Table of Contents

PRIVACY POLICY  

Last revised on January 01, 2024  

This privacy notice for Flow Commission (“we,” “us,” or “our”) outlines how and why we may collect, store, utilize, and/or share (“process”) your information when you use our services (“Services”), such as when you:  

Visit our website at https://flowcommission.com/, or any of our websites that refer to this privacy notice  

Download and utilize our mobile application (Flow Commission), or any other application of ours that links to this privacy notice  

Engage with us through other related means, including any sales, marketing, or events  

If you have questions or concerns, reading this privacy notice will assist you in understanding your privacy rights and choices. If you do not agree with our policies and practices, we ask that you refrain from using our Services. Should you have any further inquiries or concerns, please reach out to us at [email protected].  

SUMMARY OF KEY POINTS  

This summary highlights important points from our privacy notice, but you can find more detailed information on each topic by clicking the links following each key point or by using our table of contents below to locate the section you want.  

What personal information do we process? When you visit, utilize, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.  

Do we process any sensitive personal information? We do not handle sensitive personal information.  

Do we receive any information from third parties? We do not acquire any information from third parties.  

How do we process your information? We process your information to deliver, enhance, and manage our Services, communicate with you, for security and fraud prevention, and to comply with legal obligations. Additionally, we may process your information for other reasons with your consent. We only process your information when we have a valid legal basis to do so.  

In what circumstances and with which parties do we share personal information? We may share information under specific situations and with certain third parties.  

How do we ensure your information is safe? We maintain organizational and technical measures to safeguard your personal information. However, no electronic transmission over the internet or information storage technology can be fully secure, so we cannot assure you that hackers, cybercriminals, or other unauthorized individuals will not bypass our security and improperly collect, access, steal, or modify your information.  

What rights do you have? Depending on your geographical location, the relevant privacy legislation may grant you specific rights concerning your personal information.  

How can you exercise your rights? The simplest way to exercise your rights is by visiting https://app.flowcommission.com/, or by contacting us. We will review and respond to any request in accordance with applicable data protection laws.  

1. WHAT INFORMATION DO WE COLLECT?  

Personal information you share with us  

In Summary: We gather personal information that you willingly provide to us.  

We collect personal information that you voluntarily share with us when you register on the Services, express interest in learning about us or our products and Services, when you participate in activities within the Services, or when you otherwise reach out to us.  

Personal Information Provided by You. The personal information we collect varies based on how you interact with us and the Services, the choices you make, and the products and features you utilize. The personal information we may collect includes:  

  • names  
  • phone numbers  
  • email addresses  
  • mailing addresses  
  • usernames  
  • passwords  
  • contact preferences  
  • billing addresses  
  • debit/credit card numbers  
  • contact or authentication details  
  • job titles  

Sensitive Information. We do not handle sensitive information.  

Payment Data

We may collect information necessary to process your payment if you make purchases, such as your payment instrument number and the security code linked to your payment instrument. All payment data is secured by https://stripe.com/. You can find their privacy notice link(s) here: https://stripe.com/en-ca/privacy.  

Social Media Login Data

We may offer you the option to sign up with us using your existing social media account details, such as your Facebook, Twitter, or other social media accounts. If you opt to register this way, we will gather the information described in the section titled “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.  

Application Data

If you use our application(s), we might also collect the following information if you grant us access or permission:  

Mobile Device Data

We gather device information automatically, including your mobile device ID, model, and manufacturer, as well as details about the operating system, version, and system configuration. This may also encompass device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are utilizing our application(s), we might also capture details regarding the phone network tied to your mobile device, your mobile device’s operating system or platform, the type of mobile device you are using, your mobile device’s unique ID, and information about the features of our application(s) that you accessed. This data is primarily taken to ensure the security and functionality of our application(s), for troubleshooting purposes, and for our internal analytics and reporting. All personal data that you provide must be accurate, complete, and truthful, and you are required to inform us of any changes to such personal data.

Information automatically collected

In summary, certain information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is automatically gathered when you engage with our Services. We automatically gather specific information when you visit, use, or navigate through the Services. This information does not disclose your specific identity (like your name or contact details) but may include device and usage information, such as your IP address, browser and device specifics, operating system, language preferences, referring URLs, device name, country, location, along with details concerning how and when you utilize our Services, and other technical information. This data is mainly required to ensure the security and functionality of our Services, along with our internal analytics and reporting. As is common practice among many businesses, we also capture information via cookies and similar technologies.

The data we collect encompasses:

  • Log and Usage Data
    • Log and usage data consists of service-related, diagnostic, usage, and performance details that our servers automatically gather when you access or use our Services and record in log files. Depending on your interactions with us, this log data may involve your IP address, device information, browser type, settings, and details regarding your activity within the Services (such as date/time stamps linked to your usage, pages and files accessed, searches, and various actions you take, including which features you utilize), as well as device event information (like system activity, error reports often referred to as “crash dumps,” and hardware settings).
  • Device Data
    • We gather device data, including information regarding your computer, phone, tablet, or any other device you utilize to access the Services. Depending on the device employed, this device data may involve information like your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration details.
  • Location Data
    • We collect location information such as data concerning your device’s location, which can be either precise or approximate. The extent of information we gather is determined by the type and settings of the device you utilize to access the Services. For instance, we may employ GPS and other technologies to gather geolocation data that informs us of your current location (based on your IP address). You can opt out of permitting us to collect this data either by denying access to the information or by turning off your device’s Location setting. However, if you decide to opt out, certain aspects of the Services may not be accessible to you.

2. HOW DO WE HANDLE YOUR INFORMATION?  

In Summary: We handle your information to provide, enhance, and manage our Services, communicate with you, ensure security and prevent fraud, as well as comply with legal requirements. Additionally, we might process your information for other reasons if you consent.

We handle your personal information for various reasons based on your interaction with our Services, such as:  

  • To assist in account creation and authentication, and to manage user accounts. We may use your information to help you create and log in to your account, as well as maintain your account’s functionality.  
  • To provide and facilitate the delivery of services to the user. We may utilize your information to deliver the service you requested.  
  • To address user inquiries and offer support to users. We may process your information to reply to your questions and resolve any issues you might encounter with the requested service.  
  • To send you administrative information. We may use your information to share details about our products and services, updates to our terms and policies, and similar information.  
  • To meet and handle your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through our Services.  
  • To enable communication between users. We may process your information if you opt to use any offerings that allow for interaction with another user.  
  • To collect feedback. We may process your information when needed to request feedback and contact you regarding your use of our Services.  
  • To send you marketing and promotional communications. We may use the personal information you provide for our marketing purposes, provided this aligns with your marketing preferences. You can unsubscribe from our marketing emails at any time. For more details, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.  
  • To deliver tailored advertising to you. We may process your information to create and display personalized content and advertising suited to your interests, location, and more.  
  • To safeguard our Services. We may use your information as part of our initiatives to keep our Services secure, including monitoring and preventing fraud.  
  • To identify trends in usage. We may process information on how you utilize our Services to gain insights into usage patterns so we can enhance them.  
  • To assess the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to design marketing and promotional efforts that are most relevant to you.  
  • To protect or save an individual’s vital interests. We may process your information when necessary to safeguard or protect an individual’s essential interests, such as preventing harm.  

3. WHAT LEGAL GROUNDS DO WE RELY ON TO PROCESS YOUR INFORMATION?  

In Summary: We only process your personal information when we believe it is necessary and that we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as your consent, compliance with laws, fulfillment of services, contractual obligations, protection of your rights, or pursuit of our legitimate business interests.

If you are situated in the EU or UK, this section is relevant for you.  he General Data Protection Regulation (GDPR) and UK GDPR mandate that we clarify the valid legal bases we rely on to process your personal information. Therefore, we may rely on the following legal grounds to process your personal information:  

  • Consent. We may process your information if you have granted us permission (i.e., consent) to use your personal information for a specific purpose. You can revoke your consent at any moment. 
  • Performance of a Contract. We may process your personal information when we think it is necessary to fulfill our contractual obligations to you, which includes providing our Services or responding to you prior to entering into a contract with you.  
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to pursue our legitimate business interests, provided those interests do not outweigh your interests and fundamental rights and freedoms. For example, we might process your personal information for some of the purposes described to:  
  • Inform users about special offers and discounts on our products and services  
  • Create and show personalized and relevant advertising content for our users  
  • Analyze how our Services are used to improve them, thereby engaging and retaining users  
  • Support our marketing efforts  
  • Diagnose issues and/or prevent fraudulent activities  
  • Understand how our users interact with our products and services to enhance user experience 
  • Legal Obligations. We may process your information when we believe it is necessary for compliance with our legal obligations, such as cooperating with law enforcement or regulatory agencies, defending our legal rights or disclosing your information as evidence in litigation in which we participate.
  • Vital Interests: We may process your information when we believe it is essential to protect your vital interests or those of a third party, including scenarios where a person’s safety may be threatened.  

If you reside in Canada, the following section is relevant to you.  

We may process your information if you have given us explicit permission (i.e., express consent) for a specific purpose or in circumstances where we can infer your consent (i.e., implied consent). You may withdraw your consent at any time.  

In some exceptional instances, we may be permitted by applicable law to process your information without your consent, including, for example:  

  • If collection clearly benefits an individual and consent cannot be timely obtained.  
  • For investigations, fraud detection, and prevention.  
  • During business transactions if specific conditions are satisfied.  
  • If the information is part of a witness statement and collecting it is necessary to assess, process, or resolve an insurance claim.  
  • For identifying injured, sick, or deceased individuals and communicating with their next of kin.  
  • If we have reasonable grounds to suspect that an individual has been, is, or may be a victim of financial abuse.  
  • If it is reasonable to expect that collecting and using consent would undermine the availability or accuracy of the information, and the collection is reasonable for investigating a breach of an agreement or a violation of Canadian law or a provincial law.  
  • If disclosure is necessary to comply with a subpoena, warrant, court order, or court rules concerning the production of records.  
  • If the information was generated by an individual in their professional capacity and the collection aligns with the purposes for which the information was generated.  
  • If the collection is solely for journalistic, artistic, or literary purposes.  
  • If the information is publicly accessible and specified in the regulations.  

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?  

In summary: We may disclose information in particular scenarios detailed in this section and/or with the following third parties.  

We might need to share your personal information in the following circumstances:  

  • Business Transfers: We may disclose or transfer your information in connection with, or during the negotiations for, any merger, company asset sale, financing, or acquisition of all or part of our business by another company.  
  • When utilizing Google Analytics: We may share your information with Google Analytics to track and evaluate the use of the Services. The Google Analytics Advertising Features that we might employ include: Google Display Network Impressions Reporting, Remarketing with Google Analytics, and Google Analytics Demographics and Interests Reporting. To opt-out of being tracked by Google Analytics across the Services, visit httpss://tools.google.com/dlpage/gaoptout. You can opt-out of Google Analytics Advertising Features through Ads Settings and Mobile Apps Ad Settings. Additional opt-out options include https://optout.networkadvertising.org/ and https://www.networkadvertising.org/mobile-choice. To learn more about Google’s privacy practices, please refer to the Google Privacy & Terms page.  
  • Affiliates: We may share your information with our affiliates, and in such cases, we will ensure those affiliates adhere to this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that share common control with us.  
  • Business Partners: We may share your information with our business partners to provide you with certain products, services, or promotions.

5. DO WE UTILIZE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Summary: We might employ cookies and various tracking technologies to gather and store your information.  

We may utilize cookies and similar tracking technologies (such as web beacons and pixels) to retrieve or save information.

6. HOW DO WE MANAGE YOUR SOCIAL LOGINS?

In Summary: If you opt to register or log in to our Services using a social media account, we might obtain specific information about you.  

Our Services provide you with the option to register and log in using details from your third-party social media account (like your Facebook or Twitter credentials). When you choose this option, we will acquire certain profile details about you from your social media provider. The type of profile information we receive may differ based on the chosen social media provider; it typically includes your name, email address, friends list, and profile picture, along with any other information you have made public on that social media platform.  

We will utilize the information received solely for the purposes outlined in this privacy notice or as explicitly communicated to you regarding the relevant Services. Please be aware that we do not manage, and cannot be held accountable for, any additional use of your personal information by your third-party social media provider. We encourage you to review their privacy notice to understand how they gather, use, and distribute your personal information, and how you can adjust your privacy settings on their sites and applications.

7. HOW LONG DO WE RETAIN YOUR INFORMATION?

In Summary: We will keep your information for as long as is necessary to meet the objectives outlined in this privacy notice unless dictated otherwise by law.  

We will only retain your personal information as long as it is essential for the objectives specified in this privacy notice, unless a longer retention period is either required or allowed by law (such as for tax, accounting, or other legal obligations). No purpose described in this notice will necessitate the retention of your personal information beyond three (3) months after the termination of the user’s account.  

When we no longer have a legitimate business reason to process your personal information, we will either delete or anonymize the information, or, in cases where this is not feasible (for instance, if your personal information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion becomes possible.

8. HOW DO WE SECURE YOUR INFORMATION?

In Summary: We strive to safeguard your personal information through a combination of organizational and technical security measures.  

We have instituted suitable and reasonable technical and organizational security measures designed to safeguard the security of any personal information we process. However, despite our protective measures and attempts to secure your information, no electronic transmission over the Internet or information storage technology can be entirely guaranteed to be secure; hence, we cannot assure you that hackers, cybercriminals, or other unauthorized third parties may not succeed in bypassing our security and improperly collecting, accessing, stealing, or altering your information. Although we will make every effort to protect your personal information, the transmission of personal information to and from our Services is done at your own risk. You should only access the Services in a secure environment.

9. DO WE COLLECT DATA FROM MINORS?

In Summary: We do not intentionally collect information from or target children under 18 years of age.  

We do not intentionally seek information from or market to children under 18 years of age. By using the Services, you affirm that you are at least 18 years old or that you are the parent or guardian of such a minor and you consent to the minor dependent’s use of the Services. If we discover that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable steps to promptly remove such data from our records. If you become aware of any information that we may have collected from children under 18, please reach out to us at [email protected].

10. WHAT ARE YOUR PRIVACY RIGHTS?  

In Summary: In certain areas, such as the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and Canada, you possess rights granting you greater access to and authority over your personal information. You have the option to review, modify, or delete your account whenever you wish.  

In specific regions (like the EEA, UK, Switzerland, and Canada), applicable data protection laws grant you certain rights. These may include the right (i) to request access and receive a copy of your personal information, (ii) to ask for correction or deletion; (iii) to limit the processing of your personal information; (iv) if applicable, to request data portability; and (v) to avoid being subjected to automated decision-making. Under certain conditions, you might also have the right to contest the processing of your personal information. Such requests can be made by reaching out to us using the contact information provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.  

We will consider and respond to any request in accordance with the applicable data protection regulations.  

If you are in the EEA or UK and believe we are unlawfully handling your personal information, you also have the right to lodge a complaint with your local data protection authority or the UK data protection authority.  

If you are in Switzerland, you may reach out to the Federal Data Protection and Information Commissioner.  

Withdrawing your consent: If we are relying on your consent to process your personal data, which may be explicit and/or implicit consent based on the law, you have the right to revoke it at any time. You can withdraw your consent by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or by updating your preferences.  

However, please understand that this will not affect the legality of the processing conducted before your withdrawal, nor, where applicable law permits, will it influence the processing of your personal information that relied on lawful grounds other than consent.  

Opting out of marketing and promotional communications: You can opt out of our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send or by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. After doing so, you will be removed from the marketing lists. However, we may still contact you— for example, to send you service-related messages necessary for managing and using your account, to respond to service requests, or for other non-marketing reasons.  

Account Information  

If you wish to review or modify the information in your account or terminate your account at any time, you can:  

  • Log into your account settings and amend your user account.  
  • Contact us using the provided contact information.  

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our records to prevent fraud, resolve issues, assist with investigations, enforce our legal terms, and/or comply with legal obligations.  

Cookies and similar technologies: Most web browsers are configured to accept cookies by default. If you prefer, you can typically adjust your browser settings to remove cookies and reject them. If you decide to remove or reject cookies, this may impact certain features or services of our Services.  

If you have inquiries or feedback regarding your privacy rights, you may email us at [email protected].  

11. CONTROLS FOR DO-NOT-TRACK FEATURES  

Most web browsers and some mobile operating systems and applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to express your privacy preference not to have data about your online browsing activities monitored and collected. Currently, no standardized technology has been established for recognizing and implementing DNT signals. As such, we do not presently respond to DNT signals from browsers or any other mechanism that automatically conveys your choice not to be tracked online. If a standard for online tracking is adopted that we are required to follow in the future, we will notify you about that practice in a revised version of this privacy notice.

12. DO RESIDENTS OF THE UNITED STATES HAVE SPECIFIC PRIVACY RIGHTS?

In Summary: If you reside in California, Colorado, Connecticut, Utah, or Virginia, you have specific rights related to accessing your personal information.

What types of personal information do we gather?

We have gathered the following types of personal information over the last twelve (12) months:

  • Identifiers
    • Contact details including real name, alias, postal address, phone or mobile number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name is not collected.
  • Personal information as outlined by the California Customer Records statute
    • Name, contact details, educational history, employment, job history, and financial details is not collected.
  • Characteristics under state or federal law
    • Gender and birthdate is not collected.
  • Commercial information
    • Transaction data, purchase records, financial details, and payment information
  • Biometric data
    • Fingerprints and voiceprints is not collected.
  • Online or similar network activities
    • Browsing history, search history, online behavior, interests, and interactions with our and other websites, applications, systems, and advertisements is not collected.
  • Geolocation information
    • Device location may be collected.
  • Audio, electronic, visual, thermal, olfactory, or related information
    • Images, audio, video, or call recordings made in connection with our business activities is not collected.
  • Professional or job-related data
    • Business contact information to deliver our Services at a professional level, or job title, work experience, and professional credentials, if you apply for a position with us, is may be collected.
  • Educational Information
    • Student records and directory data is not collected.
  • Inferences made from collected personal information
    • Inferences made from any personal information listed above to create a profile or summary regarding, for instance, an individual’s preferences and traits is collected
  • Sensitive personal information is not collected.

We will utilize and keep the personal information collected as required to provide the Services or for:

  • Category K – As long as the user maintains an account with us.

Additionally, we may gather other personal information outside these categories when you interact with us in person, online, or via phone or mail in contexts such as:

  • Receiving assistance through our customer support services;
  • Participation in customer surveys or contests; and
  • Facilitating the delivery of our Services and addressing your inquiries.

Will your information be shared with others?

We may share your personal information with our service providers based on a written agreement between us and each service provider.

We may utilize your personal information for our internal business purposes, such as conducting internal research for technological advancement and demonstration. This does not qualify as “selling” your personal information.

In the last twelve (12) months, we have not disclosed, sold, or shared any personal information with third parties for any business or commercial purpose. We will not sell or share personal information belonging to website visitors, users, and other consumers in the future.

California Residents  

Under California Civil Code Section 1798.83, commonly referred to as the “Shine The Light” law, users who are residents of California can request and receive information from us, once per year at no cost, about the categories of personal information (if any) that we shared with third parties for direct marketing purposes, along with the names and addresses of all third parties with whom we disclosed personal information during the previous calendar year. If you reside in California and wish to make such a request, please send your written request to us using the contact details provided below.  

If you are under 18 years old, live in California, and have a registered account with our Services, you have the right to ask for the removal of any unwanted data that you have publicly posted on the Services. To request the removal of this data, please reach out to us using the provided contact information, including the email address associated with your account and a statement confirming your California residency. We will ensure that the data is no longer publicly displayed on the Services, but please understand that it may not be entirely or comprehensively eliminated from all our systems (for instance, backups, etc.).  

CCPA Privacy Notice  

This section is applicable only to residents of California. According to the California Consumer Privacy Act (CCPA), you have the following rights.  

The California Code of Regulations defines “residents” as:  

(1) every person who is in the State of California for reasons other than a temporary or transient purpose and  

(2) every person who is domiciled in California but is outside the state for temporary or transitory reasons.  

All other individuals are classified as “non-residents.”  

If you fit this definition of “resident,” we are obligated to adhere to specific rights and responsibilities regarding your personal information.  

Your rights concerning your personal data  

Right to request deletion of the data — Request to delete  

You may request the deletion of your personal information. If you choose to ask us to delete your personal information, we will honor your request and delete your personal information, subject to certain legal exceptions, such as (but not limited to) the exercise of another consumer’s right to free speech, our legal compliance obligations, or any processing necessary to combat illegal activities.  

Right to be informed — Request to know  

Depending on the situation, you have the right to know:  

  • whether we collect and utilize your personal information;  
  • the categories of personal information that we gather;  
  • the purposes for which the personal information collected is used;  
  • whether we sell or share personal information with third parties;  
  • the categories of personal information that we sold, shared, or disclosed for business purposes;  
  • the categories of third parties to whom your personal information was sold, shared, or disclosed for business purposes;  
  • the business or commercial reasons for collecting, selling, or sharing personal information; and  
  • the specific pieces of personal information that we collected about you.  

In line with applicable law, we are not required to provide or delete consumer information that is de-identified in response to a consumer request, nor to re-identify individual data to verify a consumer request.  

Right to Non-Discrimination for Exercising a Consumer’s Privacy Rights  

We will not treat you differently if you choose to exercise your privacy rights.  

Right to Limit Use and Disclosure of Sensitive Personal Information  

We do not process sensitive personal information from consumers.  

Verification process  

Upon receiving your request, we need to confirm your identity to ensure you are the individual about whom we hold information in our system. This process requires us to ask for information to match it with what you have previously provided us. For example, depending on the type of request you make, we might ask you to supply specific information so that we can align it with what we have on file, or we may reach out to you through a communication method (such as phone or email) that you have previously given us. We may also employ other verification methods as warranted by the situation.  

We will solely use the personal information provided in your request for identity verification or to establish your authority to make the request. As much as possible, we will try to avoid asking for additional information from you for verification purposes. However, if we cannot confirm your identity with the information we already possess, we may ask you to provide further information for verification and security or fraud-prevention reasons. We will discard any additional information provided as soon as we complete the verification process.  

Other privacy rights  

  • You can contest the processing of your personal information.  
  • You have the right to correct your personal data if it is inaccurate or no longer relevant, or to request a restriction on its processing.  
  • You can appoint an authorized agent to submit a request under the CCPA on your behalf. We may reject a request from an authorized agent if they do not provide proof of valid authorization to represent you as stipulated by the CCPA.  
  • You have the option to opt out of any future selling or sharing of your personal information with third parties. Once we receive an opt-out request, we will process it as soon as reasonably possible, and no later than fifteen (15) days from the request date.  

To exercise these rights, you can reach out to us by visiting https://app.flowcommission.com/, by emailing [email protected], or by referring to the contact information at the end of this document. If you have concerns regarding our handling of your data, we would like to hear from you.

Colorado Residents  

This section is applicable solely to residents of Colorado. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in some situations, we may decline your request as allowed by law.  

  • Right to be informed whether we are processing your personal data.  
  • Right to access your personal data.  
  • Right to correct inaccuracies found in your personal data.  
  • Right to request the deletion of your personal data.  
  • Right to receive a copy of the personal data you previously provided to us.  
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in relation to decisions that have legal or similarly significant effects (“profiling”).  

To submit a request to exercise these rights mentioned above, please email [email protected] or visit https://app.flowcommission.com/.  

If we choose not to act on your request and you want to appeal our decision, please email us at [email protected]. Within forty-five (45) days of receiving your appeal, we will provide a written response regarding any actions taken or not taken in relation to the appeal, including a written explanation of the reasons for our decisions.

Connecticut Residents  

This section is relevant only to residents of Connecticut. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and there are instances where we may deny your request as permitted by law.  

  • Right to be informed about whether we are processing your personal data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you have shared with us previously.
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, sale of personal data, or profiling that leads to decisions with legal or similarly significant implications (“profiling”).

To submit a request to exercise these rights, please email [email protected] or visit https://app.flowcommission.com/.  

If we decline to act on your request and you would like to appeal our decision, please email us at [email protected]. Within sixty (60) days of receiving an appeal, we will inform you in writing of any actions taken or not taken in response to the appeal, along with a written explanation of the reasons for such decisions.

Utah Residents  

This section pertains only to residents of Utah. Under the Utah Consumer Privacy Act (UCPA), you are granted the following rights. However, these rights are not absolute, and in certain situations, we may deny your request according to the law.  

  • Right to be informed if we are processing your personal data.  
  • Right to access your personal data.  
  • Right to request deletion of your personal data.  
  • Right to obtain a copy of the personal data you have previously shared with us.  
  • Right to opt out of the processing of your personal data if it is utilized for targeted advertising or the sale of personal data.  

To submit a request to exercise these rights stated above, please email [email protected] or visit https://app.flowcommission.com/.

Virginia Residents  

Under the Virginia Consumer Data Protection Act (VCDPA):  

“Consumer” refers to a natural person who resides in the Commonwealth, acting solely in an individual or household capacity. It does not include an individual acting in a commercial or employment context.  

“Personal data” signifies any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” excludes de-identified data or publicly available information.  

“Sale of personal data” refers to the exchange of personal data for monetary compensation.  

Right to be informed regarding whether we are processing your personal data. Your entitlements concerning your personal data include:

  • The right to be informed about whether we are processing your personal data.
  • The right to access your personal data.
  • The right to correct any inaccuracies in your personal data.
  • The right to request the deletion of your personal data.
  • The right to obtain a copy of the personal data you previously provided to us.
  • The right to opt out of your personal data being processed if it is used for targeted advertising, the sale of personal data, or profiling that leads to decisions with legal or similarly significant consequences (“profiling”).

Exercise your rights as outlined under the Virginia VCDPA.

You can reach us via email at [email protected] or by visiting https://app.flowcommission.com/.

If you are using an authorized representative to exercise your rights, we may deny a request if the authorized representative fails to provide proof of their valid authorization to act on your behalf.

Verification requirements

We might ask you for additional information reasonably needed to verify you and your consumer’s request. If you make the request through an authorized representative, we may need to gather further information to verify your identity before we can process your request.

Upon receiving your request, we will respond promptly, but in all instances, within forty-five (45) days of receipt. The response period may be extended once for forty-five (45) additional days when there is a reasonable need. We will notify you of any such extension within the initial 45-day response period, along with the reason for the delay.

Right to contest

If we choose not to act regarding your request, we will communicate our decision and the reasoning behind it. If you wish to challenge our decision, please send us an email at [email protected]. Within sixty (60) days of receiving your appeal, we will inform you in writing of any actions taken or not taken in response to the appeal, along with a written explanation of the reasons for those decisions.

13. DO WE MAKE CHANGES TO THIS NOTICE?

In Brief: Yes, we will revise this notice as needed to remain compliant with applicable laws.

We may update this privacy notice periodically. The updated version will have a new “Revised” date, and it will take effect as soon as it becomes accessible. If we make significant alterations to this privacy notice, we may inform you by prominently posting a notice of such changes or by sending you a notification directly. We encourage you to frequently review this privacy notice to stay informed about how we safeguard your information.

14. HOW CAN YOU GET IN TOUCH WITH US ABOUT THIS NOTICE?

For questions or comments regarding this notice, you may email us at [email protected].

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the applicable laws in your country, you may have the right to request access to the personal information we have collected from you, modify that information, or eliminate it. To request access, updates, or deletion of your personal information, please visit: https://app.flowcommission.com/.