Thank You for using www.phlow.com (the “Website”) . phlow Zone Limited is a company registered in the United Kingdom (company number 09777976) with its registered office at 78 York Street, London W1H 1DP (“phlow”) and phlow is committed to protecting and respecting Your privacy.
For the purpose of GDPR , the data controller is phlow Zone Limited.
Date of last revision: 24.05.2018
1 Data phlow may collect from You
phlow may collect and process the following data about You:
1.1 Data You give phlow. You may give phlow data about You by filling in forms on the Website or by corresponding with phlow by phone, e-mail or otherwise. This includes information You provide when You register to use the Website, upload or view User Content uploaded to the Website, participate in discussion boards or other social media functions on the Website, enter a competition, promotion or survey and when You report a problem with the Website. The information You give phlow may include Your name, address, e-mail address and phone number, , personal descriptions, photographs, locational data provided when using phlow’s services on Your mobile device, and any other information that You upload to Your profile.
Any information phlow gets from those services depends on Your settings or their privacy policies.
1.2 Data phlow collects about You. With regard to each of Your visits to the Website phlow may automatically collect:
1.2.1 technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information and location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, cookie and device data; and
1.2.2 information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products You viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call phlow’s contact number.
1.3 Data phlow receives from other sources. phlow works with third parties (including business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about You from them.
Some websites use specific phlow features and phlow may collect log information from those sites. Online advertisers share information with the websites where they run adverts to measure or improve those adverts, and phlow receives this information. Online media (newspapers, magazines, blogs) typically share information about their readers, and phlow might use this information to share fresh and relevant content with You.
3 How and why we use your data
phlow ultimately uses information held about You to calculate what is relevant, to offer you filtered content that is both customised and relevant (including showing You photo streams or adverts that phlow think You might like). phlow does this in the following ways:
Data You give to phlow. phlow will use this to:
3.1 Keep phlow running: Legal basis Contract – Legitimate Interests
3.1.1 carry out phlow’s obligations arising from any contracts entered into between You and phlow and to provide You with the information, products and services that You request from phlow;
3.1.3 provide, or permit selected third parties to provide, information about products, services or events that phlow feels may interest You. If You are an existing phlow User, phlow will only contact You by electronic means (e-mail or SMS) with information that phlow reasonably consider is relevant to You, based on the data phlow has acquired through Your use of the Website. If You are a new User, and where phlow permits selected third parties to use Your data, phlow (or they) will contact You by electronic means only with Your permission. If You do not want phlow to use Your data in this way, or to pass Your details on to third parties for marketing purposes, you have the right to withdraw consent. You can also exercise the right at any time by contacting phlow at phlow zone LTD 8 York Street, London, W1H 1DP, U.K. or email@example.com.
3.1.4 measure or understand the effectiveness of advertising phlow serves to You and others, and to deliver relevant advertising to You; and
3.1.5 to keep the Website safe and secure;
3.1.6 Data phlow receives from other sources. phlow may combine this with information You give to phlow and information phlow collects about You. phlow may use this information and the combined information for the purposes set out above (depending on the types of information phlow receives).
3.2 Improving phlow: Legal Basis: Contract – Legitimate Interests.
3.2.1 ensure that content from the Website is presented in the most effective manner for You and for Your computer or device.
3.2.2 administer the Website and for internal operations (such as troubleshooting, data analysis, testing, research, statistical and survey purposes);
3.2.3 improve the Website to ensure that content is presented in the most effective manner for You and for Your computer;
3.2.4 allow You to participate in interactive features of phlow’s services when You choose to do so;
3.3 Marketing and Communications (with your consent): Legal basis Consent
3.3.1 make suggestions and recommendations to You and other Users of the Website about goods, products, events or services that may interest You or them.
3.3.2 notify You of any changes to phlow’s services; and
3.3.3 provide You with information about other products or services that phlow offers that are similar to those that You have already purchased or enquired about;
4 When phlow discloses Your data
When You use Your phlow account to create a collection of images, anyone can view them along with the personal information on Your Account or profile page. Other limited circumstances where phlow may share Your personal information include:
4.1 when You give phlow permission to do so (i.e. by linking phlow to Your Facebook or Twitter account);
4.2 where phlow wish to provide information to any company affiliated with phlow (which includes our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006);
4.3 when phlow sell or buy any business or assets (in which case phlow may disclose Your personal data to the prospective seller or buyer of such business or assets);
4.4 if substantially all of phlow’s assets are acquired by a third party (in which case personal data held by phlow about phlow’s Users will be one of the transferred assets); and
phlow may also share Your information with selected third parties, including:
4.6 business partners, suppliers and sub-contractors for the performance of any contract phlow enters into with them or You;
4.7 advertisers and advertising networks that require the data to select and serve relevant adverts to You and others. phlow does not disclose information about identifiable individuals to its advertisers, but phlow may provide them with aggregate information about its Users (such as traffic profiles on an advertisement on any given day). phlow may also use such aggregate information to help advertisers reach the kind of audience they want to target. phlow may make use of the personal data it has collected from You to enable phlow to comply with its advertisers’ wishes by displaying advertisements to that target audience; and
4.8 analytics and search engine providers that assist in the improvement and optimisation of the Website.
5 Where phlow stores Your data
5.2 All information You provide to phlow is stored on phlow’s secure servers. Any payment transactions will be encrypted. Where phlow have given You (or where You have chosen) a password which enables You to access certain parts of the Website, You are responsible for keeping this password confidential. phlow asks You not to share a password with anyone.
5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although phlow will do its best to protect Your personal data, phlow cannot guarantee the security of Your data transmitted to the Website. Therefore, any transmission is at Your own risk. Once phlow has received Your data, phlow will use strict procedures and security features to try to prevent unauthorised access.
6 Your rights
You have the following rights with respect to how we handle your personal information. To exercise these rights, please see below or submit your request to the DPO: firstname.lastname@example.org.
6.1. Explanation and copies of your data
- You have the right to request an explanation of the information that phlow has about you and how phlow uses that information.
- You also have the right to receive a copy of the information that phlow collects about you, We will give you a copy of your data in CSV or JSON
- If phlow has information about you that you believe is inaccurate, you have the right to request correction of your information. Alternatively you can use the tools provided by phlow under your profile configuration to update your details.
- Users may request deletion of their accounts at any time by emailing: email@example.com. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.
6.4 Right to withdraw consent
- You have the right to ask phlow not to process your personal data. phlow will usually inform You (before collecting Your data) how it intends to use Your data for the purposes described in this policy or if phlow intends to disclose Your information to any third party for such purposes. You can exercise Your right to prevent such processing by checking certain boxes on the forms phlow use to collect Your data. You can also exercise the right at any time by contacting phlow at phlow zone LTD 8 York Street, London, W1H 1DP, U.K. or firstname.lastname@example.org.
6.5 Objections and complaints
- Users have the right to object to phlow’s processing of personal data, including for marketing purposes. phlow may continue to process your information notwithstanding the objection to the extent permitted under GDPR.
- Users also have the right to file a complaint relating to phlow’s handling of your personal information with the Information Commissioner’s Office https://ico.org.uk/.
6.6 The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites may have their own privacy policies and phlow does not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.
6.7 When You close Your Account, phlow will deactivate it and remove anything You have uploaded to Your Account. phlow may retain archived copies of your information for at least 7 years, as required by law or for legitimate business purposes (such as to identify spam).
7. Right to withdraw consent
You have the right to ask phlow not to process your personal data. phlow will usually inform You (before collecting Your data) how it intends to use Your data for the purposes described in this policy or if phlow intends to disclose Your information to any third party for such purposes. You can exercise Your right to prevent such processing by checking certain boxes on the forms phlow use to collect Your data. You can also exercise the right at any time by contacting phlow at phlow zone LTD 8 York Street, London, W1H 1DP, U.K. or email@example.com.
7 Access to data
You have the right to access information phlow holds about You. Your right of access can be exercised in accordance with GDPR . Any access request may be subject to a fee of £10.00 to meet our costs in providing You with details of the information phlow holds about You.
Customers have the right to file a complaint concerning our processing of their personal data. All queries and complaints shall be handled in a timely manner by the DPO in accordance with internal procedures.
In the unlikely event that customers have suffered harm due to a breach of their rights under the data protection policy and phlow has not handled the complaint in a sufficient manner, customers may lodge a complaint with the supervisory authority relevant to your country (http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm)
Complaints can be submitted to the DPO: firstname.lastname@example.org