PRIVACY POLICY

Effective February, 2019

WELCOME TO FLASHBACK TECHNOLOGIES

This Privacy Policy is here to help you understand how we collect, use, disclose, and process your Personal Data (as defined below). We also describe your choices and rights with respect to how we process that Personal Data. Please read this policy carefully.

WHO WE ARE

This is the Privacy Policy (“Policy”) of Flashback Technologies, Inc. (“Flashback”, “us”, “our”, or“we”), a Delaware Corporation with offices at PO Box 270157, Louisville, CO 80027, United States. You can contact us here.

APPLICABILITY

This Privacy Policy applies to our website located at www.flashbacktechnologies.com, including any subdomains, mobile versions, and any other sites that link to or post this Privacy Policy (collectively, the “Site”).

AGREEMENT

This Policy is incorporated into the Terms of Usegoverning your use of our Site. Any capitalized terms not defined in this Privacy Policy will have the definitions provided in the Terms of Use.

Your continued use of our Site indicates your acknowledgement of the practices described in this Policy.

THIRD PARTIES

This Policy does not apply to the practices of third parties, for example, when we, or you, provide your information to a third party. Please review any third-party privacy policies before disclosing your Personal Data to them. 

COLLECTION AND USE OF PERSONAL DATA

Personal Data We Collect

We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements listed in each category are only examples and may change):

Identity Data:            
Personal Data about you and your identity, such as your first name, last name,and other similar Personal Data you may provide on various forms available through the Site.

Contact Data:           
Personal Data used to contact you, e.g. email address(es), physical address(es), phone number(s), or other communications platforms’ usernames/handles, as well as a name or other salutation.

Device/Network Data:Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application or device IDs, identifiers from cookies, session history, site-referral, and other data generated through applications and browsers, including cookies and similar technologies. 

User Content:             
Information that a user provides as part of a file upload, text entry, or other unstructured or free-form data provided to us through the Site, including articles, abstracts, summaries, biographies, etc., as well as any Personal Data to the extent included in that User Content.

How We Collect Personal Data

We collect Personal Data from various sources based on the context in which the Personal Data will be processed:

Data we collect from you:     
We collect Personal Data from you directly, for example, when you complete an online form or contact us directly.

Data we receive from others:  We receive Personal Data from third parties with whom we have a relationship in connection with a certain transaction, for example, we may receive certain customer information (e.g. name, contact, and shipping information) when you purchase a product using a third party payment service provider.

Data collected automatically:We may collect certain Personal Data automatically, for example, we collect Device/Network Data automatically using cookies and similar technologies when you browse our Site.

How we Process Personal Data

Contact Us

Data:     
When you contact us using the contact us forms on our Site we process certain Personal Data such asIdentity Data, Device/Network Data, andany Personal Data contained within anyUser Content

Uses:     
We use Identity Data, Contact Data, and User Content as necessary to communicate with you about the subject matter of your request and related matters. Subject toYour Rights & Choices, we may also use Identity Data and Contact Data to in connection with Marketing Communications, if relevant to your request, such as when you request more information about our products and for internal process and service improvement, and for other lawful purposes described below.

Marketing Communications

Data:     
If you choose to enroll to receive marketing communications, or when you open or interact with our marketing communications, we may process Identity Data and Contact Datayou provide us in order to send and personalize email marketing communications, and to otherwise manage our mailing lists and marketing communications.

Uses:     
We use Identity Data and Contact Data as necessary to provide marketing communications, and consistent with our legitimate business interests, we may send you marketing and promotional communications if you sign up for those communications. Further, if you are sent a marketing communication we may collect additional information about whether users receive, open, or click on any content that marketing communications. See Your Rights & Choicesfor information about how you can limit or opt out of this processing.

Cookies and Similar Tracking Technologies

Data:     
We, and certain third parties, may process Contact Data and Device/Network Datawhen youinteract with cookies and similar technologies on our Site. We may receive this data from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may apply to these technologies and information collected. 

Uses:     
Subject to Your Rights & Choices, we use this information as follows: 

(I) for “essential” or “functional” purposes, such as to enable various features of the Site such as remembering passwords, or staying logged in during your session; and

(ii) for “analytics” & “performance” purposes, consistent with our legitimate interests in how the Site is used or performs, how users engage with and navigate through the Site, what sites users visit before visiting our Site, how often they visit our Site, and other similar information.

Note:     
Some of these technologies may be used by our third-party partners to identify you across platforms, devices, websites, and services. 

Specific Processing Purposes 

Internal Processes

Subject to Your Rights & Choices, we may process any information we collect in connection to analyze how users interact with our Site, in connection with market research, for product and service improvements, and as necessary to monitor and maintain the integrity and security of our Site and the data we process. 

Aggregated Data

We will collect and aggregate on an anonymous basis information about you, including with information about other users of the Site in order to identify trends, security anomalies, process maps, or other proprietary data (“Aggregated Data”). We may share Aggregated Data with the third parties referred to in the section below to improve the functionality and effectiveness of the Site. Aggregated Data will not contain information from which you may be personally identified.

Additional Processing 

If we process Personal Data in connection with our Site in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to Your Rights & Choices) unless otherwise stated when you provide it. 

Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the Data Sharingfor more information about how we disclose Personal Data in extraordinary circumstances.

DATA SHARING

GENERALLY

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients and associated business purposes described below.

Business Purposes:In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests or other business purposes, we may share your Personal Data with service providers or subprocessors who provide certain Site or process data on our behalf. For example, we may use cloud-based hosting providers to host our Site or disclose information as part of our own internal operations, such as security operations, internal research, etc.) When we disclose information for business purposes we may disclose IdentityDataContactDataDevice/NetworkData, and UserContent.

Corporate Events:  Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Affiliates: In order to streamline certain business operations, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies. 

Legal Disclosures:  In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person. Note,these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

YOUR RIGHTS & CHOICES

Your Rights

To the extent required under applicable law, and subject to our rights or obligation to limit or deny access or disclosure, you may have the following rights in Personal Data:

List of Data:        
You may receive a list of the specific Personal Data about you that we process.

Rectification:        
You may correct any Personal Data that we hold about you.

Erasure:             
You may request that we delete your Personal Data from our systems. 

Data Export:       
We will send you a copy of your Personal Data in a common portable format of our choice. 

California Rights:  Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. You may also request that we provide you a copy of your Personal Data, direct us to stop selling or disclosing Personal Data for certain purposes (if we have done so), and if we receive a verifiable request from you, receive information regarding: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties with whom we have disclosed your Personal Data, or sold, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.

You may exercise these rights by contacting usat the address below. We may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to verify your identity.

Note: While we may notify third parties of your request, we are able to fulfill rights requests regarding Personal Data we control or process, and we may not have access to or control over Personal Data controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information. 

Your Choices

You have the following choices regarding the Personal Data we process:

Consent:                         
If you consent to processing, you may withdraw your consent at any time, to the extent required by law. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of the service.

Direct Marketing:              
You have the choice to opt-out of or withdraw your consent to marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting usre: direct marketing. 

Cookies & Similar Tech:    
If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit the Google Ads Privacy Policy, or Google Analytics Opt-out. To learn more about how to opt out of Google’s use of cookies for advertising or retargeting, visit Google’s Ads Settings, here. Please note, at this time, our Site does not respond to your browser’s do-not-track request.

Other Processing:               
You may have the right under applicable law to object to our processing of your Personal Data for certain purposes, including without limitation, situations where we process in accordance with our legitimate interests. You may do so by contacting usre: data rights requests. Note that we may not be required to cease processing based solely on an objection.

SECURITY

We follow and implement reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure. 

INTERNATIONAL TRANSFERS

We operate and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. 

DATA RETENTION

We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.

MINORS

Our Site is neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it. 

CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Site following notice of any changes indicates acceptance of any changes.

CONTACT US

Feel free to contact us with questions or concerns: info@flashbacktechnologies.com