Privacy Policy

Approved: 14.07.2021

Published: 26.07.2021

Will be reviewed: 14.07.2022

This Privacy Policy explains our practices regarding the collection, use and disclosure of information that we receive through our Services, and how you can opt-out of a use or correct or change such information. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service (the “Terms”). Please make sure that you have read and understood our Terms.

This Privacy Policy applies to any information relating to an identified or identifiable natural person (“Personal Information”) that is collected, recorded, organized, structured, stored, adapted or altered, retrieved, consulted, used, disclosed by transmission, dissemination or otherwise made available, aligned or combined, restricted, erased, or destroyed, whether or not by automatic means, or any other operation performed on Personal Information (“Processed”) by Flow through our Services.

Types of Personal Information We Collect

Flow collects the following categories of information about users of the Services:

Communications with Us. We may collect Personal Information from you such as your name, email address, phone number, and postal address when you request information about our Services, register for Flow’s newsletter, request to receive customer or technical support, or otherwise communicate with us. Information in regards to Communication is processed on the basis of Legitimate interests.

Account Information. If you create an Account, we’ll collect certain information that can be used to identify you, such as your name, age, email address, state of residence, and mobile number. If you create an Account using your login credentials from one of your SNS Accounts, we’ll be able to access and collect your name and email address and other Personal Information that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information. Information necessary to provide you with an Account is processed on the basis of Contractual Obligation.

Session Data. We may measure, collect and store your Session Data, your mood and feelings (measured through your responses to surveys and questionnaires in the App), in connection with your use of the Services; if you use the Services through an Account, Session Data may include Personal Information.

Third-Party Services

Our Services may support integrations with your accounts for certain third-party services, for example, Apple Health Kit or Google Fit. We may receive Personal Information about you from third-party services that you permit us to access, such as fitness activity data about you. Such information may be associated with your Account. You may enable or disable integrations with third-party applications via our Services.

Information Collected Using Cookies and Other Technologies. Like many websites and mobile application owners and operators, we use automated data collection tools such as cookies and web beacons to collect certain information, as described in Section 3.

The Services may contain links to other websites and other websites may reference or link to our Services. The Services may also support integrations with your accounts for certain third-party services such as Apple Health Kit or Google Fit. Any information that you provide on or to a third-party service or that is collected by a third-party service is provided directly to the owner or operator of the third-party service and is subject to the owner’s or operator’s privacy policy. We encourage our users to read the privacy policies of these third-party services. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites, services or applications. Visiting these other websites or applications, or using these third-party services, is at your own risk.

When you purchase a Subscription, you expressly authorize us (or our third-party payment processor) to charge you for such purchase. We may ask you to supply additional information relevant to your purchase, including your credit card number, the expiration date of your credit card, and your email and postal addresses for billing and notification (such information, “Payment Information”).

Location Information

When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

How Flow Uses Your Information

We collect, store, use, and Process Personal Information about users for a variety of business purposes, including to:

To Fulfill our Agreement with You and Provide our Services. Flow will use your Personal Information to provide and improve the Services, including: managing Accounts; undertaking activities to verify or maintain the quality or safety of our Services; processing payments and transactions; communicating with you about your Account, activities on our Services and policy changes; providing our newsletter; or providing customer or technical support.

Analyze and Improve our Services Pursuant to Our Legitimate Interest. Flow may use your Personal Information for other purposes pursuant to our legitimate interest, including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; measuring interest and engagement in our Services; improving, researching, and developing products and services, and marketing and security procedures; maintaining, repairing, or debugging our Services; verifying your identity and preventing fraud; and complying with our legal obligations, protecting your vital interests, or as may be required for the public good.

De-Identified and Aggregated Information Use. Flow may use your Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, and Flow may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information with third parties.

Other Uses

Flow may use your Personal Information for other purposes which are disclosed to you at the time you provide Personal Information or with your consent.

Cookies, Pixel Tags/Web Beacons, and Analytics Information

We, as well as third parties that provide content or other functionality on our Services, may use cookies and web beacons, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. This information may include your IP address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with Accounts and other devices. In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.

Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

Pixel Tags/Web Beacons.

A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.

Analytics

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting, and other service providers, to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use Technologies that are necessary to the operation of our Services. This includes technologies that allow you access to our Services; or that are required to identify irregular site behavior, prevent fraudulent activity and improve security;

Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine whether you have viewed an item or link, or to improve our Services;

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using the Services. This may include identifying you when you sign into the Services or keeping track of your specific preferences, interests, or past items viewed so that we may enhance the presentation of content on the Services;

If you would like to opt-out of the Technologies we employ on our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Information We Share

We may share your information as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property).

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) payment processing; (iii) customer service activities; and (iv) in connection with the provision of the Services. Flow has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Business Partners

Flow may share Personal Information with its business partners, and affiliates for it and its affiliates’ internal business purposes or to provide you with a product or service that you have requested. Flow requires its affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on its behalf and not to use it for any purpose other than the purpose for which Flow provided the information.

Displaying to Other Users

The content you post to the Services may be displayed on the Services. We are not responsible for the privacy practices of the other users who will view and use the posted information.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) to respond to your requests; (iii) to protect your, our or others’ rights, property, or safety; (iv) to enforce Flow policies or contracts; (v) to collect amounts owed to Flow; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers. Information that we collect from our users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.

Opt-Out (Right to Restrict Processing)

GENERAL

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Flow’s Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting info@flow.is. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Services and for other legal purposes as described above.

EMAIL AND TELEPHONE COMMUNICATIONS

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Flow and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

“DO NOT TRACK”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. You can also choose not to be included in Google Analytics https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en. To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether Flow is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an email to info@flow.is or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Flow. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Flow makes good faith efforts to provide users with access to their Personal Information, there may be circumstances in which Flow is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If Flow determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Flow will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Data Retention

Flow retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Flow removes all your personally identifiable information, if you delete your account.

Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an email to you. You may have a legal right to receive this notice in writing.

Children’s Privacy

The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Flow does not knowingly collect Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at info@flow.is. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information from our files as soon as possible.

Redress/Compliance and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact Flow by email at info@flow.is. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Supervisory Authority. If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.

Changes to Our Privacy Policy and Practices

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy regarding how we process Personal information, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

If you have questions about our privacy practices or this Privacy Policy, please contact us at info@flow.is