FLOW PRIVACY NOTICE (“Notice”)

Flow Retail Ltd. (“Flow”, “our,” “we” or “us”) recognize and respect the importance of maintaining the privacy of our customers, prospective customers, employees, employment prospects, partners, vendors and website visitors. This Privacy Notice describes the types of information we collect from you when you visit our website (“Site” or “Website”), or information that we receive about you or that you may provide in the course of your interest in our services (“Services”), during business transactions, or as otherwise detailed in this policy. This Privacy Notice also explains what Personal Information we collect from you, how we use it and what your rights are. If you have any questions regarding our policies or practices, please contact us at: info@flow-retail.com

FLOW is committed to:

Respecting and protecting the privacy of all individuals with whom we interact including, without limitation, Website Users of our Website and the Services;

Transparent management of Personal Information; and compliance with applicable privacy and data protection laws

By using our Website, you hereby Consent to our use of your Personal Data for the purposes set forth herein. If you object to your Personal Data being transferred or used as described in this Notice or if you discover or believe that our Processing of your Personal Data violates applicable privacy laws, you must refrain from using the Website.

In addition, please note that in connection with your use of the Website you may be required to enter into additional agreements with FLOW or other third parties. This Policy is incorporated into such other agreements and into our Terms of Use.

The following terms are used throughout this Notice:

“Consent” means the freely given, specific, informed and unambiguous indication of the data subject’s (the individual person whose Personal Data we Process) wishes by which he or she, by statement or by a clear affirmative action, signifies agreement to the Processing of their Personal Data.

“Personal Information” or “Personal Data” are used interchangeably (unless specifically defined within the Additional Terms) and mean information related to an identified or identifiable living person, otherwise referred to in this Notice, as a data subject.  These definitions include identifiers, which are data elements that identify a unique individual and can permit another person to “assume” that individual’s identity without their knowledge or consent such as names, identification numbers, location data and online identifiers such as Cookies. The exact list of identifiers considered to be Personal Data varies by jurisdiction.

“Process” or “Processing” means any operation or set of operations which is performed on Personal Data in any format including, without limitation, the collection, use, storage, Processing, analysis or transfer of Personal Data.

This Notice explains the following:

What types of Personal Information we Process

Our policy regarding Cookies

How we use Personal Information and how long we keep that information;

How we secure Personal Information;

When we share and disclose Personal Information;

Our policies regarding international and intra-company transfers of personal information (general);

Your rights regarding the Personal Information that you provide to us;

The scope of our responsibility for Website links;

Governing law and jurisdiction;

Changes to the Notice;

Brief description of jurisdiction-specific terms (and links to the full text of such terms)

How to contact us;

[Registered agent and DPO contact information inserted as necessary]

What Types of Personal Information we Process

We collect and Process (without limitation) the following Personal Data from Website Users:

Identity and contact data – including data derived from Website Users’ use or access to the Website and data generated during the general course of our Website User or customer relationships, which may include Personal Data related to our customers’ employees or other personnel and basic user (and user-personnel) details such as names, e-mail addresses, and job titles;

Business information – including data provided to us in the course of our contractual relationship with Website Users or customers or otherwise voluntarily provided to us by Website Users to us;

Profile and usage data – including marketing, communications and tracking data related to Website Users;

Technical data – including data necessary for the technical operation of the Website, information collected during Website Users’ visits to the Website, Internet Protocol (IP) addresses, login data, browser type and version information, device type information, time zone settings, browser plug-in types and versions and operating system and platform information; and

Cookies – as detailed in our Cookies Policy.

We do not collect Personal Data that is classified as a Special Category of Personal Data.  “Special Categories of Personal Data” means sensitive categories of Personal Data defined under applicable privacy laws, which includes at least, data regarding a data subject’s religious beliefs, trade union activities, physical or mental health, sexual life and sexual orientation, criminal offenses, genetic or biometric data, and other categories of data subject to enhanced protections pursuant to applicable privacy laws. The exact definition of this term varies by jurisdiction and may include additional types of Personal Data including financial data.

We do not seek to collect information about children aged 16 or under. If you have any concerns about your child’s privacy in relation to our Website, or if you believe that your child may have entered Personal Information onto our website, please contact us at: info@flow-retail.com. We will delete such information from our records within a reasonable time.

How we use Personal Information and How Long we Keep that Information

We collect and use Personal Information from Website users while:

Sending system performance messages and compiling system usage data;

Engaging in customer service activities and communications;

Enforcing our legal, equitable and contractual rights, taking measures to protect against fraud and abuse and pursuing available remedies;

Fulfilling our regulatory obligations;

Communicating with our attorneys and accountants;

Enhancing or expanding our product and service offerings;

Protecting our facilities and taking measures to secure our systems;

Performing data analytics;

Engaging in advertising activities or market and opinion research; and

Performing other activities related to our business or the Website, as permitted by applicable law.

We store your Personal Information in accordance with legal, regulatory, information technology and best-practice business requirements. In addition, please note that we may be required to retain such Personal Information in accordance with relevant records retention laws. Once your Personal Information is no longer necessary, we will securely delete/destroy your data in line with our data retention policies.

How we Secure Personal Information

We maintain appropriate organizational and technological safeguards to help protect against unauthorized use, access to or accidental loss, alteration or destruction of Personal Information, taking into due account the risks involved in its Processing, the nature of the relevant Personal Information and the behaviors or activities of the relevant data subjects. However, no method of data transmission over the Internet and no method of electronic storage is 100% secure, so we cannot guarantee its absolute security.

Information Sharing and Disclosure

We may share Personal Data both internally and with third parties including:

Our subsidiaries and affiliated companies, to help us to provide the Services or operate our business;

Third party service providers such as business partners, suppliers, agents, contractors or subcontractors who provide Services-related support to us, process transactions, fulfill information requests, provide professional advice, analyze data, provide IT and other support services or tasks, operate search engines or assist us to improve and optimize our Website or promote our marketing efforts;

Third parties including government entities in the context of our compliance in the context of fulfilling our legal, contractual or audit or compliance obligations; or

Corporate transactions – From time to time, we may consider corporate transactions such as a merger, acquisition, reorganization, asset sale, or similar type of transaction. Personal Information may be transferred to third parties involved in such transactions and we may also assign Personal Information to a successor entity in the case of a merger and acquisition.

We may also transfer and disclose non-personal or anonymized data to third parties in accordance with our business needs, as permitted by privacy laws. Please note that we do not sell Website Users’ or customers’ Personal Data.

Your Personal Information may also be stored in one or more databases hosted by third parties who do not have use or access to your Personal Information for any purpose other than cloud storage or retrieval.

International and Intra-company Transfers of Personal Information

Subject to applicable privacy laws, your Personal Information may be stored and Processed in any country where we have facilities or in which we engage or use the services of contractors, service providers or personnel. By using our Website or Services, you hereby Consent to the transfer of your Personal Information to countries outside of your country of residence, including the United States or to another jurisdiction which may have different data protection rules from those of your country. Please review any additional relevant conditions described within the Additional Terms applicable to you. Please also note that, subject to applicable privacy laws, in certain cases, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.  If you would like more information on the any of the data transfer mechanisms on which we rely please contact us at using the details provided below.

Your Rights Regarding the Personal Information you Provide to us (general)

Website users or customers who wish to stop receiving marketing communications from us may choose to cease receiving such communications by clicking on the “unsubscribe” link at the bottom of the relevant mailing. Persons you wish to opt-out completely should contact us at using the details provided below.

Persons who would like for us to delete their Personal Information from our records, must contact us using the contact details below, following which we will respond within a reasonable time. Please note, however, that we may be required to retain certain information by law and/or for our own legitimate business purpose.

If you exercise the rights above we may require you to provide information proving your identity.

If you are from either the European Union or California, you may have additional rights. We urge you to review any jurisdiction-specific terms that apply to you.

Responsibility for Website links

The Website may include links to third-party Websites. We have no responsibility for or control over the information collected by such third-party Websites and we cannot be responsible for the protection and privacy of any information which you may provide on such Websites.

Governing Law and Jurisdiction

This Notice shall be governed by the laws and jurisdictional requirements set forth within the Terms of Service, unless otherwise required by applicable Privacy Laws.

Changes to the Notice

This Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal data. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use the Website or our Services and please refrain from sharing your personal data with us. You should check this notice frequently for updates.

Additional Jurisdiction-Specific Terms

Information applicable to persons located within the European Economic Area (EEA)

We are committed to Processing the Personal Information (known as Personal Data under the GDPR, as defined below) of persons who are located within the European Economic Area (“EEA”) in a manner that meets its obligations under the European Union General Data Protection Regulation (“GDPR”). The GDPR requires us to provide certain information to such persons about their Personal Data, as described within the GDPR Notice. To this end, we have created a separate GDPR Notice, which is intended to apply to people who are located in the EEA and supplements this Policy. 

Information applicable to California residents

We are committed to Processing the Personal Information of California residents in a manner that satisfies its obligations under applicable California laws. To this end, we have instituted a separate notice aimed at such persons (“California Notice”). The California Notice is intended to apply to California residents and supplements the Policy. The laws referenced within the California Notice require us to provide certain information to such persons about our use of their Personal Information and to make certain disclosures to such residents and supplements this Policy.

How to contact us

If you have any questions about this Notice, our approach to privacy or you would like to exercise any of the rights mentioned in this Notice you may contact us as stated below:

Nirim 3, Tel-Aviv, Israel

info@flow-retail.com

Cookies Policy

Cookies are small packets of information stored by your web browser when you visit certain Websites, including our Website and are generally used by Websites to improve Website Users’ experience by enabling that Website to ‘remember’ Website Users, either strictly for the duration of their visit or for repeat visits. We may use the following types of Cookies and Web trackers:

Strictly necessary cookies – these cookies are essential to enable you to browse around our Website and use their features. Without these cookies, services like shopping baskets and e-billing cannot be provided.

Performance cookies – these cookies collect information about how you use our Website — for instance, which pages you go to most. This data may be used to help optimize our Website and make them easier for you to navigate. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.

Functionality cookies – these cookies allow the Websites to remember choices you make while browsing. For instance, these cookies may be used to keep track of what featured products and services that you have viewed. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on third-party Websites.

Third-party cookies – to enrich our Website content, we may embed video content from other social media Websites and other third-party sources. As a result, when you visit a page with content embedded, you may be presented with cookies from these Websites. We have no control or liability over these cookies set, so you should review the relevant third party’s cookie policy for more information.

Choices about cookies

Please check your browser settings to find out how to disable cookies. Because cookies are used throughout our Website, disabling them may prevent you from using certain parts of the site.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our Website will be limited.

How to disable cookies

You may set your browser to block all Cookies, or to indicate when a Cookie is being set by us. However, it is important to know that portions of our Website may not function properly if your Cookies are disabled.

The effect of disabling cookies depends on which cookies you disable but, in general, the Website may not recognize your device, may not remember your preferences and so on, if cookies are disabled or removed. However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use.