Our privacy policy
We respect your privacy. The information we collect from you via our marketing activities is never marketed, rented or sold to any outside parties. We focus on managing data in accordance with leading international regulations to protect your privacy, time and data. We follow best practice regulations to support our clients and markets.
These include, adherence to data protection legislation such as the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Personal Information Protection and Electronic Documents Act (PIPEDA), Data Protection Act (DPA), Protection of Personal Infromation Act (POPIA), Act on the Protection of Personal Information (APPI), and other leading global data protection legislation.
The Floow also follow communication regulations such as: ePrivacy Directive (ePD), Controlling the Assault of Non-Solicited Pornography And Marketing Act (CAN-SPAM), Privacy and Electronic Communications Regulations (PECR), Canadian Anti-Spam Legislation (CASL), Electronic Communications and Transactions Act (ECTA), Telecommunications and Broadcasting Act (TBA), and other leading communication legislation.
If you opt-in to receive marketing information from us, we will request an email address to ensure that the people using our contact forms are bona fide. It also allows us to send you information by email. Your postal address is required in order to send you pricing information if you request it.
If you wish to receive a copy of audit certificates for, ISO 27001 or ISO 9001 please contact our data controller.
If you have questions, please contact us via: data.controller@thefloow.com.
Privacy Policy (FloowDrive App)
This Privacy Notice explains how we (The Floow Limited) collect your personal data i.e. any information which identifies you, or which can be identified as relating to you personally.
It is important that you are aware that journey data will be collected and transmitted any time the FloowDrive App is enabled.
We will process your data in accordance with this privacy notice on the basis of performance of a contract with you and for our legitimate business interests.
This app is not designed for use by children and no data is intended to be gathered from children.
Who is responsible for processing your data?
This section explains how The Floow (we, our us) processes your personal data. Please read this document to better understand our policies, practices and views around personal data. By downloading our apps or Floow powered apps (App) via either Apple’s App Store or the Google Play Store, you are accepting and consenting to the practices described in this section.
Postal address:
The Floow Limited
The Floow Campus
Wicker Lane
Sheffield S3 8HQ, England
Email address: data.controller@thefloow.com
If you have any questions about this information, you may contact us by post at the above address, or by e-mail at data.controller@thefloow.com.
EU Representative
The Floow have appointed IT Governance Europe Limited to act as our EU Representative for all our EU client and customers. If you wish to exercise your rights under the EU General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please contact our EU Representative via:
Email address: eurep@itgovernance.eu
Postal address:
EU Representative, IT Governance Europe,
The Mill Enterprise Hub,
Stagreenan, Drogheda,
Co. Louth, A92 CD3D, Ireland
When contacting our EU Representative please ensure you include our company name, The Floow, in any correspondence.
What data and sources do we use?
Information you give us:
When you download, activate and use the FloowDrive App (or contact us in respect of the App), we may collect any or all of the following information about you:
Personal details (name, email, country, company)
When you complete a form on our website we may collect any or all of the following information about you:
Personal details (name, email, phone number, country, company) or the other information as specified on the form itself.
As part of the completion of this form, we will use your contact information in order to make contact with you. If this is applicable to the form that you complete then you will be expressly notified of this on the form itself. Where applicable, once the form has been completed we will send out an automated email to you with the link to the content which you have requested to view and this will be followed up with contact via the contact information provided.
As part of our advertising profile on the social media site LinkedIn we will be engaging with this platform to link to a web form hosted on our website. As part of the linking service between LinkedIn and The Floow, we will track user activity and engagement on the form by use of JavaScript code and the cookies mentioned in our Cookie Policy. This will be used for functionality, performance and analytics and advertisement.
Data we collect automatically:
When you install and run the FloowDrive 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 log-in information, browser type and version, regional settings, operating system and platform);
data about your use of the FloowDrive App (e.g. frequency, duration) ;
specific location information and direction (we use GPS technology to determine your current location);
data about your driving behaviour (current speed, duration of journey, acceleration, braking and cornering);
data on mobile phone usage while driving (i.e. information about when you make and receive phone calls and send and receive text messages on your device). We do not have access to the content of phone calls, text messages or any other app on this phone.
The FloowDrive App only starts recording information when you are travelling at a minimum speed and will stop recording when your journey ends. Further, please note the following:
We do not record you 24/7
Location access is only used to for the core functionality of the FloowDrive App, captured journeys are processed to generate driver and journey scores
Location data is not used for any type of advertising purposes
The FloowDrive App will collect data for all kinds of journeys, independent of the mode of transportation. The FloowDrive App may collect journeys when you are not using a car such as train, bike, plane, boat or whilst walking. As stated previously, the App starts recording all journeys automatically based on minimum speed detection. This recording stops once the journey ends.
All of your journey data will be collected and retained by the FloowDrive App, whether you are a driver or passenger. Passenger journeys, however, can be excluded from your diving scores by tagging your journey.
The data that is automatically collected will be sent to our servers and we will use the information to provide you feedback on your driving style. This information will be used to build up a profile of how, where, and when your car is driven and the level of your mobile phone distraction during those journey times. This information will be combined to form a driving score based on your driving behaviour.
All data is processed for the purposes of performing our contract with you and for the purposes of our legitimate business interests in providing journey information to our client’s to further our commercial enterprise.
It is not the intention of the app to collate the purpose of your journey. For instance, travel to a specific place for a specific reason is not part of our data collection over and above the fact that a journey started at one street address and ends at another. For this reason we do not believe that we will process sensitive data or other data for which we will need your consent.
How long we keep your personal information for?
We will collect, process and retain your personal and journey data to the minimum required to meet the needs for providing, maintaining and improving our services as well as meeting relevant regulation. Data retention periods may vary across both data types and across differing platforms. To understand more about data retention for personal data please contact us via: data.controller@thefloow.com.
Rights of access, correction, erasure, and restriction
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data protection office by email.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Our Approach to Data Protection
The Floow has a focused and holistic approach to data protection. We have a dedicated DPO (Data Protection Officer) whose responsibility it is to work across all aspects of the business to ensure a rigorous approach to data protection is maintained.
We believe that there are many benefits to International Data Protection Regulation and The Floow work carefully to ensure strong compliance to international law and good practice. The Floow fully support data protection legislation applicable to our clients and the data we hold. These include, the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Personal Information Protection and Electronic Documents Act (PIPEDA), Data Protection Act (DPA), Protection of Personal Infromation Act (POPIA), Act on the Protection of Personal Information (APPI), and other leading global legislation.
The Floow is currently ISO/IEC 27001(E) and ISO 9001 certified. ISO certification defines requirements for the establishment, implementation, maintenance, and continual improvement of an Information Security Management System (ISMS), through robust internal and external auditing.
Assessed and certified for ISO 27001
Assessed and certified for ISO 9001