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
This hierarchy clause means that the Privacy Statement's terms are subordinate to the DPF Principles, so the operative data-protection rules in a conflict scenario are those of the DPF framework rather than the Privacy Statement.
The updated policy now explicitly discloses that Fly.io uses third-party fraud-prevention services that collect device and browser signals (such as device identifiers and browser fingerprints) when you create an account or sign in. The policy states this data collection is mandatory and cannot be opted out of, distinguishing it from analytics collection, which remains optional. The company asserts its legal basis is its legitimate interest in protecting the platform and its users.
View change record →Where the Privacy Statement and the DPF Principles say different things, the DPF Principles are the rules that apply to your data.
How other platforms handle this
The Federal Trade Commission has jurisdiction over ZipRecruiter's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Glassdoor complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
Discord commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner's Office (ICO) and the Swiss Federal Data Protection and Information Commissioner...
"If there is any conflict between the terms in this Privacy Statement and the DPF Principles, the DPF Principles shall govern.Excerpt from Fly.io's Privacy Policy
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This hierarchy clause means that the Privacy Statement's terms are subordinate to the DPF Principles, so the operative data-protection rules in a conflict scenario are those of the DPF framework rather than the Privacy Statement.
Where the Privacy Statement and the DPF Principles say different things, the DPF Principles are the rules that apply to your data.
ConductAtlas has identified this type of provision across 267 platforms. See the full comparison.
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