Users in the UK or EEA may treat "Personal Information" in this Policy as meaning "Personal Data" as defined in applicable local law and should consult section 5 below
Users in California and states with comparable privacy laws should consult section 13 below regarding their rights and choices in regard to Personal Information.
We encourage you to read this Policy carefully. Any updates or modifications to this Policy will be posted to our website on this page. By using or accessing the Website, you signify that you have read, understand and agree to be bound by this Policy. This Policy was modified on August 2, 2023.
1.When this Policy applies
This Policy applies when you use the Website or otherwise gather Personal Information about you. Please note that:
- This Policy does not apply to our current or former employees or contractors. If you are a current or former employee or contractor, you may contact us about your privacy practices and rights at email@example.com.
- If we receive your Personal Information in our role as a service provider for another business, the policies of that business govern our use of your Personal Information.
2.Personal Information we collect and how your Personal Information is collected
If you reside in the United States or do not purchase goods through the Flow.io platform, there are different types of Personal Information that may be collected through our Website:
(1) Identity Information such as your name, title, date of birth and gender. (2) Contact Information including your e-mail address, billing address, delivery address and phone numbers. (3) Financial Information including bank account and payment card details. (4) Transaction Information which includes details about payments to and from you and other details of products and services you have purchased from us. (5) Technical Information which includes information about your computer (for example your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website). (6) Usage Data which includes information about your use of the Website, products and services. (7) Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences. We also collect, use and share aggregated data such as statistical or demographic data for legitimate business purposes not prohibited herein or by applicable data protection law. Aggregated data may be derived from your Personal Information but is not considered personal data under applicable data protection law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.
If you choose to connect to our Website through a third-party social network such as Facebook (each, a “Social Network”), we may collect Personal Information from your profile on such Social Network, such as your name, username, and e-mail address, and we may publish your activity on our Website through such Social Network.
We may, from time to time, give you the ability to share our Website (or features or products thereon) with your friends. In order to do so, we may ask for certain Personal Information about your friends such as their name and e-mail address. It is solely your responsibility to ensure that your friend consents to receiving what you share from us. We will only use and store your friends’ Personal Information for as long as necessary to fulfill your request. It will be deleted promptly after your request has been fulfilled.
Whether or not you submit Personal Information, we may collect, store or accumulate certain Usage Data based on your use of our Website, such as information regarding which of our pages or products are most popular, the browser you use, your computer’s IP address, and the URLs you visited before and after using our Website. Please note that we will only collect your credit card information if you choose to purchase our products online via our Website and do not use the Flow.io platform. If you do make such an online purchase, our payment processing partner will collect your payment information and process your payment. We do not store any credit card information or share it with anyone other than our payment processor.
3.Uses and sharing of Personal Information
We use your Personal Information where:
- It is necessary for us to process the Personal Information so that we can provide products and services to you.
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- We need to comply with a legal or regulatory obligation.
- We have your consent.
We use your Personal Information that we collect directly to process your requests, fulfill your orders, run our contests, promotions and casting calls, authenticate website visits/usage, inform users of relevant products and specials through promotional e-mails, maintain and develop our Website, and communicate with you. You always will be given the opportunity to unsubscribe from further emails in any promotional messages we send you.
Except as described in this Policy, we will not disclose, rent, sell or share any Personal Information to unaffiliated third parties for marketing purposes.
We contract with companies or individuals to provide certain services including email and hosting services, software development, administration of contests, promotions and casting calls, credit card processing, shipping, data management, surveys and marketing, promotional services, etc. We call them our “Service Providers.” Such Service Providers include Flow.io, which processes certain orders for residents outside the United States.
We may share both your Personal Information with Service Providers solely as appropriate for them to perform their functions. We do not share your credit card or other account information with third parties unless you authorize us to do so, or if it is necessary to fulfill our responsibilities including, but not limited to, delivering a product or service that you order.
We may share your Personal Information with analytics providers, such as Google Analytics and Tag Manager servicers, to tell us how the Website is doing, such as to which part interest visitors and how long they visit before leaving. Among other data, they may receive a User’s IP address.
We may share your Personal Information (other than credit card information) with our affiliates and related companies. Our affiliates and related companies may contact you directly regarding certain promotions.
If you would like to opt out of having us share your Personal Information with our affiliates and related companies, please e-mail us at firstname.lastname@example.org and include “Opt Out” in the subject line.
Usage Data may be used in aggregate (anonymized) form for internal business purposes, such as generating statistics and developing marketing plans. We may share or transfer such aggregate, non-personally identifiable Usage Data with or to our affiliates, licensees and partners for administrative, analytical, research, optimization, security and other purposes, but no such information will be linked with your Personal Information or be used to identify or contact you.
We may share information with advertising partners to advertise our products and services to you. If you are a California resident you may opt out of such sharing by clicking “Do Not Share My Information” before entering the Website.
4.Data Retention - How long will we use your Personal Information?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for as specified in this Policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
For example, we delete some activity as soon as you exit the Website, whereas we may retain traffic data for analytics purposes.
5.Processing of Orders by Flow.io and the Rights of UK and EEA Residents
In conjunction with your use of the Flow.io facility, you have the option to consent to provide Flow.io with certain personal data relating to you, including Personal Information, to allow Flow.io to process your orders or good through our website. Such information may be considered “Personal Data” in the EEA under the General Data Protection Regulation (“GDPR”) and in the UK under the UK GDPR. Flow.io shares certain of this Personal Data with us so that we may fulfill or process your orders, facilitate returns, and respond to customer inquiries. If you do not provide such Personal Data, Flow.io may not be able to process your orders and we may not be able to fulfill your orders, facilitate returns or respond to customer inquiries. During the check-out process facilitated by Flow.io you also have the option to consent to provide Personal Data to us for marketing purposes. Your decision to provide such Personal Data through the Flow.io check out process or directly on our website is entirely optional. We may also collect Personal Data about residents outside the United States, including residents in the UK and the EEA, when you choose to fill out forms on our website to obtain information about us or our goods. We may combine the Personal Data that you provide through Flow.io with Personal Data provided by you directly through our website. We use that Personal Data to provide marketing information about our goods. We will not share the Personal Data that we obtain through Flow.io or directly from you with third parties except as described above in regard to Personal Information. You may withdraw your consent for us to process or retain your Personal Data by contacting us email@example.com with the subject line “Personal Data Request.” If we remove your Personal Data, we may no longer be able to provide you with certain services, including processing your orders or responding to your complaints or inquiries. You always have the right to instruct us to not process your Personal Data for marketing purposes.
If you are resident in the UK or the European Economic Area (“EEA”), including countries in the European Union (“EU”) or resident in certain locations outside the United States, you may have certain rights with respect to your Personal Data, including the rights to:
- Ask us for details of the Personal Data we hold and process about you.
- Ask that any inaccurate information we hold about you is corrected.
- Ask that we delete Personal Data that we hold about you.
- Ask that we stop using your Personal Data for certain purposes.
- Ask that we do not make decisions about you using completely automated means.
- Withdraw your consent to the processing of your Personal Data.
- Ask that we give you a copy of the Personal Data that we hold about you, or (where it is technically feasible for us to do so) that we give this Personal Data to a third party chosen by you, in a commonly-used, machine-readable, format.
If you are a resident of the UK or the EEA and wish to access or correct the Personal Data that we have about you or have any questions relating to the processing of your Personal Data, please contact us at firstname.lastname@example.org with the subject line “GDPR Data.”
If you have a complaint about how we handle your personal information or respond to your request, you have the right to complain to your data protection authority. We ask that you kindly contact us first via email at email@example.com, so that we have an opportunity to resolve your complaint.
6.International Data Transfers
Personal Data that is transferred to us by Flow.io with your consent or Personal Data that you submit directly to us through our website may be stored or processed in the United States, which does not have data protection laws equivalent to those in the UK or the EEA and other jurisdictions.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it in that country by putting safeguards in place, for example by using contract terms that have been approved by an appropriate data protection authority in the relevant jurisdiction.
If you do not wish your Personal Information to be stored or processed in the United States, please do not provide such information to Flow.io or to us. We protect all Personal Data transferred to the United States in the same manner as we protect Personal Information.
7.Privacy and security
It is entirely your choice whether or not you provide Personal Information to us. We take commercially reasonable and appropriate technical and organizational precautions to protect our customers' Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at firstname.lastname@example.org.
9.Children under 16
This website is targeted to adults. We do not knowingly collect or solicit personal information directly from anyone under the age of 16. If you are under 16, please leave the Website and please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from anyone under 16 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with Personal Information, please contact us at email@example.com.
11.Links to third-party websites
Our Website or emails may contain links to third party websites to which we have no affiliation. Except as set forth in this Policy, we do not share your Personal Information with those websites and are not responsible for the privacy policies of any other website or their management of your Personal Information. Because they may treat your Information differently than we do, we suggest you read the privacy policies on those third party websites prior to submitting any Personal Information.
12.Your rights and obligations
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at firstname.lastname@example.org. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person. If you wish to review, delete and/or revise the Personal Information we have stored about you, please contact us with your specific request at email@example.com; provided, however, that we reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information. If you are a resident of the UK or the EEA and other jurisdictions outside the United States, these qualifications may not apply to you. Please see the section entitled "Processing of Orders by Flow.io and the Rights of UK and EEA Residents". If you are a resident of California, the following section applies to you. If you use the Website, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.
13.Your California and other state privacy rights
This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights or substantially similar rights. Rights of California residents are specifically referred to as “rights under the CCPA” or “CCPA rights.”
Rights under the CCPA
The California Consumer Privacy Act (“CCPA”) provides California consumers rights regarding their Personal Information (as defined in the CCPA).
The categories of Personal Information we collect are generally described in the section above titled: Personal Information we collect and how your Personal Information is collected. These categories depend on how you use the Website.
Under the CCPA, qualifying California consumers may have the following rights:
Right to Know, Access, Correct and Delete
A California consumer has the CCPA rights to request that we disclose what Personal Information we collect, use, disclose, share or disclosed for a business purpose.
We may deny deletion requests, in whole or in part, with respect to information we reasonably need to:
- Comply with a legal obligation
- Allow you, other consumer, or us to exercise free-speech rights or other legal rights
- Perform a contract with you or
- If we use the information for solely internal purposes reasonably aligned with consumer expectations
Rights to Opt-Out of Sharing/Sale and Limit Use of Sensitive Information
You also have the CCPA rights to direct us (1) not to share or sell your Personal Information and (2) to limit our disclosure and your use of “sensitive personal information” necessary to provide the website to you.
When entering the website, California consumers have the right to opt-out of sharing or selling of Personal Information. If you wish to exercise this right you may also use the following link.
We do not collect “sensitive personal information” as it is defined in the CCPA and we therefore do not provide a mechanism to opt out of the use of such information.
We are in the process of updating the Website to honor any global opt-out preference signal sent from California IP address to the website through browser or device-level settings, provided the signal complies with the requirements of the CCPA. Our goal is for the website to automatically respond to compliant signals by opting California residents out of any sharing or sale of their data in a frictionless manner.
Please contact us if you believe the Website collected or processed your information in a manner inconsistent with your opt-out preference signal.
The CCPA prohibits us from discriminating against you if you exercise rights under the CCPA. You do not need to exercise this CCPA right. We never retaliate against anyone exercising their rights under the CCPA.
To submit a request to exercise a CCPA right, please submit a request as follows:
2335 W 208th St, Torrance, CA 90501
(with “Personal Information Request” in the subject line of your e-mail)
If we receive any request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests.If requests are unclear or submitted through means other than as outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If the requests are unclear we may respond with direction on how to remedy the deficiencies.
If we cannot verify the identity of the consumer making the request, we may deny the request in full or in part.
Responding to Requests
We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. For California consumers, we will confirm receipt of your CCPA request within 10 days and will substantively respond within 45 days, unless we provide an explanation why an additional 45 days is necessary. California residents may submit rights requests through an authorized agent. We may request proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.
The content of our response will vary with the nature of your request, but we will always respond in accordance with any deadlines or requirements specified by the laws that apply to you.
Under certain circumstances, we may be unable to provide responsive Personal Information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, users’ accounts with us, or the security or our systems and networks. We do not disclose account passwords or other non-personal information that enables users to access accounts. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medication identification numbers.
We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medication identification numbers, or account passwords and security questions and answers.
We reserve the right to retain an archive of any information about you to the extent permitted by law. We also retain de-identified or aggregate data derived from information about you.
California Do Not Track Disclosures
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Civil Code 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
We reserve the right to change this Policy at any time. In the event we make material changes to this Policy, such policy will be re-posted in the "Privacy" section of our Website with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy. If you have any questions about the changes that were implemented, please contact us at firstname.lastname@example.org and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Website after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Website or opt out by sending us an appropriate notice.
Our Website operates AS-IS, and we do not represent or warrant that our Website will be available at all times, or that your use of the Website will be uninterrupted or error-free. We are not responsible for your ability to access the Website or for matters beyond our control. This Policy will be governed by and construed in accordance with the laws of the State of California, without regard to any principles of conflicts of law. You agree that any action at law or in equity that arises out of or relates to any use of the Website will be filed only in the state or federal courts located in Los Angeles County, and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action. If you have questions or comments about this Policy, please contact us at email@example.com with “Website Privacy” in the subject line of your email.