We do not currently use any cookies on our website so portions of this policy are not yet implemented. As our site evolves, we will provide the required information and privacy controls in line with this policy.
FlowPoint Technologies Ltd. (“FlowPoint”) values and respects the privacy of potential employees, representatives of potential customers, customers and their clients.
We have customers around the globe, so we offer individuals industry-leading personal information protections that address data protection requirements around the globe. Our Privacy Notice incorporates the core privacy principles that underlie many international data protection laws. Traditionally, European data protection laws have been among the world’s strictest. To provide individuals with a robust framework, we have aligned our approach to the GDPR requirements as the baseline for our Privacy Notice. As new laws take effect, we adjust as necessary to ensure continued compliance with data protection laws.
This Privacy Notice sets out how we collect, use, disclose and otherwise process your personal information when you visit our Website, request marketing materials or documentation from us, sign up to our newsletters, apply for a job with us, or when a company with which you are associated either considers subscribing for services from us or, ultimately does so, including:
- What personal information we collect and when and why we use it
- How we share personal information
- How we use website information and cookies
- Explaining more about Direct Marketing, Profiling, and Automated Decision Making
- Transferring personal information globally
- How we safeguard and retain personal information
- Legal rights available to help manage your privacy
- How you will be notified of changes made to this privacy notice
- How you can contact us for more support
Further privacy information may be provided in additional notices at the time we process personal information.
How do we collect personal information
We collect personal information directly from you, as well as through automated means described in this Privacy Notice. We may also collect personal information about you from third parties: for example, we may ask previous employers for job references when you apply to work with us.
What personal information we collect and when and why we use it
We only collect, use and share your personal information if we are satisfied that we have an appropriate legal basis to do. For individuals in the EU and UK, please see the Appendix for the corresponding lawful basis.
Email Communications: If you sign-up for our email communications such as our monthly newsletters, we will collect your name and email address. You can opt-out of receiving these marketing communications at any time by clicking the unsubscribe link located at the bottom of our emails or by contacting us using the information at Contact Us below. If you unsubscribe, you may continue to receive certain transactional or account-related communications from us (such as account notifications, updates, and responses to inquiries).
White Papers and Webinars: We may collect your name, business email, company name, number of company employees, job title, industry when you download our white papers and view our webinars.
Employment: If you submit a job application or make a related inquiry, you may provide us with certain personal information (such as that found in a resume, cover letter, or similar employment-related material). We will process this personal data to assess your suitability for employment (and if applicable, to make arrangements to employ you), to respond to your related enquiries and to consider you for other current and future career opportunities.
Services Opportunities: We may collect names, email addresses, phone numbers, and addresses of directors, officers, senior managers and shareholders to assess services opportunities and to manage risk. If requested, we may enter into a confidentiality agreement with you in connection with a services opportunity.
Services Fulfilment: In the course of providing our services to our customers and their clients we will use, copy, modify, process, transmit and disclose personal information only as reasonably required for the purposes for which it is provided to us, examples being, to understand and meet customer and client needs and preferences and to manage and develop our customer relationships.
Suppliers: We may collect names and business contact information (such as email addresses, phone numbers and addresses) of contacts at suppliers to assist us in conducting business and communication with those suppliers.
Surveys and Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other research projects. The information obtained through our surveys and research projects is used in an aggregated, de-identified form to help us understand our users and to enhance our Website.
Contact Us: When you Contact Us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, email address, industry, company name, company website, and phone number along with additional information we need to help us promptly answer your question or respond to your comment. In line with the provisions of this Privacy Notice, we may retain this information to assist you in the future and to improve our customer service and services offerings. In the UK and the EU, we rely on our legitimate interest in responding to potential customers, in managing our business and reputation, and in improving our products and services.
Call Recording: We may wish to monitor and record our telephone conversations with you for training and quality assurance purposes.
- If you are in Germany, your active consent will be sought at the beginning of any call intended for recording.
- In other jurisdictions, you will be provided with a notice at the beginning of any call being recorded. If you do not wish to have your call recorded, please let us know at that time.
For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at:
https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at:
- https://policies.google.com/technologies/partner-sites and
For more information about cookies, please see the section on “Cookies” below. We will only collect this information where you have provided your consent.
Interest-Based Advertising: We work with third-parties such as ad networks and other advertising companies (specifically Google Advertising and LinkedIn) that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet.
These companies may collect information about your activity on our Website and third party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns. We will only collect this information where you have provided your consent. For details of the specific cookies we use please see our Cookies Policy.
For further information about how Google and LinkedIn may use your personal data please see their privacy notices:
- Google – https://policies.google.com/technologies/partner-sites
- LinkedIn – https://www.linkedin.com/legal/privacy-policy
Opting-out of Interest-Based Advertising: To opt-out/withdraw your consent to the collection of information on our Website for interest-based advertising or adjust your preference, please click here for our Cookie Preferences. For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. If you are in the UK or the EU, similar information is available at https://youronlinechoices.eu/
Please note that even if you opt-out of/withdraw your consent to interest-based advertising by a third party, these tracking technologies may (where you have provided your consent) still collect data for other purposes including analytics and you will still see ads from us, but the ads will be less relevant to you and your interests. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
SHARING OF PERSONAL INFORMATION
We share your information in the manner and for the purposes described below. This data sharing may involve your personal data being transferred to other jurisdictions: please see the section “Transferring personal data globally” for further information.
Internally: Your personal information may be transferred within FlowPoint where such disclosure is necessary to provide you with our services or to manage our business. FlowPoint resources providing support services use anonymized data whenever that is a commercially reasonable option.
Service providers: Your personal information may be transferred (or otherwise made available) to, maintained or processed by our affiliates and other third parties in the US, Canada, UK, EU or other jurisdictions who provide services on our behalf. We use service providers to send communications, provide back-office support functions, host the Website and operate certain of its features, and provide advertising and marketing services. If personal information is transferred to other jurisdictions, for example (depending upon your location) the UK, EU, US or Canada, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. Our service providers are given the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes.
Advertising Partners: Your personal information may be shared with our advertising partners (such as Google and LinkedIn) when you agree to interest based advertising. Please see “Interest Based Advertising” above for further information.
Legal and compliance: FlowPoint and our service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement, contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S., UK, EU or other law or legal process, which may include lawful access by relevant foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our assets or securities, as part of a corporate reorganization or other change in corporate control.
Marketing: With your consent, we may share your information with third parties for marketing purposes. To withdraw your consent, please contact us using the contact information at “Contact Us” below.
When you visit our Website, we may collect certain information about you automatically (with your consent where appropriate) using cookies or similar technologies.
What are Cookies?
A cookie is a small text file that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so we can recognize the user’s computer or device when the user returns.
You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all the Website features. A single cookie will be used in your browser to remember your preference not to be tracked.
You can change your cookie settings at any time via our preference centre.
Types of Cookie
- The cookies we use can broadly be divided into four categories:
- Strictly Necessary– these cookies are required for our Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work;
- Functionality – these allow us to provide optional functionality, and to personalize and optimize your website experience. For example, they may be used to remember any choices you make or to remember your chat history;
- Analytics – These cookies help us to understand how visitors engage with our Website. We may use a set of cookies to collect information and report site usage statistics and to help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance;
First and third party cookies: Cookies may be first or third party: first party cookies are placed on your device directly by our Website, whilst third party cookies are placed by third party selected partners and service providers. We use third party cookies for purposes set out in the table below, including analysing how users use our Website, and to show you targeted advertisements.
Session and persistent cookies: Session cookies allow a website operator to link your actions only during a browser session, when you open the internet browser window until you close the browser window. These cookies are temporary and they are deleted when you close the browser. Persistent cookies remain on your device for the period of time specified in the cookie. The storage period for the cookies we use is specified in the table below.
Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The process for managing cookies is different for each internet browser so we suggest you check the specific steps in your particular browser help menu. If you choose to reject certain cookies, you may not be able to use certain features of our Website, applications and online services.
Cookies we use:
We do not currently use any cookies on our website.
We will provide a table here with the description of each cookie we implement as they are put into use.
If you notice a discrepancy with this statement, please send a quick note to email@example.com so we can work to close the gap — thank you!
EXPLAINING MORE ABOUT TARGETED DIRECT MARKETING
How we use personal information to keep you up to date with our products and services
We may use personal information (including your name, job title, company name, email address, number of employees at your company, browser and device information, the country that you are located in when accessing the Website and the link used to access the Website) to build a profile about FlowPoint services that we believe will be of interest to you and to send you tailored direct marketing about those services via email. We will respect your preferences for how you would like us to manage marketing activity with you.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you (and with your consent, where required by applicable law);
- you can ask us to stop direct marketing at any time – you can opt-out of receiving marketing communications at any time by clicking the unsubscribe link located at the bottom of our emails or by contacting us using the information at Contact Us below.
- you may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
FlowPoint operates on a global basis. Accordingly, your personal information may be transferred outside of the country or province in which you are located or reside (which may include transfers outside of the province of Quebec, for Quebec residents), and stored in countries including Canada, US and UK that are subject to different standards of data protection. FlowPoint will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- we ensure transfers within FlowPoint will be covered by an agreement entered into by members of FlowPoint which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within FlowPoint;
- where we transfer your personal information outside FlowPoint or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information; and
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed.
If your personal data is transferred outside the European Economic Area or the UK, we comply with the requirements of Chapter V of the GDPR or the UK GDPR, as applicable. To the extent that an adequate level of protection is not already ensured on the basis of an adequacy decision of the EU Commission or the UK Parliament, we conclude in particular the standard contractual clauses of the EU Commission for the transfer of personal data (Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council), with the UK Addendum (where appropriate). In addition, we take supplementary measures to protect your personal data as necessary. The obligation to comply with the requirements of Chapter V of the GDPR/UK GDPR also applies to service providers we use.
You can contact us using the information available at Contact Us below for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal data when this is transferred as mentioned above.
SAFEGUARDS AND RETENTION
We have implemented appropriate administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job and service requirements.
We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes described above or to otherwise meet applicable legal requirements (which may extend beyond the end of your relationship with us). You may contact us using the information at Contact Us below to learn more about specific retention periods.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Depending on your jurisdiction of residence, and subject to certain exemptions under applicable law, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have: [these links will be provided once we start using cookies on our website]
- To access personal information
- To correct, rectify / erase personal information
- To restrict the processing of your personal information
- To transfer your personal information
- To object to the processing of personal information
- To object to how we use your personal information for direct marketing purposes
- To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
- To lodge a complaint with your local supervisory authority
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us using the details at Contact Us below. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to correct, rectify or erase personal information
You have a right to request that we rectify, update or correct inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected or otherwise processed; or
- you have withdrawn your consent (where the data processing was based on consent) and we cannot base the processing on another legal basis; or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which FlowPoint is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
If we have obtained your consent, you may withdraw your consent any time (subject to legal and contractual restrictions).
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
|Right to object to the processing of your personal dataYou can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.|
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not share your personal information with unaffiliated third parties for the purposes of direct marketing or any other purposes. Please note that in certain jurisdictions, such as Canada, we do not share personal information with third parties for their own marketing or other purposes without your prior consent.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
If you have concerns about how we are processing your personal data, you have a right to lodge a complaint with your local supervisory authority, in particular the supervisory authority at your location, place of work or place of alleged infringement.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may be updated periodically to reflect changes of our personal information practices. We will post the updated Privacy Notice on our Website. This Privacy Notice was last updated on [Date].
If you have any questions or comments about this privacy notice or would like to exercise your privacy rights, please contact us via firstname.lastname@example.org and we will be happy to assist you.
APPENDIX – EU/UK Lawful bases for processing
|Activity*||Lawful basis, including our legitimate interest (where applicable)|
|Email communications||Marketing Communications: Our Legitimate Interests in marketing our products and services to businesses that may be interested in our offering, and in maintaining a suppression list to ensure compliance with data subjects’ right to object to such processing of their data.Service Communications: Where the agreement is with your company: To comply with our Legal Obligations;To the extent that our communications are not strictly mandated by law, our overriding Legitimate Interest in complying with our obligations under the terms of any contractual agreement we have with your company.Where we have an agreement with you rather than your company: Performance of a Contract – in order to comply with our obligations under the terms of any contractual agreement we have with you.|
|White Papers and Webinars||Our Legitimate Interest in marketing our products and services to businesses that may be interested in our offering.|
|Employment||Our Legitimate Interest in employing appropriate personnel, to assess your suitability for employment and to respond to your queries.Consent – to retain your information and to send you information about other current/ future opportunities.Performance of a contract or to take precontractual measures – where we take steps to employ you.|
|Suppliers||Our Legitimate Interests in managing our suppliers and managing our relationship with our suppliers.|
|Surveys and Research||Our Legitimate Interests in understanding our users, and in improving our products and services.|
|Contact Us||Our Legitimate Interests in responding to potential customers, in managing our business and reputation, and in improving our products and services.|
|Call Recording||In Germany: Consent – Your active consent will be sought at the beginning of any call intended for recording.Otherwise:Our Legitimate Interest in ensuring the quality of our services.|
|Website Functionality||Our Legitimate Interest in ensuring the safe and secure operation of our website in relation to personal data processed in order to provide essential functionality. Consent – Your active consent will be sought for processing of personal data in order to provide optional (non-essential) functionality.|
|Interest Based Advertising (including data sharing with our advertising partners)||Consent|
|Data sharing with third parties (including within the Espresso Group) for marketing purposes||Consent|
|Internal administrative purposes||Our Legitimate Interests in managing and administering our business efficiently and in compliance with applicable legal and regulatory obligations.To comply with our Legal Obligations.|
|Legal & Compliance purposes||The lawful ground may vary depending upon the specific circumstances. This may include for example where the relevant activity is necessary:for compliance with a legal obligation;for the establishment, exercise or defence of legal claims; orin order to protect the vital interests of an individual.To the extent that special category personal data is processed (such as, on occasion, where carrying out background checks), we will usually rely on the fact that such processing is in the substantial public interest.|