Effective: 12 May 2018
1. This policy sets out how we handle personal information. It covers all Site operated as part of Flex4Me.
2. When we say ‘we’, ‘us’ or ‘Flex4Me’ it’s because that’s who we are and we own and run the Site.
The type of personal information we collect
4. We collect certain personal information about visitors and users of our Site.
5. The most common types of information we collect include things like: usernames, member names, email addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as payment agent details, transactional details, tax information, support queries, forum comments, reviews, ratings, content you direct us to make available on our Site (such as item descriptions) and web analytics data.
How we collect personal information
6. We collect personal information directly when you provide it to us, automatically as you navigate through the Site, or through other people when you use services associated with the Site.
7. We collect your personal information when you provide it to us when you complete membership registration and buy or provide items on our Site, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, write a review, post a comment or send us a communication.
Personal information we collect about you from others
8. Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
a. financial and/or transaction details from payment providers located in the UK, US and Europe in order to process a transaction;
b. third party service providers (like Google, Facebook) who are located in the UK, US or Europe, which may provide information about you when you link or connect your account with the third party provider. The information varies and is controlled by that service provider or as authorised by you via your privacy settings at that service provider; and
c. other third party sources and/or partners from UK, US or Europe, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service. We also receive information about you and your activities on and off Flex4Me platform through partnerships, or about your experiences and interactions from our partner ad networks. We also receive information about you as a rights holder from our third party authors.
How we use personal information
9. We will use your personal information:
a. To fulfil a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on our Site, like when you purchase an item.
b. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
i. operating the Site;
ii. providing you with services described on the Site;
iii. verifying your identity when you sign in to our Site;
iv. responding to support tickets, and helping facilitate the resolution of any disputes;
v. updating you with operational news and information about our Site and services e.g. to notify you about changes to our Site, website disruptions or security updates;
vi. carrying out technical analysis to determine how to improve the Site and services we provide;
vii. monitoring activity on the Site, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Site;
viii. managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Site or asking for your feedback or whether you want to participate in a survey;
ix. managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
x. improving our products and services.
xi. providing general administrative and performance functions and activities; and
c. Where you give us consent:
i. providing you with marketing information about products and services which we feel may interest you; and
d. For purposes which are required by law.
e. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
10. We will disclose personal information to the following recipients:
a. Performers that you buy an item from or send a payment to, who may be located in any of the countries our products are available in;
b. subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers; marketing and analytics services; security and fraud prevention services; subscription management services and payment processing services, any of which are located in the UK, USA or Europe. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
c. our professional advisers (lawyers, accountants, financial advisers etc.) which are located in Europe;
d. regulators and government authorities in connection with our compliance procedures and obligations;
e. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
f. a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
g. a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
h. a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
i. other recipients where we are authorised or required by law to do so.
Where we transfer and/or store your personal information
11. We are based in Romania. Your data will be processed in Romania, the US and Europe. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based in other countries. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
12. We store personal information on secure servers that are managed by us and our service providers.
How you can access your personal information
13. You have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data.To make an access or correction request, please email email@example.com.
Marketing Choices regarding your personal information
14. Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
15. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Site may not work properly in your case.
Cookies and web analytics
17. When you visit our Site, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account, some of this information could be associated with your account. We’re talking about the following kinds of details:
a. your IP address or proxy server IP address’;
b. the domain name you requested;
c. the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
d. the date and time of your visit to the website;
e. the length of your session;
f. the pages which you have accessed;
g. the number of times you access our site within any month;
h. the file URL you look at and information relating to it;
i. the website which referred you to our Site; and
j. the operating system which your computer uses.
18. Occasionally, we will use third party advertising companies to serve ads based on prior visits to our Site. For example, if you visit our Site, you may later see an ad for our products and services when you visit a different Site.
Information about children
19. Our Site are not suitable for any one under the age of 18. We do not actively collect information about anyone under the 18. If you are under 18, please do not use our Site or give us your personal information.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
22. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. It is your responsibility to check this page for updates.
How you can access your personal information
23. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
24. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
25. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
26. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
How you can contact us
27. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact firstname.lastname@example.org.