Privacy Policy
Last updated: Apr 8, 2024 4:17 PM
We value your privacy very highly. Please read this Privacy Policy carefully before using the Subflow Application (the “Application“) operated by Subflow Inc., a Corporation formed in Delaware, United States (“us,“ “we,“ “our“) as this Privacy Policy contains important information regarding your privacy and how we may use the information we collect about you.Your access to and use of the Application is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including, but not limited to: visitors, users, and others, who wish to access or use the Application.By accessing or using the Application, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Application.
1. What information we collect, where we get this information, how we use this information, what happens if we don't have it, and the legal basis for processing this information
We collect any and all information that you enter on this Application. We collect the following information about you:
| Category of information | Specific piece of information | Legal basis for processing this information | Where we get this information | How we use this information | What happens if we don't have this information |
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| Identifying information | Name |
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| Identifying information | Postal / Shipping address |
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| Identifying information | Billing address |
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| Identifying information | Phone number |
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| Identifying information | Email address |
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| Identifying information | Device identifier |
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| Financial information | Credit card or debit card number |
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| Financial information | Card expiration date |
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| Financial information | Card CVV (security code) |
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| Commercial information | Products or services purchased, obtained or considered |
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| Internet or other electronic activity | Information regarding your interaction with our website or application |
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| Sensitive personal information | Geolocation information |
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Note that we do not use your personal information for the purposes of targeted advertising, nor for profiling. Please see the “Your Rights“ section below for more information about exercising your privacy rights related to profiling and targeted advertising.
2. With whom we share your personal information
We share the personal information below with the following third parties for the following reason(s):
| Category of personal information shared | Specific piece of personal information shared | Categories of third parties with whom personal information is/was shared | Reason(s) for sharing |
|---|---|---|---|
| Identifying information | Postal / Shipping address |
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| Identifying information | Billing address |
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| Identifying information | Phone number |
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| Identifying information | Email address |
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| Identifying information | Device identifier |
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| Financial information | Credit card or debit card number |
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| Financial information | Card expiration date |
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| Financial information | Card CVV (security code) |
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| Internet or other electronic activity | Information regarding your interaction with our website or application |
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3. How we protect your information
We have implemented the following measures to protect and safeguard your personal information:
- Limiting the amount of personal information that we collect to strictly necessary only;
- Using ssl or other secure connection technologies when receiving or sending personal information beyond internal networks;
- Destroying the personal information that we no longer need;
- Training our employees.
4. Sale of your information
We do not sell your personal information. Please see the “Your Rights“ section below for more information about exercising your privacy rights regarding sales of your personal information.
5. Cookies
A cookie is a small piece of data sent from a application and stored on your device by your browser. This Application collects cookies and may use cookies for reasons including, but not limited to:
- Analyzing our Application traffic;
- Analyzing your interactions with advertisements;
- Identifying if you are signed in to the Application;
- Testing content on the Application;
- Storing information about your preferences;
- Recognizing when you return to the Application
Most web browsers automatically accept cookies. However, you can modify your browser settings to decline cookies, if you prefer. This setting may prevent you from taking full advantage of the Application.
6. Children's privacy
This Application is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond to that child to inform him or her that they cannot use this Application.
7. Analytics programs
This Application uses Google Analytics to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit this link.
8. Information retention
We retain all of the information that we collect until we no longer need the information collected for a legitimate purpose.
9. Direct marketing
We use the information that we collect about you for direct marketing purposes. Direct marketing is the act of selling products or services directly to consumers rather than through retailers. Residents of the European Union and/or the European Economic Area and the United Kingdom - You may, at any time, request that we cease to use your information for direct marketing purposes by emailing us at mitch@subflow.com.
10. Your rights
Depending upon where you reside, you may have the following rights with regard to your personal information:
| Right | Applies to |
|---|---|
| The right to opt out of use of your personal information for the purposes of targeted advertising. | Residents of Virginia, Colorado, and Connecticut only |
| The right to access the personal information that we have collected about you. | Residents of Canada, the European Union and/or the European Economic Area, the United Kingdom, Virginia, Colorado, Connecticut, and Quebec only |
| The right to say no to the sale of your personal information. | Residents of Nevada, Virginia, Colorado, and Connecticut only |
| The right to opt out of the use of your personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. | Residents of Virginia, Colorado, and Connecticut only |
| The right to request that we delete all or some of the personal information that we have collected on you. | Residents of the European Union and/or the European Economic Area, the United Kingdom, Virginia, Colorado, and Connecticut only |
| The right to equal service and price, even if you exercise your privacy rights. | Residents of Virginia, Colorado, and Connecticut only |
| The right to ask us to transmit your personal information that we have collected on you to another provider (where technically feasible). | Residents of the European Union and/or the European Economic Area and the United Kingdom only |
| The right to request that we amend any of the information that we have collected about you. | Residents of Canada, the European Union and/or the European Economic Area, the United Kingdom, Virginia, Colorado, Connecticut, and Quebec only |
| The right to withdraw your consent to the processing of your data. | Residents of Canada, the European Union and/or the European Economic Area, the United Kingdom, and Quebec only |
| The right to request that we restrict the processing of your data. | Residents of the European Union and/or the European Economic Area and the United Kingdom only |
| The right to lodge a complaint regarding our collection, sharing and processing of data with competent authorities in the proper jurisdiction. | Residents of Canada, the European Union and/or the European Economic Area, the United Kingdom, and Quebec only |
| The right to stop receiving unwanted direct marketing. | Residents of the European Union and/or the European Economic Area only |
| The right to request your personal information in a portable and, to the extent feasible, readily usable format that allows you to transmit that information to another entity. | Residents of Virginia, Colorado, and Connecticut only |
| The right to limit the use and disclosure of your sensitive personal information. | Residents of Connecticut only |
| The right to opt out of tracking of your location. | Residents of Quebec only |
11. Exercising your rights
You may exercise the rights specified above by submitting a consumer request to:
Mitch Lawson CEO mitch@subflow.com
You can opt out of us tracking your location by adjusting the settings on your browser or device.We will need to verify your identity prior to effectuating your request. To verify your identity, you will need to provide us with the following information with your request:
- Name;
- Billing address;
- Email address.
Please note that we may be unable to process your request if you do not provide us with the above information.
You may also designate an authorized agent to exercise your rights on your behalf. You may designate an agent via any of the ways used to submit requests on your behalf. We will request the agent to verify that he or she has the authority to submit requests on your behalf. We will do so by asking the agent to submit the following information:
- Valid power of attorney
- The requester's valid government-issued ID.
- Email address.
Please note that we may not be able to process your request if your designated agent and/or you do not provide us with the above information.
We will respond to most consumer requests within 30 to 45 days of receipt, depending upon where you reside. However, some requests may take longer. We will notify you in writing if we need more time to respond. We have the ability to deny your request(s) if certain exceptions in the law apply. If we do deny your request, we will provide you with the reasons for such denial.
You have the right to appeal a refusal to take action on a rights request. You may file an appeal to us at the contact information provided above. We will respond to most appeal requests within 45 days to 60 days of receipt, depending upon where you reside. However, some requests may take longer. We will notify you in writing if we need more time to respond (up to 90 days total). In our response to your appeal, we will inform you of any actions taken or not taken and the reason(s) as to why. Normally, we do not charge a fee to process or respond to consumer requests. However, we may charge a fee for a second or subsequent request within a 12-month period.
12. Accountability
The following person is accountable and responsible for our privacy practices and procedures:
Mitch Lawson CEO mitch@subflow.com
You may lodge a complaint with us by contacting the person accountable and responsible for our privacy practices and procedures at the contact information above. Residents of Quebec may lodge a complaint with the Office of the Privacy Commissioner of Quebec by filling out this form or calling 1-888-528-7741. Residents of Canada may also lodge a complaint with the Office of the Privacy Commissioner of Canada by visiting this page or calling 1-800-282-1376.
13. Location of data processing
All data processing activities undertaken by us take place in United States.
14. Data Protection Officer
Mitch Lawson is our Data Protection Officer and may be reached via email at mitch@subflow.com.
15. Do Not Track
Do Not Track is a preference you can set on your browser to inform websites that you do not want to be tracked. We do not support Do Not Track (“DNT“). You can either enable or disable Do Not Track by visiting the Preferences or Settings page of your browser.
16. Transferring Data
We plan to transfer data to the United States. This means that your information may be processed in a country outside of Canada and it may be accessible to law enforcement authorities and national security authorities of that country and jurisdiction.
17. Changes to Privacy Policy
We plan to transfer data to the United States. This means that your information may be processed in a country outside of Canada and it may be accessible to law enforcement authorities and national security authorities of that country and jurisdiction.
18. Questions
If you have any questions about this Privacy Policy, please contact us at mitch@subflow.com