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privacy policy

Privacy Policy

Sessions

Sessions

2 months ago
updated
15 min read

Last updated on: 14 June 2022

 

Sessions („our Platform ”) is provided by Flow [OS], Inc,  trading as Sessions (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our Platform, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

Data Controller: If you live in the European Economic Area (“EEA”), the UK, or Switzerland, FOS Origin SRL, a Romanian-affiliated company (“Sessions Romania”) are the joint controllers of any information processed in connection with this Privacy Policy.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use, and share any information relating to you (”your personal data”) in connection with your use of our Platform. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use, and are responsible for certain personal data about you. When we do so and you are in Europe we are subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

Given the nature of our Platform, we do not expect to collect the personal data of anyone under [18] years old. If you are aware that any personal data of anyone under [18] years old has been shared with our Platform  please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful, but we recommend you to have an adult who will explain this policy to you.

This privacy policy is divided into the following sections:

  • What this policy applies to
  • Personal data we collect about you
  • How your personal data is collected
  • How and why we use your personal data
  • Marketing
  • Who we share your personal data with
  • How long your personal data will be kept
  • Transferring your personal data out of the EEA 
  • Cookies and other tracking technologies
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us
     

1. What this policy applies to

This privacy policy relates to your use of our Platform only.

Throughout our Platform, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you, such as Dropbox, Google Drive, Miro, or other cloud storage systems and applications. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

Please take into consideration that we do not gather any kind of data on your behalf when you are accessing these services and if there is the necessity to sign in on those platforms, you will do so through their APIs and we will not gather or process any kind of data. 
 

2. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our Platform. We may collect and use the following personal data about you:

  • your name, address, and contact information, including email address and telephone number, and company details (if provided)
  • information to check and verify your identity, eg. date of birth (if provided)
  • your gender, if you choose to give this to us
  • location data 
  • your billing information (if applicable)
  • bank account and payment details (if applicable)
  • details of any information, feedback, or other matters you give to us by phone, email, post, or via social media
  • your account details, such as username and login details
  • your activities on, and use of, our Platform
  • your personal or professional interests
  • your professional online presence, eg Facebook and LinkedIn profile
  • information about the services we provide to you
  • your contact history, purchase history, and saved items
  • information about how you use our Platform  and technology systems
  • your responses to surveys, competitions, and promotions
  • any other materials and information you choose to share with us, as part of creating your account and interacting with our products and services.

If you do not provide personal data we ask for where it is (eg indicated to be ‘required’ at the point of collection), it will prevent us from providing our services to you as explained in the relevant forms on which such data is collected.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
 

3. How your personal data is collected

We collect personal data from you: 

  • directly, when you enter or send us information, such as when you: eg make an account on the Platform, contact us (including via email), send us feedback, purchase products or services via our Platform, share Content  to our Platform, and complete customer surveys via our website, and 
  • indirectly, such as your browsing activity while on our Platform; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below
     

4. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data forOur reasons

Create and manage your account with us

To perform our contract with you or to take steps at your request before entering into a contract

Providing products or services to you

To perform our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us

For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect our business, interests, and rights

Customise our Platform  and its content to your particular preferences based on a record of your selected preferences or on your use of our Platform 

Depending on the circumstances:

—your consent as gathered (eg by the separate cookies tool on our Platform )—see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool. This will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

Retaining and evaluating information on your recent visits to our Platform  and how you move around different sections of our Platform  for analytics purposes to understand how people use our Platform  so that we can make it more intuitive or to check our Platform  is working as intended

Depending on the circumstances:

—your consent as gathered —see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent you may withdraw it at any time following the Platform’s instructions (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Tracking your behaviour on our Platform  and deliver you the best experience and interaction afterwards

Your consent as gathered —see ‘Cookies and other tracking technologies’ below

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or services or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Protecting the security of systems and data used to provide the services

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us understand our customer base

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Updating and enhancing customer records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents were relevant and in order to prevent or manage any kind of legal requests

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers 

For our legitimate interests, ie to promote our business to existing and former customers

See ‘Marketing’ below for further information

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

 

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
 

5. Marketing

We will use your personal data to send you updates (by email, text message, social media messages, telephone) about our products or services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at [contact@sessions.us]
  • using the ‘unsubscribe’ link in emails, or
  • updating your marketing preferences on our Platform 

We may ask you to confirm or update your marketing preferences if you ask us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it outside our company group.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
 

6. Who we share your personal data with

We routinely share personal data with:

  • within our corporate group: we may share the information we collect with a parent, subsidiary or other affiliate or our corporate group
  • third parties we use to help deliver our products or services to you
  • other third parties we use to help us run our business, eg marketing agencies or website hosts and website analytics providers
  • in connection with a sale, merger, or other business transfer
  • our banks
  • our lawyers and consultants.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

  • our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
     

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
 

7. How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we will keep any transaction details for 5 years, according to our national regulation.

Different retention periods apply for different types of personal data. 

We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. If you stop using your account we will delete or anonymize your account data after five years.

If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your other users with whom you shared such content to make full use of the Services. 

Following the end of the relevant retention period, we will delete or anonymise your personal data.
 

If you are in the EEA, please read below

8. Transferring your personal data out of the EEA

The EEA, UK, and other countries outside the EEA have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the EEA in order to support our business operations. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the EEA where:

  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequate decisions in relation to is available here
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
  • a specific exception applies under the relevant data protection law

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.]

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
 

9. Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our Platform. We use cookies and other similar technologies, eg web beacons, action tags, single-pixel gifs on our Platform. These tracking technologies help us recognize you and your device and store some information about your preferences or past actions.

For further information on cookies and similar technologies, eg web beacons, action tags, single-pixel gifs, our use of ‘cookies’ and/or relevant similar technologies, when we will request your consent before placing them and how to disable them, please see our [Cookies Policy].
 

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our Platform 

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by contacting us, using the unsubscribe link or the dedicated section in the platform.

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). 

If you would like to exercise any of those rights, please email us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (eg your full name, address, and customer or matter reference number) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates
     

10. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
 

11. How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the competent Supervisory Authority, according to the competent law. 
 

12. Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our Platform for a reasonable period or by other means, such as email.
 

13. How to contact us

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law, or to make a complaint.

Our contact details are shown below:

Our contact details

dpo@sessions.us  

 

 

 

 

 

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