Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website, social media accounts or our online communities, and tell you about your privacy rights and how the law protects you.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to data protection laws which apply across the European Union and the United Kingdom, and we are responsible as 'controller' of that personal information for the purposes of those laws.

By providing us with your data, you warrant to us that you are over 13 years of age. This website is not intended for children, and we do not knowingly collect data relating to children.

1. Who We Are

Internal Flow Ltd is the controller and responsible for your personal data.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you:

• Identity Data — first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data — billing address, delivery or postal address, email address and telephone numbers.
• Financial Data — bank account and payment card details.
• Transaction Data — details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data — internet protocol (IP) address, your log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Profile Data — your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data — information about how you use our website, products and services.
• Marketing and Communications Data — your preferences in receiving marketing from us and your communication preferences.

We also collect Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions — by filling in forms or corresponding with us by post, phone, email or otherwise when you apply for our products or services, create an account, subscribe to our service, request marketing, enter a competition or survey, or give us feedback.
• Automated technologies or interactions — as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns via cookies and similar technologies.
• Analytics providers — such as Google Analytics.
• Payment and technical service providers — such as PayPal.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly we will use it where we need to perform a contract with you, where it is necessary for our legitimate interests, where we need to comply with a legal or regulatory obligation, or where you have consented to receive marketing communications.

Purpose / Activity	Type of Data	Lawful Basis
Register you as a new customer	Identity, Contact	Performance of a contract with you
Process and deliver your order; manage payments and collect money owed	Identity, Contact, Financial, Transaction, Marketing & Communications	Performance of a contract; Legitimate interests (to recover debts)
Manage our relationship with you — notifying you of changes, asking for reviews or surveys	Identity, Contact, Profile, Marketing & Communications	Performance of a contract; Legal obligation; Legitimate interests
Enable you to partake in a competition or complete a survey	Identity, Contact, Profile, Usage, Marketing & Communications	Performance of a contract; Legitimate interests
Administer and protect our business and website	Identity, Contact, Technical	Legitimate interests (running our business, IT services, security, fraud prevention); Legal obligation
Deliver relevant website content and advertisements; measure advertising effectiveness	Identity, Contact, Profile, Usage, Marketing & Communications, Technical	Legitimate interests (to study how customers use our services and grow our business)
Use data analytics to improve our website, products/services and marketing	Technical, Usage	Legitimate interests (to define customer types, keep website relevant and develop our business)
Make suggestions and recommendations to you about goods or services that may be of interest	Identity, Contact, Technical, Usage, Profile	Legitimate interests (to develop our products/services and grow our business)

Marketing

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if you made a purchase or asked for information from us, and you have not opted out. You can opt out of receiving marketing emails from us at any time by clicking the 'unsubscribe' link in our emails.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

5. Disclosures of Your Personal Data

We may have to share your personal data with:

• External third parties such as service providers, professional advisers, HMRC and regulators.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

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

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. If you are not a customer we shall retain your data for 2 years following your last engagement with us.

In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Changes to This Privacy Policy

We may change this privacy policy from time to time. When we do, we shall inform you via our website.