Effective Date: September 1, 2022.
This Policy describes how we collect, store, use and disclose personal information which relates to visitors of our website www.helloflare.com (“Site”) who visit the Site or otherwise interact with our online ads and content, emails and communications in relation to the Site (collectively, “Visitors”).
1. Data Collection & Processing
When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. It does not include aggregated, de-identified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Specifically, in the last twelve months (12) we have collected, in relation to the Services, the following categories of Personal information:
Category A - Identifier
Name, postal address, phone number, email address, username, password, IP address, or other similar identifiers
Category B – Additional personal information categories
Address, telephone number
Category F – Internet or other similar network activity
Access history and information on your interaction with our application recorded by log files, cookies, pixels, device fingerprinting, information for authentication and account access
Category G – Geolocation data
Location data including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level)
Client Relationship Manager (CRM) and prospective clients’ information
Contact details you provide us with, content of your communications with us, as well as any needs, preferences, attributes and insights relevant to the potential engagement
We obtain the categories of personal information listed above from the following categories of sources:
From the User: We collect personal information about you when you use the Services, such as information you provide when you access our online content or contact customer support;
Information collected automatically: We generate personal information when you use the Services, such as data about your use of the Services, data about your device (device’s operating software, your internet service provider, settings, and device identifier) and data about your location (such as location derived from an IP address or data that indicates a city or postal code level);
From third parties: We collect personal information about you from other sources such as our affiliates, social networks with which you interact, or vendors, as well as from publicly available sources.
2. Data Uses & Business Purposes
• Operating and managing our Site.
• Providing customer service.
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Supporting and enhancing our data security measures, including for purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
• Monitoring and analyzing trends, usage, and activities to improve your and others’ Visitors experience, our offerings and the overall performance of the Site
• Improving the Site or other apps, marketing efforts, products and services.
• Developing and sending you advertising, direct marketing, and communications, including about our and other entities’ products, offers, promotions, rewards, events, and services, that may be of specific interest to you.
• Creating aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose.
• Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.
• Complying with applicable laws and regulations
• Complying with court orders and warrants, and prevent misuse of the Site, and to take any action in any related legal dispute and proceeding.
We may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
3. Data Location & Retention
Data Location: We and our authorized service providers (defined below) maintain, store and process personal information in the United States and other locations as reasonably necessary for the proper performance and delivery of our Site, or as may be required by applicable law.
While privacy laws vary between jurisdictions, Flare, its affiliates and service providers are each committed to protect personal information in accordance with this Policy, customary and reasonable industry standards, and contractual terms requiring adequate protection of the personal information.
Data Retention: We may retain your personal information for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements. If you have any questions about our data retention policy, please contact us by email at email@example.com.
4. Data Disclosure
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Additional personal information categories
Category F: Internet or other similar network activity
Category G: Geolocation data
CRM and prospective client’s information
We disclose your personal information for a business purpose to the following categories of third parties:
Service providers: We engage selected third-party companies and individuals as service Providers, to perform services on our behalf or complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, fraud detection, web and mobile analytics, email and communication distribution and monitoring services, session or activity recording services, analytics services, event production and hosting services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content, lead generating and data enrichment providers, email, support and customer relation management systems, third-party customer support providers, and our legal, compliance and financial advisors and auditors.
Our service providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services or other activities, and may only use the data as determined in our agreements with them.
Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly on our Site. If you wish to remove your public review, please contact us at firstname.lastname@example.org.
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal information, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services.
Protecting Rights and Safety: We may share your personal information with others if we believe in good faith that this will help protect the rights, property or safety of Flare, our Visitors or any members of the general public.
Flare Affiliates/Subsidiaries and organizational changes: We share personal information internally within our group of companies (i.e., affiliates and subsidiaries), for the purposes described in this Policy. In addition, should Flare or any of our group of companies undergo any change in control, including by means of merger, acquisition or purchase of substantially all or a portion of its assets, or transfer of all or a portion of its business to another business, your personal information may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal information stored with us at the time, we will notify you of this event and the choices you may have via email or a prominent notice on the Site.
For the avoidance of doubt, Flare may share your personal information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.
In the preceding twelve (12) months, we have not sold any personal information.
5. Cookies and Tracking Technologies
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
We engage in Services and promotional communications, through email, phone, chat, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc.
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Flare at any time by sending an email to email@example.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.
7. Data Security
In order to protect your personal information held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal information stored with us or with any third parties as described in Section 4 above.
8. Data Subject Rights
If you wish to exercise your privacy rights under any applicable law, such as the California Consumer Privacy Act (CCPA) or other state or federal laws, such as the right to know/request access to (specific pieces of personal information collected; categories of personal information collected; categories of sources from whom the personal information was collected; purpose of collecting personal information; categories of third parties with whom we have shared personal information), to request rectification or erasure of your personal information held with Flare, or to restrict or object to such personal information’s processing (including the right to direct us not to sell your personal information to third parties now or in the future), or to obtain a copy or port such personal information, or the right to equal Services and prices (i.e. non-discrimination) – please contact us by email at firstname.lastname@example.org.
We may redact from the data which we make available to you, any personal or confidential data related to others.
9. Business/Service Provider
Certain data protection laws and regulations typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, “Business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “Services provider”), who processes such data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
10. Additional Notices
Our Services is not directed to children under the age of 16: We do not knowingly collect personal information from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal information stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at email@example.com.