Privacy Policy

Last Updated March 10, 2022

Freeflow Services, Inc. (“Freeflow,” “we ,” “us,” or “our”) has prepared this Privacy Policy to explain what personal information we collect, how we use and share that information, and your choices concerning our information practices when using our platform (the “Platform”).

Before using the Platform or submitting any personal information to Freeflow, please review this Privacy Policy carefully and contact us if you have any questions. By using the Platform, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Platform.

1. PERSONAL INFORMATION COLLECTION

Personal Information You Provide: We collect the following categories of personal information from you:

Internet Activity Information: When you visit, use, and interact with the Platform, the following information may be created and automatically logged in our systems:

The following technologies may be used to collect Internet Activity Information:

2. PERSONAL INFORMATION USE

Your personal information is used for the following purposes:

Service Delivery , including to:

Communicating with You:

Platform Improvement, including to:

Marketing and Advertising: We and our advertising partners may use your personal information for marketing and advertising purposes, including:

Compliance and Protection including to:

3. PERSONAL INFORMATION SHARING

4. PERSONAL INFORMATION RETENTION

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

5. NOTICE TO CALIFORNIA RESIDENTS

Where provided for by law and subject to any applicable exceptions, California residents may have the following rights:

If you would like to exercise any of these rights, or want an alternative form of this Privacy Policy, please contact us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you authorized the agent to submit the request. We will not treat you differently for exercising your rights.

6. EU USERS

Scope . This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).

Data Controller . Data protection laws in the EU differentiate between the “data controller” and “data processor” of personal information. Freeflow is the data controller for the processing of your personal information unless it is processing such personal information on behalf of a customer or other third party. You can find our contact information in the “Contact Us” section below.

Data Processor . Freeflow is the data processor for the processing of your personal information when it is processing such information on behalf of a customer or other third party. To exercise the rights described below in such a circumstance, please contact the corresponding Freeflow customer.

Legal Bases for Processing . This Privacy Policy (the paragraph “Personal Information Use”) describes the legal bases we rely on for the processing of your personal information. Please contact us if you have any questions about the specific legal basis we are relying on to process your personal information.

As used in this Privacy Policy, “legitimate interests” means our interests in conducting our business and developing a business relationship with you. This Privacy Policy describes when we process your personal information for our legitimate interests, what these interests are and your rights. We will not use your personal information for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Your Rights . Pursuant to the European Union General Data Protection Regulation (or GDPR), you have the following rights in relation to your personal information, under certain circumstances and subject to any applicable exceptions:

- If we are relying on a legitimate interest to process your personal information -- unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;

- If we are processing your personal information for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above);

Please see the “Contact Us” section below for information on how to exercise your rights.

Data Transfers. Freeflow is based in the United States and Freeflow processes and stores your personal information in the United States. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer.

7. CHILDREN

Our Platform is not directed individuals who are under the age of 16. Freeflow does not knowingly collect personal information from individuals under the age of 16. If you believe that an individual under the age of 16 provided personal information to Freeflow please contact us and we will delete that information.

8. LINKS TO OTHER WEBSITES

The Platform may contain links to other websites not operated or controlled by Freeflow, including social media services (“ Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

9. SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information. You use the Platform at your own risk.

10. YOUR CHOICES

Update or Correct Personal Information: You can contact us and request any updates or corrections needed to keep your personal information accurate, current, and complete.

Opt Out of Marketing Communications You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in any marketing communication we send you. You can also control the communications you receive through your settings page. Please note, however, that you may continue to receive communications as described in the Communicating with You section after opting out of marketing communications.

Limit Online Tracking: Here are some of the ways you can limit online tracking:

- Firefox; Chrome; Microsoft Edge; Safari

- Digital Advertising Alliance

- Network Advertising Initiative

Note that the above opt-out mechanisms are specific to the device or browser on which they are exercised. You will need to opt out on every browser and device that you use.

Do Not Track. We currently do not respond to "Do Not Track" or similar signals. Learn more about "Do Not Track" here.

11. CHANGES TO THE PRIVACY POLICY

The Platform and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Platform or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and the practices described in it.

12. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at [email protected]

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