Sensitive Personal Information Categories Chart

‍Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer. The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

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Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as from the forms or other information you provide to the Company.Indirectly from you, such as from your interactions with the Company's websites and mobile applications.
• From our service providers.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes
We may use and disclose the personal information we collect to advance the Company's business and commercial purposes, specifically to:We obtain the categories of personal information listed above from the following categories of sources:

• Develop, offer, and provide you with our products and services.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
• Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Notify you about changes to our products or services.Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Protect our Company, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• Make suggestions and recommendations to you and other consumers about our goods or services that may interest you or them[, including developing profiles.
• Manage your consumer relationship with us, including for:
• • online account creation, maintenance, and security;
• •  reaching you, when needed, about your account; and
• Perform data analytics and benchmarking.
• Administer and maintain the Company's systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

‍We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
• • disclose the sensitive personal information to another third party; or
• • use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to:
• • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
• • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes. For more on your right to limit these additional sensitive personal information use purposes, see Your Rights and Choices.

Additional Categories or Other Purposes

‍We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect to third parties for the business purposes described in the Personal Information Collection, use and Disclosure Purposes section and in the table below, such as to engage third parties to support our business functions. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA's other contract requirements for engaging service providers or contractors. The chart below identifies the categories of entities to whom we have disclosed our consumers' personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure's business purposes.

Business Purposes Disclosure Recipient Category, Personal Information Category, and Purposes Chart

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Selling or Sharing Personal Information
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We do not sell your personal information to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Our personal information sales and sharing does not include information about consumers we know are under age 16.

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Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests
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You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice within in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of:  
• • personal information we collected about you; and
• • sources from which we collected your personal information.
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
• • disclosed for a business purpose to each category of persons; and
• • sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information subject to any permitted redactions.

For more on exercising this right, see Exercising the Right to Know, Delete or Correct. Right to Delete and Right to Correct You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it and notify our service providers to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers to take appropriate action. For more on exercising these rights, see Exercising the Right to Know, Delete or Correct.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sharing Opt-Out and Opt-In Rights  

You have the right to request that businesses stop sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in")

We cannot share your personal information after we receive your request to opt-out unless you later consent to the sharing of your personal information. For more on exercising your opt-out rights, see Exercising the Right to Limit or Opt-Out.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete or Correct

To exercise the right to know, data portability, delete or correct described above, please submit a verifiable request to us by emailing us at [email protected] describe your request with sufficient detail so we can properly understand, evaluate, and respond to it.  You or your authorized agent may only submit a request to know, including for data portability, twice within a 12-month period.

Exercising the Right to Limit or Opt-Out

‍You can submit your request to limit or opt-out through by emailing us at [email protected].

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information.  To designate an authorized agent, please e-mail us at [email protected]. We cannot respond to your request to know, delete or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer's name, email address, or account username.

Responding to Your Requests to Know, Delete or Correct

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please e-mail us at [email protected] endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date. We will consider requests to provide a longer disclosure period that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Response and Timing on Rights to Limit or Opt-Out4

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use personal information provided from your request to comply with the request.We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.Once you make a request to limit or opt-out, we will wait at least 12 months before asking you to reauthorize personal information sharing. However, you may change your mind and opt back in at any time by e-mailing us at [email protected].

Data Security

We have implemented reasonable measures designed to secure your personal information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our websites, mobile apps, or any other company systems, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information through the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our websites, mobile apps, or other company systems. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our systems.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website at www.flow.digital.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use:

• Website: www.flow.digital
• Email: [email protected]
• Postal Address: Flow Digital Inc.300 Kent Avenue #9Brooklyn, NY 11249
• If you need to access this Privacy Policy in an alternative format due to a disability, please e-mail us at [email protected].

Flow Digital Inc.’sNotice at Collection

Flow Digital Inc. collects the following personal information (PI) categories: identifiers and commercial information.
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We collect this PI for the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.4
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

To opt-out of PI sales, visit section entitled Personal Information Sales Opt-Out and Opt-In Rights.
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To view our full Website Privacy Policy or the Privacy Policy for California Residents, visit https://flow.digital/privacy-policy
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If you have any questions about this Notice or need to access it in an alternative format due to having a disability, please contact Flow Digital Inc. at [email protected].