This analysis describes what Fly.io's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The updated policy now explicitly discloses that Fly.io uses third-party fraud-prevention services that collect device and browser signals (and set cookies) when users create accounts or sign in. Unlike analytics, which users can opt out of via cookie preferences or Google's opt-out tool, this fraud-prevention processing cannot be opted out of. The company states its legal basis is legitimate interest in protecting the platform and users. You can opt out of analytics collection, but fraud-prevention data collection will apply to all account creation and sign-in activity.
View change record →The updated policy discloses that Fly.io now uses PostHog analytics on public, logged-out pages (marketing pages, blog, documentation) in addition to Google Analytics. PostHog stores a random identifier and pageview data such as URL, referrer, and device type in the EU, but does not link this data to user names, email addresses, or Fly.io accounts, and does not capture session recordings, clicks, keystrokes, or form contents. Analytics data is retained for a maximum of 12 months. For users in the EEA, UK, or Switzerland, both Google Analytics and PostHog require explicit consent before being set; you can withdraw consent at any time using the 'Cookie preferences' link in the page footer or by using Google's opt-out browser add-on.
View change record →How other platforms handle this
The Company collect and process personal information in [Singapore, Malaysia] for the purpose of providing the services.
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"we require that if our vendors or affiliates have access to User Personal Information, they must comply with our privacy policies and with applicable data privacy laws, including signing data transfer agreements such as Standard Contractual Clause agreements.Excerpt from Fly.io's Privacy Policy
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The clause states: “we require that if our vendors or affiliates have access to User Personal Information, they must comply with our privacy policies and with applicable data privacy laws, including signing data transfer agreements such as Standard Contractual Clause agreements.”
ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.
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