YOUR PRIVACY IS IMPORTANT TO US
Updated May 4th, 2018
- Key Terms
- What information we collect about you
- How we collect personal information
- How we use your personal information
- How we share your personal information
- Your Rights
- How we protect your information
- How we retain your personal information
- Protecting your child’s privacy
- How to contact us
1. Key Terms
Flothemes offers digital products for business and personal use, including technical support, installation, design, and SEO services. We refer to all of these products as “Services” in this policy.
3. What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
- Information you provide to create an Account, specifically email address, first name and last name. If you purchase a product from us we also ask for payment and billing information when you register. For example, we ask you to designate a billing representative, including name and contact information, upon purchase. You might also provide payment information, such as payment card details, which we collect via secure payment processing services. We do not hold or store information related to your payments, we only receive confirmation from the payment provider you choose that payment has been processed.
- Your marketing preferences.
- The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others.
- Information you share with us in connection with surveys, contests or promotions.
- Information from your use of our Services. This includes: IP addresses, preferences, web pages you visited prior to coming to our or our site, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our site (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).
- Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
- Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Account (based on your privacy settings with such Third Party Service).
4. How we collect personal information
We obtain personal information from various sources. We do this in three main ways:
- You provide some of it directly (such as by registering for an Account).
- We record some of it automatically when you use our Services (including with technologies like cookies).
- We receive some of it from third parties (like when you register for an account using a Third Party Service or when you make payments to us using our payment processors).
- Collecting via our Facebook Chatbot integration.
We’ve described the above in more detail below.
a. Personal information you provide
When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to register and manage your Account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums.
You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.
Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Paid Services to determine if, and how much, tax we need to collect from you.
We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
b. Personal information obtained from your use of our Services
When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices.
c. Personal information obtained from other sources
If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services).
Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.
5. How we use your personal information
We use the personal information we obtain about you to:
- Provision of the Services. Create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries.
- Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.
- Surveys and contests. Administer surveys, contests and other promotions.
- Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Flothemes and our partners and measure the success of those campaigns.
For example, we may send different marketing communications to you based on your subscription preferences or what we think may interest you based on other information we hold about you.
- Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for Paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you.
- Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising.
We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
- Security. Ensure the security and integrity of our Services.
- Third party relationships. Manage our vendor and partner relationships.
- Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
- Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.
Our affiliates and we fully comply with national laws regarding SPAM. You can always opt out of receipt of further email correspondence from us and/or our affiliates. We agree that we will not sell, rent, or trade your email address to any unaffiliated third-party without your permission.
We process your personal information for the above purposes when:
- Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
- Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your Flothemes account.
- Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
- Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
- To operate the Flothemes business and provide you with tailored advertising and communications to develop and promote our business.
- To analyze and improve the safety and security of our Services – we do this as it is necessary to pursue our legitimate interests in ensuring Flothemes is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
- To provide and improve the Services, including any personalized services – we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.
- To share your personal information with other Flothemes group companies that help us provide and improve the Services.
- To anonymize and subsequently use anonymized information.
- Protecting you and others. To protect your vital interests, or those of others.
- Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness.
6. How we share your personal information
We share personal information in the following ways:
- Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
- Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.
- Process payments. We transmit your personal information via an encrypted connection to our payment processor.
- Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving Flothemes ads to people who already use Flothemes.
- Business transfers. If we’re involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.
We use the following services to collect your information:
Chatbot ManyChat – For contacting and communicating via the Facebook Messenger platform, we offer a so-called chat bot. This is a third-party software from ManyChat Inc., 220 Golden Oak Dr, Portola Valley, CA, 94028, USA.
To use our chat bot, you must register on Facebook. By communicating with us through Facebook Messenger Chat, you consent to the processing of your submissions, including personally identifiable information, and the procedures described below:
ManyChat gives us the ability to inform about messages or respond to user questions. We use the system to process and automate customer relationships. This means that all user input and actions in the Facebook chat are evaluated by us, stored and treated as strictly confidential within our company. To claim your data-access and data-deletion user rights for the ManyChat service, please contact us via chat or email.
ManyChat data also allows us to provide you with a tailored Facebook ad experience, where we may advertise latest offers, promotions, and valuable content to you via the Facebook platform.
7. Your Rights
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information either directly in your account or by contacting us at email@example.com to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.
You can also elect not to receive marketing communications if signed up for our newsletters or other content by changing your preferences via the unsubscribe button at the bottom of all our email correspondences.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law.
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
8. How we protect your information
While no service is completely secure, we maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession.
We employ security measures such as using firewalls to protect against intruders and testing for and protecting against network vulnerabilities.
9. How we retain your personal information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.
10. Protecting Your Child’s Privacy
Our Website is not designed for use by anyone under the age of 13 (“Child”), though we realize we may have a Child attempt to make purchases through our Website. We do not verify the age of our Users nor do we have any liability for verifying a User’s age. If you are a Child, please seek the permission of a parent or guardian before using our Website. If you are a parent or guardian and believe your Child is using our Website or has provided us with Personal Information, please contact us.
We reserve the right to ask you for verification of your relationship to the Child before we honor such a request. If we discover that we have collected Personal Information from a Child under age 13 without verification of parental consent, we will immediately delete the information as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to third parties. However, as parent of such a Child, you understand that you are legally liable for any transactions created by the Child.
11. How to contact us
In accordance with GDRP law you have the right to be aware of the lawfulness how your personal data is being processed. You have the right to:
- confirmation that your data is being processed;
- access to your personal data; and
A copy of the information that we possess will be provided free of charge. However, if the request is manifested excessively and repetitively, we reserve the right to charge a reasonable administrative fee.
Please contact us via firstname.lastname@example.org and we we will do our best to provide requested information within 72 hours, however please note that we dispose of maximum of 1 month to comply to your request.