1. Modifications to this Privacy Policy

From time to time, we may modify, revise and add specific instructions, policies and terms to this Privacy Policy. Any future updates to this Policy shall form part of this Privacy Policy. Whenever we make any material changes to this Privacy Policy, we will post the updated Privacy Policy and notify you via our periodic newsletters (if you are subscribed), or on this link or on our website or other means. Prior to giving consent, the Data Subject shall be informed of his right and method to withdraw his consent at any given time. However, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

2. What information do we process?

Basically, the information we collect, process, apply, share, store and retain are:

a. User’s phone number - You register a phone number when you create an account. Phone numbers, along with other required details, are used to open an account on our platform and grant you access to our services.

b. Name of User (optional).

c. Contact list on User’s phone to sync and find other Flom users.

d. UUID of the User’s phone device for security.

e. User’s device name and details.

f. Push or token details.

3. How we collect your data

We collect Personal Data from and about you when

a. you register on the platform,

b. use, provide or process information on our platform or

c. use our Products and Services.

4. What we do with your data

We use the Data we collect to help us operate, provide, improve, understand, customize, support, and provide you with rich, interactive Customer experiences. In particular, your data is used for the following purposes:

a. Commercial Messaging - We will allow you and third parties on Flom to communicate with each other using the provided services for business purposes, such as through service or merchandise orders, product and service sales, updates, and marketing.

b. To verify your account and eligibility for any of our products and Services.

c. To communicate with you through the channels you have approved to keep you up to date on our latest products and services, corporate and business announcements, and other information about our services, products and technologies – including client briefings, newsletters and other information.

d. For compliance with our legal obligations such as record keeping obligations (such as under antitrust laws, export controls, trade sanction and embargo laws, for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists which may be relevant for compliance purposes.

e. Personalize our products and make recommendations or to analyze and improve our services and communications, and to advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.

f. We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research to make the Service a better one for you and other users.

g. To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and to detect security threats, fraud or other criminal or malicious activities.

h. To monitor and assess compliance with our policies and standards;

i. To identify persons authorized to trade on Flom personally or on behalf of our clients, customers, suppliers and/or service providers.

j. On instruction or request from a relevant law enforcement agency or body in any jurisdiction or a relevant Third Party Entity.

k. Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.

l. To comply with court orders and exercises, or when required by law to respond to legal process and/or defend our legal rights.

m. For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

5. Sharing of your information

We may share your personal data in the following circumstances:

a. We may share your personal data between Qrios entities on a confidential basis where this is required for the purpose of providing you with our products and services, as well as for administrative, billing and other business purposes.

b. We may disclose your contact details on a confidential basis to third parties for the purposes of collecting your feedback on our service provision, to help us measure our performance and to improve and promote our services.

c. We may share your personal data with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared.

d. We may share your personal data with any third party to whom we assign or novate any of our rights or obligations.

e. We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.

f. We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

6. Storing your information

Be assured you that we take reasonable and practical steps and measures to secure the integrity of retained information. This we do by using best internationally and acceptable technological standards to prevent unauthorised access to or disclosure of your personal data, and protect your personal data from misuse, loss, alteration or destruction. Same level of security and integrity attached to our own information are deployed to safeguard your information.
Your personal data may be stored in data centres within and outside your country of residence. The infrastructure housing the data are owned and operated by us, our service providers or affiliated companies. Where the location that personal data is transferred to or stored does not have substantially similar laws as your local country of residence, we will take reasonably practicable steps to ensure that your personal data is adequately protected in that jurisdiction.

7. Security of your personal data

We take your privacy very seriously and work hard to protect your data from being accidentally lost, used or accessed in an unauthorised manner, way, altered or disclosed. We have put in place appropriate security measures to prevent this from happening. In addition, your personal data is only accessible by employees, volunteers, agents, contractors and other third parties strictly on a need to know basis for the purpose of providing the service and products. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

8. Security and encryption

Flom uses Advanced Encryption Standard (AES) which is a fast and secure form of encryption that keeps prying eyes away from your message data. It is an excellent standard for securing our electronic communication and can be applied in many situations where sensitive information needs to be protected. Judging by the current level of technology and attack techniques, you should feel confident using it in Flom well into the foreseeable future.

9. Why we are retaining your information

Your personal Data is retained in recognizable and usable format generally for the period of time required by regulation and in compliance with all legal obligations and other business objectives. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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. It is possible for us to retain your information for longer periods than required by law as long as this is not in contravention of any existing law or regulation, and there are valid reasons for us to retain such data beyond the stipulated period.

10. Assignment, change of control, and transfer

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

11. Our global operations

You agree to our information practices, including the collection, use, processing, and sharing of your information as described in this Privacy Policy, as well as the transfer and processing of your information to the United States and other countries globally where we have or use facilities, service providers, or partners, regardless of where you use our Services. You acknowledge that the laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country.

12. Any Age restriction for accessing Our Services?

Our Site and Services are not directed to children under the age of 13 years.  Where we become aware that we have inadvertently collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data.

13. Contact us

If you have questions about our Privacy Policy, please contact us
ask@flom.co
Qrios, Inc.
5465 Legacy Dr., Suite 650, Plano, TX 75024,
Texas