PRIVACY POLICY

 

Approved: 10.07.19

Published: 22.07.19

Will be reviewed: 22.07.20

 

General

FLOW ehf., (“FLOW,” “the company,” “our,” “us” or “we“) takes your privacy very seriously and is committed to protecting your personal information. In this privacy policy we explain what data we collect from you as a user of the FLOW application (the “application“) and why we collect it. Here you can find information about who receives your personal data, our legal basis for processing personal data, how long we retain it, what your rights are as a user of the application and other important facts relating to data protection laws.

Personal data that FLOW collects and how that data is used

You directly provide us with most of the data we collect.

1. Information you provide when you create an account

We receive certain information from you when you create a FLOW account. To create an account, you have four different options:

1.1. Traditional login

You can choose to create a new account directly by registering information about your name, email and password. You may optionally choose to provide information about your Company if applicable.

1.2 Login with Facebook

You can choose to use Facebook to create an account. Through this method we collect your Facebook ID and email address.

1.3. Login with Google

You can choose to use Google to create an account. Through this method we collect your Google ID and email address. 

1.4. Login with LinkedIn 

You can choose to use LinkedIn to create an account. Through this method we collect your LinkedIn ID and email address. 

2. Information you provide when you use the application

2.1. Information about your meditation

The application collects information about your meditation, such as overall length of the meditation and which meditations have been chosen, in order to allow you to keep track of your use of the application.

2.2. Information about your health and well being

In order to enhance your experience of the application you can choose to share information related to your vital signs, e.g. your pulse, and connect it to your meditations. You can also import and connect other information such as information pertaining to your sleep and stress levels. This information is used to monitor and inform you about your well being. This information is not stored by us, it is only stored on your personal device. 

2.3. Information about how you use the application

We also collect information on how you use the application in order to improve the user experience of the application. 

2.4. Log Data 

Whenever you use the application, in a case of any potential errors in the application, we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the application, the time and date of your use of the application, and other statistics.

3. Outgoing emails

3.1. Lost password

If you have lost or forgotten your account password, you can request a password reset. If we receive that kind of request from you, we will send an email with reset instructions to the email address you used to register for your FLOW account.

3.2. Promotional material

If you sign up to receive promotional materials from us via email we will use the information you give us to provide the communications you have requested. It should be noted that you, as a user of the application, have the right to object to such email communications, by unsubscribing.

3.3. Changes to Terms of Service

Our terms may change in the future. When we change them, we will send you information about those changes via email.

3.4. Changes to this privacy policy regarding how we handle personal data

This privacy policy may change in the future. We believe it is important that users of the application are aware of how the company handles their personal data. Therefore, we will send you an email if or when our privacy policy changes.

Legal basis for processing personal data

The personal information referred to in sections 1.1. – 1.4. mentioned above is collected on the basis of your consent.

The personal information referred to in sections 2.1. and 2.2. is also collected on the basis of your consent. The information in connection with your use of the application, referred to in section 2.3. and 2.4. is collected on the basis of our legitimate interest in being able to improve our services for you and keep you informed of relevant information about our services.

Emails regarding lost passwords and promotional material, as described in section 3.1. and 3.2., will be sent to you on the basis of your consent.

Emails described in sections 3.3. and 3.4. will also be sent to you on the basis of our legitimate interest in demonstrating that the company has informed users about changes to our Terms of Service or to our handling of users’ personal information.

Protection of personal data

FLOW takes precautions, including administrative, technical and physical measures, to safeguard your personal data against loss, theft and misuse, as well as against unauthorised access, disclosure, alteration and destruction. We store the personal data you provide encrypted on computer servers that are located in controlled facilities. We restrict access to personal data to our employees, contractors and agents who need access in order to operate, develop, or improve our services and the application.

Retention of personal data

We will retain your personal information only for as long as is necessary for the purposes set out in this Data Protection Policy.

The personal data referred to in sections 1. and 2. Will be deleted when you delete your account.

 

Does FLOW share my personal information with others?

To support delivery of our services we may engage and use data processors with access to certain Customer Data. When using data processors, we will enter into a data processing agreement (DPA) with each processor in order to safeguard your privacy rights and to fulfill our obligations towards you. 

Personal data transfers outside of the European Economic Area (EEA)

Where your personal data is transferred to a country outside of the EEA, and that country is not subject to an EU adequacy decision, we will ensure your data is protected by appropriate safeguards (e.g., EU-approved standard contractual clauses, a Privacy Shield certification, or a supplier’s Binding Corporate Rules).

Your rights as a user of the application

If you have granted your consent for processing certain personal data, you are entitled to withdraw your consent at any time pursuant to data protection laws. However, that right does not affect the legitimacy of the processing of data carried out before you withdrew your consent. You also enjoy other rights, such as the right to access your data, the right to have wrong or misleading information about you rectified, the right to have your personal data deleted, the right to restrict that your personal data will be processed, the right to object and your right to data portability. Please note that some of your rights may be subject to certain conditions.

 

Name and contact details of the controller

Name: FLOW ehf.

Address: Hadarstigur 4, 101 Reykjavik, Iceland.

Email: info@flow.is

Data Protection Officer

If you have further questions about how FLOW handles your personal data, or if you want to exercise your rights, you may contact our data protection officer:

Name: Magnús Freyr Norðfjörð

Address: Kópavogsbraut 95

Email: magnus@flow.is

Right to file a complaint with the Data Protection Authority

If you have any concern that FLOW handles your personal data legitimately, you have the right to file a complaint with the regulatory authority.