Privacy policy

This Privacy Policy applies to the Services offered by Flowrev, Inc. or its affiliated companies.

If you have any questions about this Privacy Policy, please feel free to contact us through our website.

Information we collect and how we use it

We may collect the following types of information:

• Information you provide When you sign up for a Flowrev Account, we ask you for personal information. We may combine the information you submit under your account with information from other Flowrev services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information. You can use the Flowrev "Home" page after log in to learn more about the information associated with your Account. Your administrator will have access to your account information including your email.
• Cookies – When you visit Flowrev, we send one or more cookies to your computer or other device. We use cookies to improve the quality of our service, including for storing user preferences.
• Log information When you access Flowrev via a browser, application or other client our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account. We log this information so we may provide you with any needed support as you use the service.
• User communications When you send email or other communications to Flowrev, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. We may use your email address to communicate with you about our services.
• Third Party Applications Flowrev utilizes information from third party web sites, such as invoices or other business data needed to deliver its services. The information collected by Flowrev when you enable a third party application is processed under this Privacy Policy. Information collected by the third party application provider is governed by their privacy policies.
• Other sites This Privacy Policy applies to Flowrev services only. We do not exercise control over the third parties sites you connect to in order to get the data that is used by the Flowrev revenue manager to deliver its service. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you and you should review their Privacy Policy on the respective site(s).

In addition to the above, we may use the information we collect to:

• Provide, maintain, protect, and improve our services and develop new services; and
• Protect the rights or property of Flowrev or our users.

If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

Flowrev processes and stores personal information on Amazon Web Services (AWS) servers in the United States of America and in other countries. In some cases, we process personal information outside your own country.

Choices

You can use the Flowrev Home page to review the information stored in your Flowrev Account.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Flowrev features and services may not function properly if your cookies are disabled.

Information sharing

Flowrev only shares personal information with other companies or individuals outside of Flowrev in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf or to deliver the Service. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures and regulations.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Flowrev, its users or the public as required or permitted by law.

If Flowrev becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews (including testing) of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. By a combination of such measures, and by utilizing GDPR compliant AWS (Amazon Web Services) infrastructure and services, we maintain compliance.

We restrict access to personal information to Flowrev employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Accessing and updating personal information

When you use Flowrev services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Enforcement

Flowrev regularly reviews its compliance with this Privacy Policy. When we receive formal written complaints, it is Flowrev’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Flowrev and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

May 25, 2018