Fly.io Privacy Policy

This document is Fly.io's Privacy Statement, governing the collection, use, and disclosure of personal data by Superfly, Inc. in connection with its cloud application hosting platform and related services. The statement asserts that Fly.io collects account information, payment data, usage and log data, communications content, and customer application data, and the terms authorize sharing this information with service providers, business partners, and in connection with corporate transactions such as mergers or acquisitions. Notably, the statement positions customer application data (data belonging to end users of applications deployed on Fly.io infrastructure) as distinct from Fly.io's own data collection, placing primary responsibility for that data on the deploying customer; this operator-versus-controller distinction is operationally significant but its precise legal weight depends on applicable data protection law and the existence of appropriate data processing agreements. The statement references compliance obligations for EU and UK users under GDPR-equivalent frameworks, California residents under CCPA, and acknowledges data transfers outside the EEA, engaging the FTC's jurisdiction over unfair or deceptive data practices in the US context and EU supervisory authority jurisdiction for European residents. Material compliance considerations include the adequacy of data transfer mechanisms for cross-border transfers, the sufficiency of contractual arrangements between Fly.io and its customers who process end-user data on the platform, and the clarity of retention and deletion practices described in the policy.