation No. 152-FZ “On Personal Data” – for users in Russia; the LGPD (Brazil), the APPI (Japan) and other comparable laws – for users in the respective countries. Nothing in this Policy limits the mandatory rights granted to you by the law of your country of residence.
Data: a contact – your Instagram handle or e-mail address; optionally your city and the colour you got in the test. If you requested a participant kit – additionally the recipient’s first and last name, postal address and, where the delivery service requires it, a contact phone number.
Purpose: one message reminding you about the day and explaining how to make your ribbon, sent roughly a week before November 21, 2026; for the first participants – sending a participant kit, if you requested one.
Legal basis: your consent (Art. 6(1)(a) GDPR; Art. 6(1)(1) of Law No. 152-FZ). Consent is given by ticking the box in the form and is voluntary: you can use the Website, the test, the map and the vote without leaving any data at all. You may withdraw consent at any time (section 9) – this does not affect the lawfulness of processing carried out before the withdrawal.
Retention: until the reminder has been sent and the campaign is over, and in any event no later than December 31, 2026; if you withdraw consent – deletion without undue delay and no later than 30 days.
Address data collected in order to send the kit is passed to the delivery service (clause 6.2) to the extent necessary for shipping and is deleted once delivery is confirmed, and in any event no later than December 31, 2026.
Data: city; the name and address of the venue; links to a website or social media pages; the applicant’s contact details (name/handle, e-mail or another contact).
Purposes: reviewing the application, contacting the applicant, adding the venue or ambassador to the map of the day and to campaign materials.
Legal bases: taking steps at your request prior to agreeing on participation (Art. 6(1)(b) GDPR) – as regards reviewing the application and contacting you; our legitimate interest in organising and promoting the campaign (Art. 6(1)(f) GDPR) – as regards publishing on the map the details of the venue and the public links given in the application. Only venue details are published (name, city, address, public links); the applicant’s personal contacts are not published on the map.
Retention: until December 31, 2026; data from rejected applications – no longer than 30 days after rejection.
Data: the city and place you choose. A vote is not linked to your identity: we do not ask for a contact and do not store any “vote – person” link. To protect against vote manipulation we apply technical limits at the level of server logs (clause 3.5), without building any profile of the voter.
Legal basis (for the technical data): our legitimate interest in keeping the vote fair and preventing abuse (Art. 6(1)(f) GDPR).
Data: the sender’s name or handle; the name or handle of the second person in the pair; city; the story of how you met (up to 140 characters).
Purposes: receiving and moderating stories; publishing the story on the “We met” page, openly accessible to anyone.
Legal bases: as regards your data – your consent to publication, confirmed by ticking the box in the form (Art. 6(1)(a) GDPR; Art. 6(1)(1) of Law No. 152-FZ); as regards the second person’s data – our legitimate interest in running the campaign (Art. 6(1)(f) GDPR), subject to the safeguards set out in this clause.
By submitting a story you represent that the second person knows about the submission and does not object to their name or handle and the text of the story being published, and that the story contains no insults, contact details or information that the second person would not want disclosed. Stories are moderated before publication; we may reject or hide a story without giving reasons. A published story is visible to every visitor of the Website and may be indexed by search engines.
Deletion: either of the two – the sender or the second person – may request that the story be deleted; we will delete it without asking for reasons and no later than 7 days after the request. To make the request it is enough to write to the address in section 1 and state the city and the text (or a screenshot) of the story; the contact left on the Website is not required.
Retention: until December 31, 2026, like the rest of the campaign data.
Data: IP address, date and time of the request, the requested URL, technical browser headers – standard web server logs.
Purposes: security, protection against attacks, vote manipulation and other abuse, troubleshooting.
Legal basis: our legitimate interest in keeping the Website secure and operational (Art. 6(1)(f) GDPR). You may object to processing based on legitimate interest (section 9).
Retention: no more than 30 days, after which logs are automatically deleted or anonymised. Logs are not combined with form data and are not used for profiling.
We do not ask for and do not collect your name (except where you have included it in the contact, in the “day’s wall” form or as the recipient of a participant kit), phone number and postal address (except for the data needed to deliver a participant kit you requested – clause 3.1), date of birth, precise location, or any special categories of data (health, beliefs and the like). If you include excessive information in free-text form fields on your own initiative, we will delete it once we notice it.
The “what colour is your hello” test runs entirely in your browser. Your answers are not sent to our servers and are not stored by us anywhere. The result (your colour) is saved locally on your device (localStorage) and stays there until you clear your browser data. We only learn your colour if you enter it yourself in the “I’m in” form. The test is an entertainment format; it is not psychological testing, a diagnosis, or automated decision-making producing legal effects for you.
5.1. The Website has no advertising trackers, social media pixels or third-party analytics. We do not use cookies that require consent, which is why there is no cookie banner. We only use your browser’s localStorage to store the test result functionally on your device; that data is not transmitted to us.
5.2. When pages load, your browser connects to the following third-party services, which technically receive your IP address and standard request data – exactly as when loading any resource on the internet:
These providers process request data in accordance with their own privacy policies. We do not pass any form data to them. The legal basis for this technical transfer is our legitimate interest in displaying the Website correctly (Art. 6(1)(f) GDPR).
6.1. We do not sell personal data, do not share it with third parties for their own purposes and do not use it for advertising – neither ours nor anyone else’s.
6.2. To run the Website we engage a limited number of processors acting on our behalf under a contract that restricts processing to our instructions: the hosting provider whose servers host the Website and the form database; an e-mail delivery service – solely to send the reminder message referred to in clause 3.1; and a delivery service (a postal or courier operator) – solely to send a participant kit you requested (clause 3.1); to the extent established by postal legislation, the postal operator acts as an independent data controller. Processors may not use the data for their own purposes.
6.3. We may disclose data where required by law – on the basis of a binding request from a court, law enforcement or supervisory authority – as well as to establish, exercise or defend legal claims. In such cases we disclose only the minimum necessary.
6.4. Within the Operator’s group, access to the data is limited to members of the World Connection Day team who need it for the purposes set out in section 3, under a duty of confidentiality.
7.1. The Website is addressed to users worldwide, so data may be processed on servers outside your country of residence, including in the United States and in EEA countries.
7.2. For users in the EEA, the United Kingdom and Switzerland: where data is transferred to countries without an adequacy decision, we rely on the safeguards provided for by law – the European Commission’s Standard Contractual Clauses (SCCs) with our processors and, where applicable, the EU–U.S. Data Privacy Framework. A copy of the applicable safeguards can be requested at the address in section 1 (with possible redactions to protect confidential information).
7.3. For users in Russia: by submitting data through the Website’s forms, you consent to its cross-border transfer for the purposes set out in section 3. The Operator complies with the cross-border transfer requirements applicable to it.
All campaign data (clauses 3.1–3.4) is deleted no later than December 31, 2026. Earlier – as soon as the data subject asks. Server logs (clause 3.5) are kept for no more than 30 days.
Data in backups is overwritten within the standard rotation cycle, which does not exceed 30 days after deletion from the main database; backups are not used for any active purpose other than disaster recovery. Once the retention periods expire, data is deleted or irreversibly anonymised.
9.1. To the extent provided by the law applicable to you (GDPR, UK GDPR, Law No. 152-FZ, LGPD, APPI and others), you have the right to:
9.2. To exercise any right, write to legal@fledge.love with the subject “WCD – personal data” and state the contact you left on the Website (to have a story removed from the day’s wall, the details set out in clause 3.4 are enough). We may ask clarifying questions where reasonably necessary to verify that the request comes from the owner of that contact; as a rule we do not ask for any identity documents. We respond without undue delay and in any event within 30 days (one month under the GDPR, with a possible extension for complex requests, of which we will inform you); deletion following a withdrawal of consent takes place within the period set out in clause 3.1.
9.3. Supervisory authorities: for the EEA/UK – the data protection authority of your country of residence, place of work or place of the alleged infringement; for Russia – Roskomnadzor; for other countries – the competent authority under the applicable law. We would be grateful if you wrote to us before lodging a complaint – as a rule that resolves the matter faster.
We apply reasonable technical and organisational safeguards proportionate to the nature and volume of the data: encrypted connections (HTTPS/TLS), need-to-know access to the database, separation of server environments, minimisation of the data collected and short retention periods. No service offers absolute security; should an incident affecting personal data occur, we will notify the supervisory authority and the individuals concerned in the cases and within the deadlines set by applicable law.
The Website’s forms are not intended for anyone under 16, and we do not knowingly collect children’s data. If you are under 16, please do not leave a contact; you can take part in the day without any forms, and an adult can leave a contact on your behalf. If we learn that data was submitted by a child under 16 (or under a higher age set by the law of their country for giving consent independently), we will delete it without undue delay. A parent or legal guardian can notify us at the address in section 1.
We do not carry out profiling and do not make automated decisions producing legal effects for you or similarly significant effects.
If the Policy changes, the new version is published on this page with a new date and version number. Material changes that expand the purposes or the scope of the data processed do not apply to data collected before the change without separate consent. An archive of previous versions is available on request.
Fleamily Inc., 228 Park Ave S, PMB 85451, New York, NY 10003, USA
E-mail: legal@fledge.love (subject: “WCD – personal data”)
Instagram: @valklimoff