Introduction

This Privacy Policy aims to give you information on how FLOWN collects and processes your personal data. It provides information on what personal data we collect, why we collect it, how it is used and the lawful basis on which your personal data is processed. It also sets out what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation ('GDPR').

FLOWN is the controller and is responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our") in this Privacy Policy.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy please contact the Data Privacy Manager by emailing liv@flown.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.

The data we collect about you

Personal data (or personal information) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity data - the personal details you provide when registering to become a host or a member. This may include first name, last name, username or similar identifier, marital status, title, date of birth, gender, profile picture, and any information about your work or business that you choose to provide, and any other information that you elect to disclose in your user profile on the FLOWN Platform.

  • Contact data - includes home and billing address, delivery address, email address, social media account names and telephone numbers.

  • Payment information - we may collect information regarding a member’s debit/credit card and/or bank account. We require this information for the purpose of recording and processing a membership application (and administering membership), and to process payments for bookings.

  • Technical data - includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types, operating system and platform, and other technology on the devices you use to access the Flown website.

  • Usage data - includes information about how you use our website and FLOWN services.

  • Location Information - FLOWN may use GPS technology to display a host’s property location. We may also use similar technology to provide location-based services to members.

  • Capacity planning and tracing information - we collect information regarding visits to our properties for capacity planning purposes and to comply with any applicable government guidelines, regulations and mandates.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

How your personal data is collected

We use different methods to collect data from and about you including:

  • Direct interactions - you may give us your identity and contact details by filling in forms or registering on the FLOWN Platform or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

  • register to become a FLOWN host or member

  • submit a support query

  • request to make a booking or modification

  • enter a competition, promotion, programme or survey

  • give us feedback or contact us for any reason.

  • Automated technologies or interactions - as you interact with the FLOWN platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email, social media or text message. You have the right to withdraw consent to marketing at any time, just let us know.

Below is a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you and your property as a new host

  • Identity

  • Contact

  • Payment Information

  • Location

  • Capacity Planning

Performance of an application, contract or relationship with you

To register you as a member

  • Identity

  • Contact

  • Payment Information

Performance of an application, contract or relationship with you

To manage our relationship with you:

Provide you with services and manage your account

Notifying you about changes to our terms of business or Privacy Policy

Asking you to leave a review

Fulfil your booking at a property

Resolve support queries

  • Identity

  • Contact

  • Payment Information

  • Technical

  • Location

  • Usage

Performance of a contract or relationship with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests

To enable you to partake in events, competitions or complete a survey

  • Identity

  • Contact

  • Usage

  • Location

Performance of a contract or relationship with you

Necessary for our legitimate interests

To administer and protect our business and this website

To provide data analytics to improve our website, products, services, marketing, customer relationships and FLOWN experiences.

To better understand how visitors interact with our websites and ensure that the FLOWN platform is presented in the most effective manner for you and for your computer/device.

  • Identity

  • Contact

  • Technical

  • Payment Information

  • Usage

  • Capacity planning

Necessary for our legitimate interests

Necessary to comply with a legal obligation

To contact you in case you may have been in contact with a person who has or is displaying symptoms of COVID-19 (or any other global illness or disease) and to comply with government guidelines, regulations and mandates.

  • Identity

  • Contact

  • Usage

Necessary for our legitimate interests to ensure the safety of our members, hosts and third parties

Necessary to comply with a legal obligation

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which FLOWN products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested it, or not opted out.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or the third parties to stop sending you marketing messages at any time.

Third Party Service providers

FLOWN sometimes hires selected third parties who act on its behalf to support its operations and help deliver FLOWN services and add ons, such as:

  • card processing or payment services

  • credit reference agencies to protect against possible fraud

  • IT suppliers and contractors as necessary to provide IT support and enable us to provide FLOWN services to members or hosts

  • web analytics providers

  • providers of digital advertising services

  • facilitators, wellbeing and exercise coaches and thought speakers

  • providers of CRM, marketing and sales software solutions.

These parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have engaged them to provide.

Payment Information

Any payments you make through our site will be processed by Flown and will be securely stored and encrypted using up to date industry standard technology.

We may arrange that card details submitted in support of a membership application are stored for the purpose of processing your application, initiating your membership or collecting a subscription fee.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who only have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

FLOWN will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Third-party links

The FLOWN website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit (if applicable).

Your legal rights:

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy

  • Where our use of the data is unlawful but you do not want us to erase it

  • You are a member and you wish to cancel your membership with FLOWN

  • You are a host and you wish to temporarily restrict bookings for properties

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you; your Membership with FLOWN might be put on hold or in the case of property Hosts your listing be removed from the FLOWN platform. We will advise you if this is the case at the time you withdraw your consent.

Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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