Last Updated December 13, 2016
What is Personal Information?
Unless permitted by law, we will not collect, use or disclose your Personal Information for any purpose without first obtaining your consent. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the Personal Information for a new or different purpose.
In most cases, and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable advance notice. It should be noted that there may be certain portions of the Sites or Services that will only be made available to you if you provide specific Personal Information to us. Consequently, if you choose not provide us with any required Personal Information, we may not be able to make available to you such portions of the Sites or Services. We will endeavour to inform you of the consequences of the any such refusal or withdrawal of consent.
Why We May Collect Personal Information
We may collect Personal Information from you when you voluntarily provide it to us in order to: provide the Sites and Services to you and other persons in accordance with your settings of the Sites and Services; improve the Sites and Services; process payments relating to the Sites and Services; provide you with information relating to the Sites and Services, including, without limitation, products, services, promotional offerings and contests (including direct marketing); provide you with support in respect of the Sites and Services; conduct surveys and customer research; meet legal and regulatory requirements; or such other purposes consistent with the foregoing purposes.
How We Collect and Use Personal Information
We only collect, use and disclose Personal Information for purposes that would be considered reasonable in the circumstances and we only use fair and lawful methods to collect Personal Information. For example, we may collect Personal Information when you: fill in forms, register or configure accounts or services (including third party services available through the Sites or Services) participate in surveys, tests, or assessments; purchase products or services; submit content or communications, including, through forums, blogs, chatrooms, messaging services, personal web pages or other services available through the Sites or Services (including third party services); select advertisements or content, navigate the Sites or Services, or otherwise interact with the Sites or Services (including third party services); or otherwise participate in the Sites or Services (including third party services).
When We May Disclose Your Personal Information
We may disclose your Personal Information:
- to individuals or organizations who are involved in:
- providing the Sites or Services, or information relating to the Sites and Services (including, without limitation, products, services, promotional offerings and contests or other products, services, promotional offerings or contests), on our behalf;
- maintaining, reviewing or developing our business systems, procedures or infrastructure, including, without limitation, testing or upgrading of our computer systems;
- a transfer of all or part of the assets or business of Flow; ora corporate re-organization of Flow; or
- for any other purpose to which you consent.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where we are obliged to disclose Personal Information without consent. Such circumstances may include:
- where required by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity;
- where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of Flow, or its licensors, affiliates, users or other third parties;
- where it is necessary to establish or collect monies owing to us, our licensors or affiliates;
- where required to identify, contact, communicate or take action against an individual who is suspected of violating the Terms of Service; or
- where the information is publicly available.
Where obliged or permitted to disclose your Personal Information without consent, we will disclose no more Personal Information than is reasonably required.
The Accuracy and Retention of Personal Information
We endeavour to ensure that any Personal Information in our possession is as accurate, current and complete as necessary for the purposes for which we use and/or disclose such Personal Information. If we become aware that your Personal Information in our possession is inaccurate, out-of-date or incomplete, we will endeavour to revise such Personal Information accordingly.
We will retain your Personal Information only for so long as it is required for the purposes it was collected. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is reasonably necessary for us to have sufficient information to respond to any issues that may arise after the end of your relationship with us. When your Personal Information is no longer required, we will destroy, delete or convert it into an anonymous form.
Protection of Personal Information
We endeavour to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorized access, disclosure, or modification of Personal Information.
PLEASE NOTE: Some or all of your Personal Information that we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to disclosure to governments, courts, or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions and without notice to us or you. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that jurisdiction to maintain protections of your Personal Information that are equivalent to those that apply in the jurisdictions in which you live.
Access to Your Personal Information
We will permit you to access and correct your Personal Information as reasonably requested by you, and will endeavour to provide such access within a reasonable period, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require additional information to allow us to confirm that the individual making the request is authorized to do so before granting access or making corrections to such Personal Information.
We reserve the right to refuse, but have not obligation, to apply requested changes to your Personal Information if we reasonably believe that such changes are inaccurate, out-of-date or incomplete. Where we refuse to make changes to your Personal Information requested by you, we will inform you as to the reasons for our refusal.
We reserve the right, but have no obligation, to refuse to provide access to Personal Information where the Personal Information requested:
- would disclose: (i) Personal Information (including, without limitation, opinions) about another individual or about a deceased individual; or (ii) trade secrets or other confidential information that may harm Flow, or its licensors, affiliates, users or a third party;
- would interfere with contractual or other negotiations of Flow, or its licensors, affiliates, users or another third party;
- is subject to solicitor-client, litigation or other legal privilege;
- is not readily retrievable and the burden or cost of retrieving such Personal Information would be disproportionate to the nature or value of such Personal Information;
- does not exist, is not held, or cannot be located by us;
- could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
- may harm or interfere with law enforcement activities or other investigative or regulatory functions of a body authorized by law to perform such functions; or
- is requested to be withheld by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity.
Where we refuse to provide access to Personal Information, we will inform the individual making the request as to the reasons for our refusal.
We will not charge you for accessing or correcting your Personal Information, however, to the extent permitted by applicable law, we may charge you a fee if you request a copy of any records containing your Personal Information.
How Do We Gather Data By Automatic Means?
We may use cookie technology, web beacons and other similar devices on or with the Sites or Services to enhance functionality and navigation for our users. Information tracked through these mechanisms includes, but is not limited to: (i) user IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the website a user visits; (iv) other websites a user visited before visiting the Sites or Services; and (v) session information. If you wish to disable cookies, refer to your web browser instruction manual or help facilities. Please note that if you disable cookies, you may be unable to access some of the features of the Sites or Services. Cookies that we use in association with the Sites or Services do not collect or contain your Personal Information.
Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on or with the Sites or Services to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize the Sites and Services and improve your experience with the Sites and Services. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Like cookies, the web beacons used by us in association with the Sites and Services do not collect or contain your Personal Information.
Third Party Websites and Services
The Sites or Services may provide features that permit you to share information with other persons (for example, chat rooms, message boards, forums, messages and other user communications). You should be aware that when you voluntarily disclose your Personal Information using any of these features, your Personal Information may be collected, used or disclosed by such persons without restriction. This may result in unsolicited messages from third parties, identity theft and other harm to you. Any Personal Information that you disclose to such persons is entirely at your own risk. Flow assumes no responsibility or liability as to any harm that you may suffer as a result of such activities.
Resolving Your Privacy Concerns
• access or correct your Personal Information in our possession;
• request that we not send you mailings or otherwise contact you; or
Please contact our Privacy Officer at: firstname.lastname@example.org