Updated DATE: May 24, 2018
We are committed to treating your personal information in a responsible and safe manner.
Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it.
For the purposes of the Data Protection Act (‘the DPA’) and the EU General Data Protection Regulation (‘the GDPR’), sensitive information includes what is defined as your ‘personal data’; this is information that could identify you.
2.1 What is included?
This Privacy Notice describes how Flo-culture collects, discloses, stores, transfers, and uses personally identifiable information of users collected through our Service (“Personal Information”).
2.2 How am I involved?
This notice applies immediately to users who utilise the Service on or after the Effective Date. Any person who does not agree to be bound by this Privacy Notice should not utilise the Service.
By using our Service, you accept and consent to the practices described in this Privacy Notice including the processing of your personal data under this lawful basis.
2.3 Our approach
In this Privacy Notice, we seek to abide by the letter and spirit of the guidelines laid out by the UK Information Commissioner’s Office (ICO) in the document ‘Privacy Notices, Transparency and Control’.
We have listed the following definitions to help clarify what the different terms in our Privacy Notice cover.
- “Flo-culture” means Flo-culture Ltd and its current and future affiliates and subsidiaries
- “Flo-culture Affiliates” means any parent, subsidiary, member, officer, director, employee, agent, or contractor of Flo-culture or any entity under common control with Flo-culture.
- “Service” means collectively, the Software, the Website, and any other Flo-culture services that link to this Privacy Notice
- “Software” means collectively, Flo-culture software and applications, including, without limitation, mobile software and applications.
- “Website” means collectively, the Flo-culture website, located at www.flo-culture.com and any other Flo-culture websites that link to this Privacy Notice,
- “we,” “us,” “our,” and other similar references mean Flo-culture, and “you” and “your” and other similar references mean any particular user of the Service.
- “Contact Information” means (i) your name, (ii) your physical address, (iii) your email address, (iv) your telephone number, and (v) any other Personal Information that we may collect to identify or contact you (including, without limitation, your Skype ID, Twitter username, etc.).
- “Partner Information” means information that our business partners share with us.
- “Privacy Notice” means the set of policies described in this document.
- “Service Information” means information gathered when you are using or accessing the Service.
- “Transaction Information” means all information related to transactions that you conduct on the Service and your interactions with the Service.
- “User Account” means an account registered with the Service and permitting access to the Service, with which is associated a user name and password.
- “User Account Information” means information that identifies you to the Service, and may include your user name, password, internet protocol address, and MAC address.
- “User Content” means images, comments, and other content, information, and materials that you post to or through the Service.
4 Who we are
We are Flo-culture Ltd, a company registered in England and Wales with Company number 10397623 and our registered office is Studio 0.02, Northern Design Centre, Abbott’s Hill, Gateshead NE8 3DF.
We are registered with ICO and for the purposes of DPA and in-line with the GDPR, Flo-culture Ltd is the Data Controller.
If you have any concerns about the way we use your information or any questions about this Privacy Notice, please let us know. We can be contacted via email at Katherine.firstname.lastname@example.org, or you can write to us at the address above.
5 Types of personal information we collect
Flo-culture collects Personal Information through the Service when it is included as part of the following types of information:
- Contact Information;
- User Account Information;
- User Content;
- Partner Information; and
- Service Information.
6 The basis on which we process information about you
There may be different reason for us processing informtion about you. These are described below.
6.1 Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- Verify your identity for security purposes
- Sell products to you
- Provide you with our services
- Provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
6.2 Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, job opportunities, our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us by contracting Katherine.email@example.com. However, if you do so, you may not be able to use our website or our services further.
6.3 Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- Whether the same objective could be achieved through other means
- Whether processing (or not processing) might cause you harm
- Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- Record-keeping for the proper and necessary administration of our business
- Responding to unsolicited communication from you to which we believe you would expect a response
- Protecting and asserting the legal rights of any party
- Protecting your interests where we believe we have a duty to do so
6.4 Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
7 Use of information we collect through automated systems when you visit our website and / or use our applications
We may employ, and/or our third-party tracking utility company may employ, software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our Website by informing us what content is effective. These gifs (or other tracking technology) may be included in or associated with emails or other communications that you receive from us (or our partners) in order to help us track your response and interests and to deliver you relevant content and services. For example, they may let us know when you take actions based on the emails that we send. We may tie information gathered by clear gifs or other tracking technology to Personal Information.
7.3 Server recording
Our servers may automatically record certain information about how a person uses our Website and Service (we refer to this information as “Log Data”), including both User Account holders and non-account holders. Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Website or Service to which a user browsed and the time spent on those pages or features, the frequency with which the Website or Service is used by a user, search terms used by a user, the links on our Website or Service that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
7.4 Behavioural targeting / re-targeting
7.5 Social media widgets
Our Service may include social media features, such as the Facebook “like” button, and widgets, such as the “share this” button. These features may collect your Personal Information and track your use of the Website. These social media features are either hosted by a third party or hosted directly on our Site. By using these tools, you acknowledge that some information from your social media services may be transmitted to us and therefore is covered by this Privacy Notice.
8 Other interactions
Our Service is not intended for children under the age of 18, and therefore, Flo-culture does not knowingly acquire or receive Personal Information from children under the age of 18. If we later learn that any user of our Service is under the age of 18, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.
If you are under 18, you may use our Service only with consent from a parent or guardian.
8.2 Email policies
Flo-culture may send you emails relating to your User Account and the Service. We will give you the ability to opt out of marketing-related emails by logging in and changing your account settings or by clicking on a link at the bottom of each such email. In some of our communications, we use tracking means, to tell us when an email is opened or a “click-through URL” linked to content on the Website. We track this data to help us measure the effectiveness of our customer communications. You cannot opt out of receiving certain non-marketing emails regarding the Service, and you agree to receive them.
8.3 Aggregate information
Generally, the Service may collect and analyse usage and performance information that is not Personal Information, or that Flo-culture aggregates or de-identifies so that it is not personally identifiable. From time to time, Flo-culture may release this information in the aggregate, e.g., by publishing a report on trends in the usage of its Service.
8.4 Interactions with others
The Service may contain areas where you may be able to publicly post information, communicate with others, submit media content, and/or review goods, services, or vendors, such as discussion boards or blogs. Any information, including Personal Information that you post there, will be public and may be viewed by the public at large, and therefore anyone who accesses such postings will have the ability to read, collect, and further disseminate such information. We have no control over, and take no responsibility for, the use, storage, or dissemination of information posted or otherwise made available on such portions of the Service. By posting Personal Information online in public forums, you may receive unsolicited messages from other parties.
8.5 Privacy practices of third parties
We have no responsibility for the privacy practices of third parties. This Privacy Notice applies only to the Service. It does not apply to products, services, or sites that are provided by or operated by third parties, even if such products, services or sites are linked or redirected to or from the Service (“Third-Party Sites”), regardless of whether or not such link or redirection is authorised by Flo-culture. Third-Party Sites may have their own policies regarding privacy, or no policy at all. The fact that we link to a Third-Party Site is not an endorsement, authorisation, or representation that we are affiliated with that third party. Flo-culture is not responsible for Third-Party Sites and you use them at your own risk. We encourage you to read the privacy policies and terms of the Third-Party Sites that you visit or use.
9 What we do to ensure the security of your personal information
We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.
We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.
We have policies and practices in place that not only ensure our compliance under the DPA but also the GDPR, including training and adequate procedures put in place for any staff that handle or have access to sensitive information.
9.1 Data storage & transfer
Our servers are hosted in London and Paris.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed outside the European Union.
We use the following safeguards with respect to data transferred outside the European Union:
- The processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
- The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
- We comply with a code of conduct approved by a supervisory authority in the European Union.
- We are certified under an approved certification mechanism as provided for in the GDPR.
- Both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
10 Your rights regarding your personal information
We may contact you via email with updates about the services that we offer or any changes that we have made to our Website.
You can opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our service may be advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
10.1 Your rights
You have the right to find out about what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days. To make a request for information please contact Katherine.firstname.lastname@example.org and a member of our team will be in touch.
If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date. If your data is incorrect then please contact us at the email address above and a member of the team will rectify this on your behalf.
You have the right ‘to be forgotten’ and to have your personal identifiable information permanently deleted from our systems. Again, if you would like to exercise this right then please contact us at Katherine.email@example.com
There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.
10.2 How long we hold your information for
At Flo-culture have procedures in place to regularly review every 12 months what personal data we hold. If you have not interacted with us or accessed our services during this or the subsequent period then we will delete your personal data from our systems, but will send you an email first informing you of our intention to do so. Of course, you have the right to be forgotten at any point. See ‘Your right’s’ section above.
10.3 Business transfers
Flo-culture may sell, transfer, or otherwise share some or all of its business or assets, including your Personal Information, in connection with a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets or in the event of bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of Flo-culture or its assets may continue to use your Personal Information as set forth in this Privacy Notice. You will be notified via email and/or a prominent notice on our Website or Service of any change in ownership or resulting change in uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
11 Changes to this Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on our website. The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our Service.