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Privacy

Flow Commerce, Inc. Privacy Policy

This privacy policy is for Flow Commerce, Inc. and its subsidiaries (together, “Flow”) (“Privacy Policy”). Flow understands that your privacy is very important to you. Rest assured that your privacy and trust are also very important to us.

This Privacy Policy details the personal information we collect about you, the means through which we collect that information, with whom we share it, and how you can change your preferences regarding how we collect and use your information when you provide it to us at our home site, www.flow.io, or at our

retail partners’ websites where you may purchase goods and services from Flow (together, the “Flow Websites”). BY (i) CLICKING THE TICK BOX TO ACCEPT THIS PRIVACY POLICY, (ii) USING THE FLOW WEBSITES,  AND/OR (iii) MAKING A PURCHASE ON A FLOW WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

European Users should see the final section of this Privacy Policy below for more information on the specific provisions and practices that apply to them. BY CLICKING THE TICK BOX TO ACCEPT THIS PRIVACY POLICY, EUROPEAN USERS ARE AGREEING TO THE TRANSFER, STORING AND PROCESSING OF THEIR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA, AS DESCRIBED IN THIS PRIVACY POLICY.

What Types of Personal Information Does Flow Collect?

We collect, store, and use information that you provide directly to us and information we acquire in other ways, each as detailed below:

What Cookies and Other Technologies Does Flow Use?

A cookie is a small file downloaded on to a device when a user accesses certain websites. When you interact with Flow or its partners, cookies and other technologies may be used for storing information, and accessing information stored on your devices, such as your computer, mobile device or other device. These cookies and other technologies may include first party cookies (i.e., those placed by the website being visited) and third party cookies (i.e., those placed by a website other than the one being visited), local shared objects (“LSO,” and commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and tracking pixels (including transparent or clear gifs also known as “web beacons”).

Cookies can either expire at the end of a session (“Session Cookies”) or be persistent and last through multiple sessions (“Persistent Cookies”). Session Cookies can be helpful for remembering items you put in your shopping cart as you browse a site, or for security reasons when you are providing financial information. Persistent Cookies are stored on your device in between sessions, which allows for your preferences or actions to be remembered and used on a website (or in some cases across different websites). Persistent Cookies may be helpful in remembering your preferences and choices when using a website or to ensure advertising messages are more relevant to you. Cookies are useful because they allow us to recognize your device and provide you with a high level of service and relevant offers.

The Flow Websites may include Social Media Features, such as the Facebook “Like” button and widgets such as the “Share” button or interactive mini-programs that run on the Flow Websites. These Social Media Features may collect your IP address, which page you are visiting on a Flow Website, and may set a cookie to enable the feature to function properly. Social Media Features and widgets are either hosted by a third party or hosted directly on the Flow Websites. Your interactions with these Social Media Features are governed by the privacy policy of the company providing the Social Media Feature.

Broadly speaking, Cookies placed on your computer or device fall into two categories:

The www.flow.io website (our “Site”) or our retail partners’ websites where you may purchase goods and services from Flow (“ Flow Websites”) may use the following types of Cookies for the purposes set out below:

Type of cookie Purpose
Essential Cookies  These Cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
Functionality Cookies These Cookies allow our Site to remember choices you make when you use our Site, such as remembering your currency and language preferences, remembering your log-in details and remembering the changes you make to other parts of our Site which you can customize.

The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.

Analytics and performance Cookies These Cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages that they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own Cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics Cookies here: Click Here
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html
You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=enGB
Targeted and advertising Cookies These Cookies track your browsing habits to enable you to see advertising which is more likely to be of interest to you. These Cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place Cookies to enable them to show adverts which will be relevant to your interests while you are on third party websites.

 

How Can I Disable Cookies? 

To limit disclosures and use of personal data – you can typically remove or reject Cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept Cookies until you change your settings.  You can take additional steps to disable or delete similar data, such as Flash Cookies, by modifying the “add-on” settings on your browser. Various browsers may offer their own management tools for access to HTML5 LSOs. However, please note that certain Cookies are required for you to be able to take advantage of some of Flow’s important functions. For example, if you do not allow our cookies, you may not be able to purchase items from one of our checkouts. You may find specific instructions for disabling cookies in some of the popular browsers via the following links: Google Chrome, Safari, Mozilla Firefox, Microsoft Internet Explorer. 

Use of Cookies on Flow Websites.

In addition to any Cookies that may be set via our Site, with their permission, we may also set Cookies via our partners’ Flow Websites to assist both them and you in our provision of the Flow Services.

How Does Flow Use and Share Your Information? 

The type or identity of third parties to which Flow discloses personal information and the purpose is addressed herein. We use and retain your information as needed to provide you services, ship and track your order, maintain a record of your purchases and returns, comply with our legal obligations, resolve disputes, and for other legitimate business reasons. By way of example, and not limitation, we analyze transactional data for the purpose of identifying trends, statistics and measurements that could contribute to the enhancement of Flow services. Such use could include identifying market sensitivities, and relative market interest in specific product categories. Another example would be if you place an order with us through a Flow Website, we (directly or through our merchant supplier or other entity on our behalf) may contact you if there is an issue with the order (e.g., to find an alternative to a restricted item).

We do not sell your information to others and do not share your information with third parties other than as outlined in this Privacy Policy. However, there are certain situations where we may provide your information to third parties.

In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar events, certain information in our possession may be transferred to our successor or assign.

How Does Flow Handle, Store and Secure Your Information?

We take the security of your data very seriously at Flow. We use a variety of current technologies and processes to protect your data, including encryption at both the storage and transport level. However, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

The security of your password is key to the security of your data. We recommend that you do not share, reuse, or store any of the passwords you may have set up with any of Flow’s retail partners with anyone else.

What You Should Understand About Third-Party Advertisers and Links to Other Websites?

The Flow Websites may include third-party advertising and links to partner websites or other third-party websites. We are not responsible for the content displayed or the practices of any such websites. We recommend that you review the privacy policy and terms and conditions of those websites.

Does Flow Transfer Your Data Cross Border?

Flow adheres to applicable laws and regulations regarding your personal information moving across geographical and jurisdictional borders. This includes the use of data transfer agreements and model contractual clauses, where available, between our corporate entities, our partners and our clients where required.

Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see How Does Flow Use and Share Your Information?), which may be situated in, or employ staff in,  places other than your home jurisdiction, the U.S. and/or the European Economic Area (EEA).  The countries concerned may not have similar data protection laws to your home jurisdiction, the US and the EEA.  Where we transfer your information we will take all reasonable steps to ensure that your privacy continue to be protected.  By submitting information via the Flow Website, you agree to this storing, processing and/or transfer.

Flow complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of

Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Flow has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the

Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.

Flow’s participation in the Privacy Shield applies to all personal data that is subject to the Privacy Policy and is received from the European Union, European Economic Area, and Switzerland.  Flow will comply with the Privacy Shield Principles in respect of such personal data, as well as the U.S.-Swiss Safe Harbor Framework and its principles, for which Flow’s participation has been registered separately.

Flow’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Flow remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Flow proves that it is not responsible for the event giving rise to the damage.

We encourage you to contact us should you have a Privacy Shield-related (or general privacy-related) complaint. For any complaints that cannot be resolved with Flow directly, Flow has chosen to cooperate with EU data protection authorities (DPAs) and comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints (as further described in the Privacy Shield Principles). If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider TRUSTe (free of charge) at  https://feedbackform.truste.com/watchdog/request.

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Flow is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) and the US Department of Transportation.

European Users should see the final section of this Privacy Policy below for more information on the specific provisions and practices that apply to them regarding cross border data transfers.

Are Children Allowed to Use Flow?

Flow does not allow anyone under the age of 18 to take part in any of its services. If you are under the age of 18, you must stop using the Flow Websites and taking part in its services now. To be clear, but not to limit what you are not allowed to do, if you are under 18, you may not make purchases from Flow or any of its partners, you may not click through to any of our partners’ websites, and you may not take part in any surveys, panels or the like.

What Should I Know About Changes to This Privacy Policy?

If we decide to change this Privacy Policy, we will post the updated policy at https://www.flow.io/help/privacy. We reserve the right to modify this Privacy Policy at any time, so please come to this link to review it frequently. If we make significantly material changes to this Privacy Policy, we will notify you by means of a notice on www.Flow.io prior to the change becoming effective.

What are the Terms & Conditions and Dispute Resolution?

If you choose to visit Flow and/or use any of Flow’s services, your visits and actions, and any disputes over privacy shall be governed exclusively by this Privacy Policy and the Terms & Conditions at www.Flow.io, including limitations on liability and exclusive application of the laws of and jurisdiction of the state of New York.

How to Contact Us:

If you have questions or concerns regarding this Privacy Policy, including any questions or complaints related to the EU-U.S. Privacy Shield Framework or U.S.-Swiss Safe Harbor Framework, please contact us as via at help@flow.io or by calling us directly at +1 929 265-2865.

Flow Commerce Inc.

22 Hudson Place

Hoboken, NJ 07030

United States

PROVISIONS SPECIFIC TO EUROPEAN USERS

What constitutes Personal Data?

When we refer to “Personal Data” this term means all data and information comprised in your Personal Information by which you can be actually be identified or could be identifiable, whether simply from that information alone, or in combination with any other readily available information. To the extent it meets the definition, each reference to how we deal with your Personal Information in this Privacy Policy shall, for users based in the European Economic Area (“European Users”), be read as a reference to Personal Data.

Who is the data controller of your Personal Data? 

For the purpose of any legislation or binding local regulations implementing the provisions of Directive 95/46/EC of the European Parliament (the ”EU Directive”), we are a data controller .

How do we deal with “Aggregated Content” of our European Users?

When used in reference to European Users, “Aggregated Content” means information that is aggregated and anonymized such that it no longer permits any individual natural person to be identified or identifiable, either alone or when combined with any other readily available information.

We may create Aggregated Content from the Personal Data we receive about you and other individuals whose Personal Data we collect.  Anonymous Information might include analytics information and information collected by us using Cookies.

Opting out of target advertising 

You can disable Cookies which remember your browsing habits and target advertising at you by visiting  http://www.youronlinechoices.com/.  If you choose to remove targeted or advertising Cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove Cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, so you may still receive some Cookies and tailored adverts from companies that are not listed. With your consent, we may transfer your Personal Data outside the European Economic Area  

Flow is a US company, this means that we store and process your Personal Data in the United States.  A large number of our staff are based in the United States – to allow us to provide you with our services they need to access and process your Personal Data. Personal Data that we collect and process may also be transferred to, and stored at, certain other destinations outside the European Economic Area.  

Consent to storage and processing of your data outside the European Economic Area. 

We ask for your consent to transfer, store or process your Personal Data in countries outside the European Economic Area, including the United States, to allow us to provide the Services.  By visiting www.flow.io or making a purchase on a Flow website, you agree to the transfer, storing or processing of your Personal Data outside the European Economic Area, as described in this Privacy Policy.

Wherever it is stored or processed, Flow will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. For example, we seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. We also take reasonable steps to procure that our service providers who access and process your Personal Data on our behalf do the same.

Access

You may access the information we hold about you. If you wish to exercise this right, please contact us using the details in the “How to Contact Us” section above.

You can also contact us using the details in the “How to Contact Us” section above to update or correct any inaccuracies in the Personal Data we hold about you. In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data that you have provided to us.  For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Retention Period 

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Sensitive Personal Data

We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) to us or our partners (whether via our Site or another Flow Website).