At the FLOWi, we are committed to helping sustainable urban impact projects get off the ground by finding investors seeking investments that deliver socio and environment benefits in addition to financial benefit.  As part of our FLOWi community, we will always make protecting and respecting your privacy a priority.

This Privacy Policy explains how FLOWi SAS will process the data relating to you that you provide to us (or that we may collect) when you visit the website at www.flowi-impact.com (“Website”), including when you login as a FLOWi member to use any of our online services or otherwise engage with us or other members of our FLOWi community.

 

1. INTRODUCTION AND GENERAL TERMS

The Website is operated by FLOWi SAS (“we, us, our, FLOWi”), a company incorporated in FRANCE with company number 851 187 385 and registered office at 128 rue la Boétie 75008 Paris.

Where we decide the purpose and means for the processing of personal data relating to you, we are the “controller”. As the controller, we will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 and Data Protection Act 2018.

If you have any questions or comments about this Privacy Policy please contact us at:

Email: contact@flowi-impact.com

 

Please read this Privacy Policy carefully as it contains important information about the following:

• What information FLOWi may collect about you or receive from others;

• How and why FLOWi will use that information;

• Whether FLOWi will disclose information about you to anyone else; and

• Your choices and rights regarding the personal information we hold about you.

This Privacy Policy should be read in conjunction with our other policies and procedures, website terms of use, notices or agreements with you, as may be relevant. 

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2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data:

Customer Services (including visiting our Website)

Type of information 

Purpose of the processing and legal basis for the processing 

Who is this information shared with?

We may ask you for, or you may submit, personal and non-personal information to us when contacting us through our Website messaging tool, by telephone or via email in relation to the services that we offer or to submit enquiries.

Personal data that we may obtain includes:

1. 1. • your first and last name

      • email address

      • phone number(s) 

      • login details (your username and password)

      • online identifiers, such as IP or MAC address, cookies and tracking data and other unique user identifiers

      • your data held by social media, such as Twitter and LinkedIn (where permitted by your account settings)

      • any other personal information you voluntarily provide in a free-text message or otherwise

We may legally process the personal information that we hold on the basis that we have a legitimate interest, under our legal obligations and/or for the performance of a contract, including processing for the following purposes: 

1. 1. • to provide you with information about investment opportunities (whether you are seeking to invest or to obtain funding) via our Sustainable City Finance & Impact deal sourcing services

      • to set up and administer your user account when you subscribe and become a member of the FLOWi community

      • to enter into and  perform our contract for the provision of membership services

• to respond to your enquires

• when you sign up to receive regular updates to keep you in the loop about our news including current and upcoming opportunities and events

• when you use our online services, including our FLOWi community network and deal sourcing facilities

1. 1. • to manage risk or prevent other illegal or prohibited activities

      • to resolve issues or fix problems in relation to our Website

We may obtain more sensitive personal data (known under law as special categories of personal data), such as data revealing racial or ethnic origin (or that of others), if you voluntarily supply it through an online submission. 

If you volunteer such information, you will be consenting to our processing it in relation to the purpose for which you have provided it.

However, we do not ask for sensitive personal data and you are always free to decline to provide it.

We keep your information confidential. We will not sell your information.  We may disclose your information to our personnel and others in the FLOWi community (in accordance with your account privacy settings) and to third party suppliers or subcontractors (including our independent impact curators and other consultants, data analytics and/or online targeted advertising providers, and cloud-based data processing and hosting providers).

If we do share your information with third parties outside our FLOWi community, we will only do so insofar as it is reasonable or necessary for the operation of our business, including for the purposes set out in this Privacy Policy, and provided that those recipients do not make independent use of the information and have agreed to adhere to the rules set out in this Privacy Policy.  

In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below. 

 

 

Marketing, Advertising and Social Media

Type of information 

Purpose of the processing and legal basis for the processing 

Who is this information shared with?

Our Website does not contain third party advertising.

We may collect information about you in order to send you our promotional or marketing communications, such as:

1. • your name (first and last)

   • your email and/or postal address

   • your telephone number(s) 

   • any other personal information that you may provide when contacting us

While we do not permit third party advertising on our Website, if you do link to one of our social media platforms you may be subject to targeted marketing via that site.

The Website contains links to FLOWi’s social media pages on Twitter, Instagram and LinkedIn.  

These third party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible. 

Should you visit those social media pages and choose to follow or connect with us on social media, FLOWi may receive personal information from the social media providers (depending on your social media privacy settings), including:

1. • your name (and/or your social media unique user name)

   • your email and/or postal address

   • your telephone number(s)

   • IP or MAC address

   • your gender and/or age

   • your general interests and preferences (e.g. Likes, Shares, Posts)

If we do receive any personal information about you from these third party social media sites, we will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so.

We may use this information to find out more about our digital community so that we can better understand and serve our FLOWi members and other visitors to our Website interested in our mission and Sustainable City Finance and Impact deals platform (for example, to create bespoke content by analysing general interests).

We may also process personal information collected via social media to improve our marketing, including the creation of custom audiences and lookalike audiences. This allows us to offer more relevant marketing to potential new customers and service users without using information that personally identifies you.

Where we provide you with information about our services, including the investment opportunities supported by our services, we will only use your personal information in this way in accordance with laws relating to marketing directly to individuals, and in the pursuit of our legitimate interest of marketing our business. 

If you have subscribed to our updates by signing up to these on our Website, which adds subscribers to our mailing list, we will provide your details to our third party email service provider that helps us to produce and manage our newsletters. 

If you change your mind, you may opt-out at any time via the unsubscribe feature that appears in our emails or by emailing contact@flowi-impact.com.

 

When you share your personal information on our these social media sites, this may be shared with that social media provider which may then process that information to enable them to provide targeted marketing messages where you have indicated your agreement (for example, via your privacy settings) to receive these messages from them or where it is otherwise lawful to do so.

In some instances, this may include you submitting your details and answering questions on lead ad forms to receive further information or prompt us to contact you directly.

We engage third party sub-processors and service providers to assist us with our data collection, analysis and marketing, including: 

• Facebook Ads, Google Ads, Hubspot, Sendgrid, Typeform.

• We will not otherwise share with any other third party the personal information that we obtain about you for the purposes of marketing, unless you have provided your consent or it is otherwise lawful for us to do so.

If you would like us to delete the personal information that we have received about you from these sites, please email us at contact@flowi-impact.com. 

If you do not want us to receive further information about you from these sites, you should also contact the sites directly to turn off the ‘follow’ setting.

If you would like to have deleted the personal data that you’ve shared with the social media accounts that you have joined or that you follow, please contact the social media providers directly.

 

Purchasing FLOWi Subscription Services (Financial Data)

 

Type of information 

Purpose of the processing and legal basis for the processing 

Who is this information shared with?

Via our Website, we offer you the opportunity to subscribe to our membership. 

If you chose to subscribe online, we will collect some financial details from you including the following personal information:

1. • your name (first and last)

   • your email and/or postal address

   • your telephone number(s)

   • credit or debit card details or bank account details

   • information about your purchase (e.g. start and end dates of subscription)

We may collect and process your details to provide you with our subscription services for which you have placed an order. 

We process this personal data in order to perform our services agreement with you and to meet our legal obligations or legitimate interests as a sustainable urban impact projects investor-investment deal sourcing platform. 

We may contact you about your purchase (for example, sending you updates about platform features or notices about changes to our platform), and we may create and store a record of your purchase history.

Financial transactions via our Website are handled by us in conjunction with our third party e-payment services provider. While we receive information about your order (for example, details about the subscription that you are purchasing), we do not receive your personal financial data.

Via the links on our Website, you may be re-directed to our third party e-payment service providers’ websites where further financial personal details will be required in order to complete your purchase.  

The third party e-payment  service provider that we use is Stripe, Inc. (https://stripe.com/gb)

When you opt to make a purchase via our third party e-payment services provider(s), we will not share any personal information with them, nor will we receive any of the financial information that you provide to them. 

 

Purchasing FLOWi Subscription Services (Financial Data)

 

Via our Website, we offer you the opportunity to subscribe to our annual membership. 

All financial transactions are handled directly by our payment service providers. We will not share any personal information with these third party providers, nor will we receive any of the financial information that you provide to them. 

The third party e-payment service provider which we use is Stripe, Inc. For further information about this service provider, please visit its website at https://stripe.com/gb

 

Data Analytics and Cookies

Our Website uses cookies and other mechanisms to collect log and analytical information, to help analyse how visitors use the site, to compile statistical reports on Website activity and to improve our marketing function.  To find out more about the use of cookies, please visit http://www.allaboutcookies.org/.

Our Website also uses website analytics, including Google Analytics, to evaluate and improve our Website, personalise your experience and to offer the best, most accessible service possible to all of our customers.  

To find out more about Google Analytics and to learn how to opt out, please visit:

• How Google uses data when you use our partners' sites or apps, or

• https://tools.google.com/dlpage/gaoptout/.

When you visit our Website, these analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:

• number of visitors to our Website;

• pages visited while at the Website and time spent per page;

• page interaction information, such as scrolling, clicks and browsing methods;

• websites where visitors have come from and where they go afterwards (clickstream), including date and time, products or services that you viewed, searched for or hovered over;

• page response times and any download errors; and

• Internet protocol (IP) address used to connect, browser type and version (including any browser plug-in details) and operating system and your time zone setting and login information

We process this analytics information for a number of purposes, including:

• to help us improve our Website and the online services to ensure that content, including marketing and promotional content, is presented in the most effective manner for you and for your device;

• to understand how, and how often, users visit and interact with our Website and social media and use our online services (such as our members’ FLOWi messaging feature); 

• to understand how visitors interact with our Website and each other;

• to find out statistical information about the use of the Website;

• to monitor the technical operation of our Website (e.g. response times, downloading / uploading errors);

• to obtain other technical information relating to end user devices;

• to administer our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to compile statistical reports regarding visitor activity (for example, your IP address is used to approximate the country from which you access our Website, and we aggregate this information together so we can see from what regions or countries most of the visitors to our Website originate); and

• to protect against and remove objectionable uploaded content.

This analysis is fundamental to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Website, and to provide a better service and source of information to visitors.

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3. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy. If you would like to find out more about how the third parties listed in this policy use your information, this should be set out in their respective privacy policies.

We keep your information confidential but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard this information.

In addition, we may disclose your information to the extent that we are required to do so by law (which may include government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements between us, to investigate potential breaches, or to protect the rights, property or safety of FLOWi SAS, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If you send us objectionable content or behave in a disruptive manner when using our Website, we may process any personal information that you have submitted to us, including in your personal messages, to respond to and stop such behavior.  Where we reasonably believe that you are or may be in breach of the law (i.e. the content you share on the Website amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties about the content, such as your email or internet provider or law enforcement agencies.

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4. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by clicking on the unsubscribe link in those emails or contacting us at contact@flowi-impact.com at any time.

  

5. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

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You have a number of rights in relation to the way we process personal data about you.  Where an individual makes a request in accordance with provisions of the GDPR, we aim to comply without undue delay, and within one month at the latest.  Those data subject rights include the right to make the following requests:

• to ask for confirmation and information about the personal data that we process about you, including a copy of data we are processing about you;

• to have inaccuracies corrected or incomplete personal data made complete;

• to ask us to restrict, stop processing, or to delete your personal data; 

• to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and to not be subject to automated decision-making, including profiling; and

• to make a complaint to the data protection supervisory authority.

To make a request, please let us know by contacting our Data Protection Manager on the details below.

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6. DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits the identification of the person(s) to whom it relates for any longer than is necessary.

If you would like us to stop using your personal information, please email us at contact@flowi-impact.com

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7. DATA RELATING TO CHILDREN

We do not knowingly use the Website to solicit data from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us or otherwise interacting with us without consent of a parent or guardian, we ask that this be brought to our immediate attention.  We will make it our priority to address this situation and delete information relating to a child as soon as practicable. In such an event, please contact us at contact@flowi-impact.com

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8. SECURITY OF DATA

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We will take commercially reasonable, appropriate technical and organizational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorized disclosure of or access to the personal information transmitted, stored or otherwise processed by us. 

Please be aware that, while we take the security of our Website and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.  

 

9. INTERNATIONAL DATA TRANSFERS

The personal data that we collect from you (or obtain about you) may be transferred to, and stored at, or accessed from a destination outside the European Economic Area (EEA).  It may also be transferred to and processed by: 

• staff operating outside the EEA who work for us or for one of our suppliers or third party service providers, many of whom may operate from multiple locations including non-EEA based operations or engage sub-processors located outside the EEA.  This includes staff engaged in, among other things, the provisions of membership services or IT support services; and/or

• other members of the FLOWi community, including investors (and prospective investors), investment project representatives, intermediaries and project advocates (including influencers, incubators or accelerators), impact curators and other project partners, who may access, use, store and otherwise process personal data that is available on the platform from locations outside the EEA.

Where such international transfers of personal data occur, we will ensure that appropriate safeguards are put in place that meets the requirements of EU data protection laws.

If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at contact@flowi-impact.com.

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10. CHANGES TO THIS POLICY

This Privacy Policy may be updated from time to time. We will notify you of any changes to this policy by posting the new version of the Privacy Policy on our Website. You are advised to consult this Privacy Policy webpage regularly for any changes.

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11. HYPERLINKS TO THIRD PARTY WEBSITES

Our Website may contain hyperlinks to third party websites.  These third-party websites operate independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources.  The appearance of such links on our Website is not an endorsement. Should you use any of these websites, such use is at your own risk and we would advise that you review their respective privacy policies.

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12. CONTACT US

Questions, comments, and requests in relation to this Privacy Policy are welcome and should be addressed to contact@flowi-impact.com.

Alternatively, you may address these to our Data Protection Manager at FLOWi impact 128 rue La Boétie 75008 Paris, France.

 

Last Updated: [July 2019]