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Privacy Policy
This Privacy Policy will let you know how we at Flow 48 will collect, process, store and protect your personal information when you visit our website (www.flow48.com) or utilise our services and products (together, the “Services”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Our Services are not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Who we are
The data controller is Flow 48 Limited and is responsible for your personal data (referred to as Flow 48, "we", "us" or "our" in this Privacy Policy). If you have any questions about this Privacy Policy, please contact us at:
hello@flow48.com.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The Data We Collect About You
This Privacy Policy applies to personal information processed by us. Personal information is information that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.
The type of personal information we collect will depend on the Services you utilise, and the requirements of applicable law. We will collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations such as credit reports, and other KYC and compliance information.
We may collect, use, store and transfer personal data about you, such as identity data, contact data, financial data, professional data, transactional data, technical data, profile data, usage data, browsing data and marketing and communications data when you use our website, request information about our Services, register for our product, create an account, request marketing information, or otherwise communicate with us.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Professional data (company name, position, function).
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical and Browsing Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Any information you wish to send us as part of your contact request.
We may obtain information about you from other sources, including through third-party services. In addition, we may also collect information contained in a credit report or KYC report from a consumer reporting agency or fraud prevention agencies or from other public information databases such as fraud and OFAC reporting sources and Companies House.
Where we need to collect personal data by law, or under the terms of a contract we have with you in respect of our Services, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you our products). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How we use your personal data
We will only use your personal data when the law allows us to. We use your information for a variety of business purposes, including to provide our Services, for administrative and marketing purposes to pursue our legitimate business interests and to market our products and Services.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate and the period for which we will retain your data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest | Data Retention Period |
|---|---|---|---|
To register you as a new customer and/or to create a database of customers and prospects | (a) Identity | Performance of a contract with you. Our legitimate interest in developing and promoting our business | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us. |
To process and deliver transactions with you including: | (a) Identity | (a) Performance of a contract with you | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us |
To manage our relationship with you which will include: | (a) Identity | (a) Performance of a contract with you | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us. |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us. |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us. |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity | Necessary for our legitimate interests (to develop our products/services and grow our business) | For our customers: their personal data are retained for the duration of our business relationship and retained for a further 3 years from your last contact with us. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us. |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal information with our officers, employees, agents, contractors, group companies and/or our third-party service providers, professional advisors, business partners or affiliates who use that information to help us provide our Services. We may also share your personal information with our processors: hosting provider, CRM tool, learning management system tool, mailing provider; We may also share your personal data with regulators and other authorities who require reporting of processing activities in certain circumstances.
We also use, process and store your information for other purposes as requested by you, as we may disclose to you and/or as permitted by applicable law or in order to comply with law and our legal obligations or for other legitimate interests.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please refer to our cookies policy.
Data transfer
Your personal data is hosted for the duration of the processing on the servers of the company Amazon Web Services (AWS), located in London, UK.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United Kingdom or other countries, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information, we will use commercially reasonable efforts to ensure that the transfer is to a country that provides an adequate level of protection under applicable laws and one of the derogations for specific situations found in applicable law applies to the transfer including explicit consent, where such transfer is necessary for the performance of a contract or exercise, or the defense of legal claims; or the transfer is otherwise consistent with the requirements of applicable laws.
Our third-party service providers and CRM tools may store personal data outside of the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
Data retention
The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested deletion of the data, and whether we have any legal or regulatory obligation to retain the data. We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected. We will typically keep your data for up to 3 years after you last had an active account or product with us. We may keep your personal data for a longer period where it is necessary for legal, regulatory or operational purposes.
Your privacy rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please contact us at gdpr@flow48.com for any of the following:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us.
No fee usually requiredWe may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Modifications
We may modify this Privacy Policy at any time, in particular in order to comply with any regulatory, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this Privacy Policy.