This Privacy Notice (“Privacy Notice”) describes the privacy practices of Flowium (collectively, “Flowium” or “us” or “we”).
Flowium provides marketing technology services to other businesses – our clients. To take advantage of our services, our clients share with us information about their individual consumers, including contact details and shopping histories. We analyze that information and develop and send communications to the consumers only at the direction of the client who provided the information, and only on that client’s behalf.
We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential customers or job applicants’ resumes. We do not collect employee or HR related data in the EU or Switzerland, or transfer such information either into or out of the EU or Switzerland.
This Privacy Notice applies to:
- The flowium.com website and any other websites or online services controlled by us and which display this Privacy Notice, and
- Marketing services that we provide to our clients.
1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, and it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information.
2.0 RELEVANT LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- EU-US and Swiss-US Privacy Shield
- California Consumer Privacy Act (CCPA)
This site’s compliance with the above legislation, all of which are stringent, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
How we collect the information
We may collect information:
- Directly from individuals
- From third party vendors, data brokers, or business partners
Types of information we collect
The types of information we collect include:
- Personal and business contact information (such as name, business name, address, telephone number, email address, and mailing address)
- Payment information (such as credit card or other financial account numbers)
Flowium collects and uses personal information for the following reasons:
3.1 Information You Provide to Us
We collect information you provide to us, for example when you create or modify your account, register to use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This information may include name; address; address; email address; telephone number; credit card, debit card number or bank account number (solely for payment purposes); IP address; and other information you choose to submit to us.
3.2 Information We Collect Automatically Through Your Use of our Site
Google Analytics and Google Tag Manager Privacy notice
Like most websites, this site uses Google Analytics (GA), and Google Tag Manager (GTM) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA, GTM also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor (see section 8.0 below).
Flowium uses the analytics.js implementation of GA.
(“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on how your online activity is.
Disabling cookies on your internet browser will stop GA, GTM from tracking any part of your visit to pages on this website.
Pixel Tags and Cookies
This website is built on WordPress CMS. Like most website operators, WordPress collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. WordPress’s purpose in collecting non-personally identifying information is to better understand how WordPress visitors use its website. From time to time, WordPress may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
Disabling cookies on your internet browser will stop WordPress, Facebook and other tools from tracking any part of your visit to pages on this website.
Third Party Data Sources
We use third party data sources to identify and provide contact information about visitors to Third Party Sites who have opted in to allowing their personal information to be shared with third parties. We then share the contact information of visitors to Third Party Sites with our Site Owner customers.
No Information from Children Under Age 13
If you are under the age of 13, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please Contact Us.
3.3 Contact forms and emails
Should you choose to contact us using the contact form on our Contact us page, none of the data that you supply will be stored by this website. This data will be processed by one of the third party data processors defined in section 8.0.
Also when you contact us at Contact Us page email address, your name and other data about your business will be forwarded to us via Pipedrive CRM who provide us their CRM to store and manage data about our customers. We consider Pipedrive to be a third party data processor (see section 6.0 below). The email address, your name that you submit will not be stored in our Flowium website’s database or in any of our internal computer systems.
When you send the email to us the data will be collated into an email and sent to us over the Google Gsuite who provide us their Email Servers to store and manage data about our customers via emails. We consider Google Gsuite to be a third party data processor (see section 8.0 below).
Your email address, your name, your phone number, your Address, zip code, and location will remain within our JotForm database for as long as we continue to use JotForm services. At some Contact Forms, we would collect your Organization and Resource number. In addition, the data you put in the contact form will be collated into an email and sent to us, on our computer and email server.
The data will remain on these systems until you specifically request removal. You can do this by requesting removal at this page, or you can send us an email. If you need to delete, update or download your personal information which is hosted on our Pipedrive database, or at Google Gsuite please send us an email or you can do that by requesting an update or downloading your personal data at this page.
3.4 Email newsletter
If you choose to join our email newsletter, the email address and the name you submit in the form on the web page will be forwarded to ActiveCampaign. ActiveCampaign is the provider of our email and newsletter services. We consider ActiveCampaign to be a third party data processor (see section 6.0 below). The email address and name, and some other data, as business details, that you submit will not be stored in our Flowium database.
Your email address and name will remain within ActiveCampaign’s database for as long as we continue to use ActiveCampaign’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal – you can send us an email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 13 years of age, you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the ActiveCampaign database, you will receive periodic newsletter-style emails from us.
4.0 HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3 above, if you sign up via this website some personal information will be stored in this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in WordPress Database, and we can only manually identify and update, delete this information; it’s a limitation of the content management system that this website is built on (WordPress and hosted by Kinsta).
5.0 ABOUT THIS WEBSITE’S SERVER
This website is hosted by Kinsta. Full details of Kinsta security features can be found here.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6.0 OUR USE OF PERSONAL INFORMATION
Our Use of Personal Information for Flowium Own Business Purposes
We may use personal information to:
- Provide our services to our clients
- Communicate about the products and services we offer, and respond to requests, inquiries, comments, and suggestions
- Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)
- Operate, evaluate and improve our business, our websites, and other products and services we offer (including to develop new products and services)
- Invoice and collect payment for our services
- Establish and maintain an individual’s profile in our service
- Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)
- Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide
- Process employment applications
- Monitor recruiting statistics, to inform our recruitment activities
We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
7.0 INFORMATION WE SHARE
We may share personal information for the purposes set out in this Privacy Notice with:
- Service providers that perform services on our behalf, such as technology providers (including providers of payment processing, technology support, web hosting, and email communications)
- Survey and market research providers
- Advertising and marketing partners
- Analytics organizations
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
8.0 OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen, and all of them comply with the legislation set out in section 2.0. All 5 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
9.0 PRIVACY PREFERENCES, RIGHTS, AND CHOICES
Individuals have certain rights and choices regarding Flowium’s processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.
Individuals whose personal information Flowium processes on behalf of a client should contact that client to exercise the rights and choices described in this section.
We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.
9.1 General Objections to the Processing of Personal Information
To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Flowium’s use or disclosure of your personal information will mean that Flowium will not be able to provide products or services to you or to otherwise engage with you.
9.2 Access to Personal Information
You may request access to correct, amend, or delete the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection. If you wish to exercise this right please contact us here at privacy@Flowium.com
We will also provide an EU or Swiss individuals with opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
To limit the use and disclosure of your personal information, please submit a written request to email@example.com.
9.3 Portability of Personal Information
You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
9.4 Deletion of Personal Information
You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
9.5 Marketing Emails
You may unsubscribe from receiving marketing or other commercial emails from Flowium by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).
9.6 Online Behavioral Advertising
Some of the business partners that collect information about users’ activities on our websites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. For example, users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
9.7 INTERNATIONAL DATA TRANSFERS
We may transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where Flowium is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.
9.8 EU-US PRIVACY SHIELD & SWISS-US PRIVACY SHIELD CERTIFICATIONS
Flowium participates in the EU-US Privacy Shield framework and Swiss-U.S. Privacy Shield framework.
In particular, if Flowium transfers to its service providers any personal information that Flowium received in reliance on its Privacy Shield certification, Flowium is responsible for the third parties’ processing of that personal information, unless Flowium proves that it is not responsible for the event giving rise to the damage. Please be aware that Flowium may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Flowium is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Flowium has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
As further explained in the Privacy Shield Principles more fully described here, you may be entitled to invoke binding arbitration pertaining to certain residual complaints that have not been resolved by any other means.
10.0 HOW WE PROTECT INFORMATION
We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized access, disclosure, alteration, use, loss, or destruction. However, we cannot guarantee that the safeguards we maintain will ensure the security of the personal information.
11.0 DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
11.1 CHANGING INFORMATION
12.0 DATA CONTROLLER
The data controller of this website is: Aboychuk Inc. (DBA Flowium)
Flowium, company number: 3476835586
Whose registered office is 57 Beach Street, Staten Island NY 10304
13.0 DATA PROTECTION OFFICER
Founder at Flowium.
14.0 DATA RETENTION
We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.
15.0 HOW TO CONTACT US
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or if you wish to access, delete or correct you information, by emailing firstname.lastname@example.org.
If you are a resident within the European Economic Area, you also have the right to file a complaint with the supervisory authority of your member state.