Privacy Policy

Last Updated: June 21, 2024

These Privacy Policies explain how information about you is collected, used, maintained, protected, and disclosed by FOL Management LLC and its affiliates on the applicable website (in Appendix I) and mobile application (in Appendix II). We respect your privacy and are committed to protecting it through our compliance with these policies. Please read each carefully to understand our policies and practices regarding your information and how we will treat it.

We may change these Privacy Policies from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to the Website home page or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Website to stay informed about our information practices and the ways you can help protect your privacy.

If you have any questions about this Privacy Policy, please contact us via email at privacy@flow.life. or via phone at +1 (866) 789-3569.

You may also send us a written notice to:

FOL Management LLC
1170 Kane Concourse, Suite 300
Bay Harbor Islands, FL 33154

Individuals in the Kingdom of Saudi Arabia may alternatively contact us at privacy@flow.life or by written notice to Flow MENA Real Estate Management, 8730 Al Olaya 2779 Riyadh, Postal Code 12214.

Appendix I: Website Privacy Policy

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website https://flow.life/ (the “Website”) and explains how information about you is collected, used, maintained, protected, and disclosed by FOL Management LLC and its affiliated companies (“Flow,” “we,” “us” and/or “our”).

If you do not agree with our policies and practices described in Appendix I, your choice is not to access our Website. By accessing or using the Website, you agree to this Website Privacy Policy.

1. Scope

This Privacy Policy applies to information we collect on the Website and in email, text, and other electronic messages between you and the Website. It does not apply to information collected via our mobile application, offline, or through any other means, including on any other website operated by us or any third-party.

In this Privacy Policy, “Personal Information” means information that can be associated with a specific person and can be used to identify that person. Personal Information does not include information that has been aggregated and/or anonymized so that it does not identify a specific person.

This Privacy Policy does not apply to:

• information collected by us through our mobile application, offline or through any other website or mobile application operated by Flow, including websites you may access through this Website;
• information collected by any third party, including third-party software and lease management providers, or advertising and social media features that may be accessible from the Website;
• information collected by our third-party or
• unsolicited information you provide to Flow through the Website or through any other means or any information you voluntarily provide to be published or displayed on public areas of the Website, such as forums. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and Flow shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution

Our websites and other services, and these other third parties, may have their own privacy policies, which we encourage you to read before providing information on or through them.

We will not share your personal information with any third-party companies for the purpose of marketing or promotional activities. For the avoidance of doubt the affiliates of FOL Management LLC are not third parties. 

Finally, certain states provide consumers with additional privacy rights. Please see our State Privacy Rights and Disclosures section for further information, including how to exercise those rights.

1.1 Children Under the Age of 18

This Website is not intended for children under 18 years of age. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features or provide any information about yourself to us. If we learn we have collected or received Personal Information from a child under 18 we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at privacy@flow.life.

2. Information We Collect About You

2.1 Personal Information

We may collect the following information from you:

• Personal Information that you provide to us voluntarily when you complete a form on the Website, which may include your name, email address, and telephone number.
• Information about you that does not identify you, such as information from your device and browser, such as Internet Protocol (IP) address, browser type and settings, device type and settings, and operating system.
• Usage data, such as the interaction of your browser and device with the Website, including crash reports, system activity, and the date, time, and referrer URL of your request.

3. Methods of Collection

We may collect Personal Information from you directly, automatically when you use the Website, and through third parties. We describe each source below.

3.1 Information We Collect Directly From You

We may collect the following types of information directly from you:

• Forms: Information that you voluntarily provide by filling in forms on the Website. This may include Personal Information that you provide when you fill out the Contact Us form, schedule a tour of one of our properties, or request additional information regarding our listings.
• Correspondence: Records and copies of your correspondence if you contact us via the Website.
• Search Queries: Your search queries on the Website.

3.2 Information Collected Automatically

When you access our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Usage Details: When you access and use the Website, we may automatically collect certain details of your access to and use of the Website, including traffic data, logs, communication data and the resources that you access and use on or through the Website.
• Device Information: We may collect information about your device and internet connection, including the device’s unique device identifier, hardware model, and operating system and version.
• Information Collected by Cookies and Other Tracking Technologies: We and our service providers may use various technologies to collect information, including through cookies and web beacons. Cookies are small data files stored in your browser or device memory that help us improve our Website and your experience, see which areas and features of our Website are popular and count visits. Web beacons are small electronic files that permit us, for example, to count users who have visited those pages and for other related statistics.

We may use the following types of cookies:

• Session Identification (“ID”) Cookies, which are random numbers generated by the Internet server when you launch a website. When you close your browser, Session ID Cookies are deleted. Unlike other cookies, session ID cookies are not stored in your browser or on your device.
• Analytical Cookies are used to analyze your activity to improve the Website. For example, we can use Analytical Cookies to look at your usage of different pages and aggregate patterns based on actions that you might perform.
• Testing and Performance Improvement Cookies are used to ensure you receive consistent experience and to improve the performance and reliability of our Website.
• Marketing Cookies may be used from third-party service providers such as Google and Facebook for marketing purposes such as targeted advertisements and other content that has been customized for you.[A2]

We do not collect Personal Information automatically, but we may tie non-personal information collected automatically to Personal Information about you that you voluntarily provide to us.

3.3 Third Party Use of Cookies and Other Tracking Technologies

We may allow third parties to provide analytics services and serve advertisements on our behalf across the Internet and on our Website. When you use the Website, these third parties may use automatic information collection technologies to collect information about you or your device and your use of the Website, including pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Flow and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Website and other websites and better understand your online activity.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt-out of receiving targeted advertising from many providers, see “Your Choices” in Section 8 below.

4. Use of Information

We may use information about you, including any Personal Information, for various purposes, including to:

• Provide you with the Website and its contents, and any other information, products, or services that you request from us;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Flow and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with our Website;
• Detect, investigate, and prevent fraudulent and/or illegal activities and protect the rights and property of Flow and others;
• Personalize and improve the Website and provide advertisements, content or features; and
• Carry out any other purpose for which the information was collected.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf;
• To fulfill the purpose for which you provide it;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Flow or others;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Flow's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Flow about our users is among the assets transferred;
• Between and among Flow and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
• With your consent or at your direction.

Flow may also share aggregated, non-personally identifiable information with third parties for auditing, analytics, maintenance, security, or other related business purposes as determined appropriate by Flow.

Other than as stated in this Policy, Flow does not disclose or sell any of your Personal Information to third parties without your consent. Notwithstanding anything in this Policy to the contrary, Flow reserves the right to collect, use, retain or sell de-identified or aggregated non-personally identifiable information and data obtained from use of the Website.

6. Aggregated Personal Information

In an ongoing effort to better understand and serve you, Flow conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Flow may share this aggregate data with its affiliates, agents, business partners. This aggregate information does not identify you personally. Flow may also disclose aggregated customer statistics to describe our Website or services to current and prospective business partners, and to other third parties for other lawful purposes.

7. Security

The security of your Personal Information is important to us, and we implement and maintain reasonable, commercially acceptable security procedures and practices such as encryption and access controls, to protect it from unauthorized access, use, modification, or disclosure. However, please be aware that no method of transmission over the Internet, or method of electronic storage is completely secure, and we are unable to guarantee the absolute security of information we collect from you.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our Website. 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 the Website.

8. Your Choices

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

8.1 Tracking Technologies and Advertising

If you want to control which cookies you accept, you can configure the settings in your browser or on your device to accept cookies or to alert you every time a cookie is offered. Most browsers automatically accept cookies. You can configure your cookie settings and remove cookies by following directions provided in your browser “help” page. If you reject cookies, you may still use our Website, but you may find that some parts of the Website may not function properly and your ability to use some parts of our services will be limited.

8.2 Promotional Communications

If you voluntarily sign-up to receive email communications from us, you may later opt-out of receiving such communications by following the instructions in those emails to unsubscribe.

8.3 Third Parties

We do not control third parties' collection or use of your non-personal information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

We do not share your Personal Information with third-parties for promotional purposes.

9. US State Privacy Rights and Disclosures

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information.

9.1 Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their Personal Information.
• Access and delete certain Personal Information.
• Correct inaccuracies in their Personal Information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of Personal Information processing for:
• • targeted advertising (excluding Iowa);
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process Sensitive Personal Information. Sensitive Personal Information is Personal Information that is of a sensitive nature, such as your racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sexual orientation, citizenship or citizenship status, and genetic or biometric data that may be processed to uniquely identify you. However, please know that we do not currently collect Sensitive Personal Information via the Website.
• The exact scope of these rights may vary by state. To exercise any of these rights, or to appeal a decision regarding a consumer rights request, please email us at privacy@flow.life.
• Nevada provides its residents with a limited right to opt-out of certain Personal Information sales. Residents who wish to exercise this sale opt-out right may submit a request to by emailing us at privacy@flow.life. However, please know we do not currently sell data triggering that statute's opt-out requirements.

9.2 State Privacy Disclosure

We may collect (and may have collected during the 12-month period prior to the effective date of this policy) the following categories of Personal Information about you:

9.2.1 Personal Information

9.2.2 Sensitive Personal Information

We do not collect and have not collected (during the 12-month period prior to the effective date of this policy) any Sensitive Personal Information via the Website.

We do not control the collection, use, disclosure, or retention of Sensitive Personal Information by third party websites that are accessible from our Website. This includes information provided by you in connection with a lease application. For information regarding their data privacy practices, please refer to their privacy policy before providing any information.

9.3 Data Retention

We retain your information, including your Personal Information, as long as necessary to fulfill the business purpose for which it was collected, protect our interests, maintain the integrity of our services and operations, and comply with any legal requirements.

10. Kingdom of Saudi Arabia Privacy Rights and Disclosures

The below additional provisions apply if you are located in the Kingdom of Saudi Arabia.

For Personal Data which we collect directly from you, it is optional whether to provide this, however if you do not provide the data, we may not be able to provide the relevant services to you.

10.1 Legal Basis

We may use information about you, including any Personal Data, for various purposes and in accordance with the legal basis below, including:

• Provide you with the Website and its contents, and any other information, products, or services that you request from us, for our legitimate interests to provide effective services, and to perform the contract with you;
• Respond to your comments, questions and requests and provide customer service, for our legitimate interests to provide effective services and correspond with customers;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Flow and others, and provide news and information we think will be of interest to you, for our legitimate interests to promote our services, or with your consent to send you marketing communications;
• Monitor and analyze trends, usage, and activities in connection with our Website, for our legitimate interests to develop and improve our Website;
• Detect, investigate, and prevent fraudulent and/or illegal activities and protect the rights and property of Flow and others, for our legitimate interests to ensure the security of our Website and in accordance with our legal obligations;
• Personalize and improve the Website and provide advertisements, content or features, for our legitimate interests to promote our services, or with your consent to send you marketing communications; and
• Carry out any other purpose for which the information was collected.

10.2 Your Rights

You may have certain rights in relation to your Personal Data, including:

• Access. You have the right to access and receive a copy of the Personal Data we hold about you, how we use it, and who we share it with.
• Correction. You have the right to correct Personal Data we hold that is inaccurate. This includes completing and updating your Personal Data.
• Erasure. In certain circumstance, you have the right to delete the Personal Data we hold about you.
• Restriction of processing to storage only. You have the right to require us to stop processing the Personal Data we hold about you, other than for storage purposes, in certain circumstances.
• Objection. You have the right to object to our processing of your Personal Data.
• Objection to marketing. You can object to marketing at any time by opting-out using the unsubscribe/opt-out function displayed in our communications to you.
• Withdrawal of consent. Where we rely on consent to process your information, you have the right to withdraw this consent at any time by emailing us at privacy@flow.life.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, if fulfilling your request would adversely affect other individuals or if we are required by law to retain your Personal Data.

To exercise any of these rights, you can contact privacy@flow.life. We will respond to requests to exercise these rights in accordance with the timelines set out in the applicable laws.

If you think we have infringed data protection laws, you may also have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction.

10.3 International Data Transfers

We store and process your Personal Data in various jurisdictions, including the United States. Your Personal Data may be shared with and processed by us and our affiliates and third-party suppliers and vendors outside of the country in which your Personal Data was collected.

The laws on processing such information in these locations may be less stringent than in your country. Your Personal Data may also be processed by staff operating outside of your country who work for us or one of our third party service providers or partners. We will take all steps reasonably necessary and/or required by applicable data protection laws to ensure that your information is treated securely and in accordance with this notice and applicable law, such as transferring Personal Data to jurisdictions considered “adequate” for data protection purposes, or putting in place standard contractual clauses for data transfers.

10.3 Data Retention

We retain your information, including your Personal Data, as long as necessary to fulfill the business purpose for which it was collected, protect our interests, maintain the integrity of our services and operations, and comply with any legal requirements.

Appendix II: Mobile App Privacy Policy

This Privacy Policy explains how information about you is collected, used, maintained, protected, and disclosed by FOL Management LLC and NIP Finco LLC and its affiliated companies (“Flow,” “we,” “us” and/or “our”) in connection with Flow’s mobile application.

If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to this Privacy Policy.

1. Scope

This Privacy Policy applies to information we collect when you download, install, register with, access, or use the Flow mobile application (the “App”), when you access or use the services provided through the App (the “Services”), or when you otherwise interact with us in connection with this App or the Services, including via email, text and other electronic means.

In this Privacy Policy, “Personal Information” means information that can be associated with a specific person and can be used to identify that person. Personal Information does not include information that has been aggregated and/or anonymized so that it does not identify a specific person.

This Privacy Policy does not apply to:

• information collected by us offline or through any other website or mobile application operated by Flow, including websites you may access through this App;
• information covered by your lease or obtained during the leasing process for an apartment;
• information collected by any third party, including any third-party payment gateway that may be linked to and process payments in connection with the Services or advertising and social media features that may be accessible from the App; or
• unsolicited information you provide to Flow through the App or Services or through any other means or any information you voluntarily provide to be published or displayed on public areas of the App, such as forums. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and Flow shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution

Our websites and other services, and these other third parties, may have their own privacy policies, which we encourage you to read before providing information on or through them.

Finally, certain states provide consumers with additional privacy rights. Please see our State Privacy Rights and Disclosures section for further information, including how to exercise those rights.

1.1 Children Under the Age of 18

This App is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this App or through any of their features, register for the Services, make any purchases or transact through the App, use any of the interactive features of this App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 18 we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at privacy@flow.life.

2. Information We Collect About You

2.1 Personal Information

We may collect the following Personal Information from you:

• Identifiers, such as name, address, email, phone number, date of birth, employment, online identifiers, information collected from cookies or other tracking technology, and other similar identifiers.
• Demographic information, such as age, gender, and education.
• Financial information, such as bank account number, credit or debit card number, and other financial information.
• Commercial information, such as purchase history and engagement with the App or Services, door access records, information about guests and residential service providers, maintenance requests with any attachments, and incident case details.
• Information from third parties, such as personal information stored with third parties that you choose to provide to us (e.g., Facebook, Instagram, LinkedIn). By linking your third-party accounts, you authorize Flow to have access to this information and you agree that Flow may collect and use this information in accordance with the Policy.
• Information from your device and browser, such as Internet Protocol (IP) address, app information, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number.
• Information about the location of your device each time you use or access our App or otherwise consent to the collection of this information. For more details, please see “Declining to Share Your Information” below.
• Usage data, such as the interaction of your apps, browsers, and devices with the App or Services, including crash reports, system activity, and the date, time, and referrer URL of your request.
• Access control data, including records of door entries on Flow properties.
• Information you provide to us, including when responding to surveys or interacting with our customer support personnel and other Flow team members.
• Inferences, including information about your interests and preferences.

Methods of Collection

We may collect Personal Information from you directly, automatically when you use the App, and through third parties. We describe each source below.

3.1 Information We Collect Directly From You

We may collect the following types of information directly from you:

• Forms: Information that you provide by filling in forms on the App. This includes information provided at the time of registering to use the Services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App or the Services.
• Correspondence: Records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
• Surveys: Your responses to surveys that we might ask you to complete for research purposes.
• Transaction Details: Details of transactions you carry out through our App and of the fulfillment of your orders.
• User Contributions: You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the App or transmitted to other users of the Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

3.2 Information Collected Automatically

When you access or use our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Usage Details: IWhen you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, communication data and the resources that you access and use on or through the App.
• Device Information: We may collect information about your mobile device and internet connection, including the device’s unique device identifier, hardware model, operating system and version, mobile network information, and the device’s telephone number.
• Stored Information and Files: The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information: We may collect information about the location of your device each time you use or access the App or otherwise consent to the collection of this information. For more details, please see “Your Choices” in Section 8 below.
• Information Collected by Cookies and Other Tracking Technologies: We and our service providers may use various technologies to collect information, including through cookies and web beacons. Cookies are small data files stored in your browser or device memory that help us improve our Website and your experience, see which areas and features of our Website are popular and count visits. Web beacons are small electronic files that permit us, for example, to count users who have visited those pages and for other related statistics.

We may use the following types of cookies:

• Session Identification (“ID”) Cookies, which are random numbers generated by the Internet server when you launch a website or mobile application. When you close your browser or mobile application, Session ID Cookies are deleted. Unlike other cookies, session ID cookies are not stored in your browser or on your device.
• Functionality Cookies are used to provide certain Services or to remember choices you make so we can personalize our App or Services for you, for example, by remembering your username, choice of language, and schedule preferences.
• Analytical Cookies are used to analyze your activity to improve the App or Services. For example, we can use Analytical Cookies to look at your usage of different Services and aggregate patterns based on actions that you might perform.
• Testing and Performance Improvement Cookies are used to ensure you receive consistent experience and to improve the performance and reliability of our App or Services.
• Marketing Cookies may be used from third-party service providers such as Google and Facebook for marketing purposes such as targeted advertisements and other content that has been customized for you.

We do not collect Personal Information automatically, but we may tie non-personal information collected automatically to Personal Information about you that you voluntarily provide to us.

3.3 Information Collected From Third Parties

We may also obtain information from other sources and combine that with information we collect through our App. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, lease management providers and publicly available sources.

3.4 Third Party Use of Cookies and Other Tracking Technologies

We may allow third parties to provide analytics services and serve advertisements on our behalf across the Internet and in our App. When you use the App or its content, these third parties may use automatic information collection technologies to collect information about you or your device and your use of the Services, including pages viewed, time spent on pages, links clicked and conversion information. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. This information may be used by Flow and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt-out of receiving targeted advertising from many providers, see “Your Choices” in Section 8 below.

4. Use of Information

We may use information about you, including any Personal Information, for various purposes, including to:

• Provide you with the App and its contents, and any other information, products, or services that you request from us;
• Process payments and collect fees;
• Send you technical notices, App updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Flow and others, and provide news and information we think will be of interest to you;
• Include you in a member directory made available to residents of your building;
• Monitor and analyze trends, usage, and activities in connection with our App;
• Detect, investigate, and prevent fraudulent and/or illegal activities and protect the rights and property of Flow and others;
• Personalize and improve the App and provide advertisements, content or features that match user profiles or interests;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected.

We may also use your information to contact you via email about our own and third parties’ goods and services that may be of interest to you. If you do not want to receive marketing emails, you may opt-out via your account settings page. For more information, see “Your Choices” in Section 8 below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and other service providers, including payment processors and financial service providers, who need access to such information to carry out work on our behalf;
• To fulfill the purpose for which you provide it;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Flow or others;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Flow's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Flow about our users is among the assets transferred;
• Between and among Flow and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
• With your consent or at your direction.

Flow may also share aggregated, non-personally identifiable information with third parties for auditing, analytics, maintenance, security, or other related business purposes as determined appropriate by Flow.

Other than as stated in this Policy, Flow does not disclose or sell any of your Personal Information to third parties without your consent. Notwithstanding anything in this Policy to the contrary, Flow reserves the right to collect, use, retain or sell de-identified or aggregated non-personally identifiable information and data obtained from use of the App or Services.

6. Aggregated Personal Information

In an ongoing effort to better understand and serve you, Flow conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Flow may share this aggregate data with its affiliates, agents, business partners. This aggregate information does not identify you personally. Flow may also disclose aggregated customer statistics to describe our App or Services to current and prospective business partners, and to other third parties for other lawful purposes.

7. Security

The security of your personal information is important to us, and we implement and maintain reasonable, commercially acceptable security procedures and practices to protect it from unauthorized access, use, modification, or disclosure. However, please be aware that no method of transmission over the Internet, or method of electronic storage is completely secure, and we are unable to guarantee the absolute security of information we collect from you.

The safety and security of your information also depends on you. Where access to certain parts of our App requires a user password, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our App. 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 the App.

8. Your Choices

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

8.1 Account Information

You may update, correct, or delete your information and preferences at any time by accessing your account settings page. Your account is protected by a password. We encourage you to choose your password carefully and keep it secure. If you have trouble accessing your account or your information, or if you wish to delete or deactivate your account, you can contact Flow by emailing our customer support team at privacy@flow.life.

Please note that while any changes you make will be reflected within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

8.2 Tracking Technologies and Advertising

If you want to control which cookies you accept, you can configure the settings in your browser or on your device to accept cookies or to alert you every time a cookie is offered. Most browsers automatically accept cookies. You can configure your cookie settings and remove cookies by following directions provided in your browser or device “help” page. If you reject cookies, you may still use our App and Services, but you may find that some parts of the App may not function properly and your ability to use some parts of our Services will be limited.

8.3 Location Information

You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.

8.4 Promotional Communications

You may opt-out of receiving emails from Flow to promote our own or third parties’ products or services by following the instructions in those emails or by opting-out via your account settings page. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

8.5 Mobile Push Notifications/Alerts

We may send you SMS messages in the case of a login or password reset. We do not send promotional or marketing SMS messages, push notifications or alerts to your mobile device.

8.6 Third Parties

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

9. State Privacy Rights and Disclosures

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

9.1 California Residents

The Flow App is not currently intended for residents of California.

9.2 Nevada Residents

The Flow App is not currently intended for residents of Nevada.