Privacy

 
 

THE FLOOW LIMITED – MOBILE APPLICATION PRIVACY POLICY

The Floow Limited (we, our, us) are committed to protecting and respecting your privacy. This policy (together with our end user licence agreement and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading TRIPMATE app (App) via either Apple’s App Store or the Google Play Store, you are accepting and consenting to the practices described in this policy.

1. WHO ARE WE?

Your personal data i.e. any information which identifies you, or which can be identified as relating to you personally, will be collected and used by The Floow Limited, a company registered in England with company number 07968005. Our registered office is at The Floow Campus, Wicker Lane, Sheffield, S3 8HQ.

The data controller is The Floow Ltd, The Floow Campus, Wicker Lane, Sheffield, UK, S3 8HQ

2. THE DATA WE COLLECT FROM YOU

2.1. Information you give us. When you download and use the App (or contact us in respect of the App), we may collect any or all of the following information about you: * Personal details (Email address, name, region, age range & gender).

2.2. Data we collect automatically. When you install and run the App, we may collect any or all of the following technical data: * Device Identifiers (the internet protocol address used to connect your device to the internet, your login information, browser type and version, regional settings, operating system and platform); * data about your use of the App; * information stored on your device; * location information. We use GPS technology to determine your current location; * data about your driving (acceleration, braking, speed, journey times); and * data about when you make and receive phone calls, send and receive text messages on your device.

3. COOKIES

3.1. What cookies are and how we use them. Cookies are small data files which we place on your device. We use cookies to distinguish you from other users using the App. This helps us to provide you with a good experience when you use the App and also helps us to improve the App.

4. HOW WE USE YOUR PERSONAL DATA

4.1. The purpose of processing your personal data. You have asked us to process your personal data for the purpose of analysing your driving habits and calculating a driving “score” which may then be used: (i) by you for your own purposes; (ii) by us to determine the results of any prize competitions that you may enter that are run by us; and (iii) by us for improving our services and operations, developing new services and offerings, and other research, data science, analytics and related purposes.   None of the data that is collected will be used to calculate insurance premiums, or for any other insurance purpose.

4.2. How your personal data is used. We only ever use your personal data with your consent, or where it is necessary in order to: * enter into, or perform, a contract with you; * comply with a legal duty; * protect your vital interests; * remember your preferences e.g. if you ask not to receive marketing material, we’ll keep a record of this; or * for our own (or a third party’s) lawful interests, provided your rights don’t override these.

In any event, we’ll only use your personal data for the purposes for which it was collected, or purposes which are very similar.

4.3. Withdrawing your consent. You can withdraw your consent at any time to our processing of your personal data for any purpose at any time, by contacting us at the email or postal address set out in paragraph 8.

4.4 How Anonymous Data may be used. For the purpose of this paragraph 4.4 “Anonymous Data” means data that has been de-identified and/or aggregated with other data to such an extent that you are no longer identified, identifiable or otherwise ascertainable by reference to such data or in combination with other datasets. We will maintain Anonymous Data as part of our own records and information and may share Anonymous Data with third parties. Anonymous Data may be used by us (and shared with third parties) for certain legitimate business purposes including operating and improving our services and operations, developing new services and offerings, and other research, data science, analytics and related purposes.

5. HOW WE PROTECT YOUR PERSONAL DATA

5.1. Technical and organisational measures. We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorised access to, use or disclosure of it. Electronic data and databases are stored on secure computer systems and we control who has access to them (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection policies and procedures which personnel are required to follow when handling personal data. Of course we cannot absolutely guarantee the security of the internet or external networks and any online communications (e.g. information provided by email or through our website are at your own risk).

5.2. Device security. You are fully responsible for access to your device. You undertake not to allow unauthorised third parties to use your device for any reason whatsoever. You undertake to contact us as soon as possible should you suspect that an authorised person has gained access to your device. We shall not be held liable for any misuse of your device and any resulting consequences for you, your partner, or any third party.

6. WHO CAN ACCESS YOUR PERSONAL DATA

We will not communicate, sell or transfer your personal data to third parties without obtaining your prior written consent, except where we are required to do so by law. We may share personal data with subcontractors or suppliers who provide us with services. However, these activities will be carried out under a contract which imposes strict requirements on our subcontractors or suppliers to keep your information confidential and secure.

7. STORAGE OF PERSONAL DATA

7.1 Where it is stored. We only store data within the European Economic Area (EEA). If our trusted service providers transfer any of it outside of the EEA we will take steps to make sure adequate levels of privacy protection, in line with UK Data Protection legislation, are in place.

7.2. How long it is stored for. The data will be stored and kept for as long as your App remains active. Following deactivation of the App or in the event that you do not use the App for a period of six months then we will treat the account as expired - we continually review the personal data we hold and delete what is no longer required.

7.3 BREXIT TOLERANT. We are monitoring the BREXIT debate in regards to deal or no deal, and how BREXIT will impact the UK Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) (“GDPR”). We are closely monitoring the rules governing the collection and use of personal data that are currently set at an EU level by the GDPR. If the UK leaves the EU even with no agreement in place regarding future arrangements for data protection, the Information Commissioner's Office advice is there would be no immediate change in the UK’s own data protection standards. This is because the Data Protection Act 2018 would remain in place and the European Union (Withdrawal Act) 2018 would write the GDPR into UK law with the necessary changes to tailor its provisions for the UK.

8. YOUR RIGHTS We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows: * the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of it (this is known as a subject access request) within one month of our receiving your request; * the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason); * the right to have inaccurate data rectified; * the right to object to your data being used for marketing or profiling; and * where technically feasible, you have the right to see any personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format. If you would like further information on your rights or wish to exercise them, please write to us at marketing@thefloow.com or The Floow Limited, The Floow Campus, Wicker Lane, Sheffield, S3 8HQ.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.