Privacy policy

Our beginning

We – referred to as “We” or “Our” – are committed to protecting your personal information and your privacy.

This privacy policy is designed to explain how we collect, store, process and use the information you provide in connection with the website Flow Capital (hereinafter “the Website”).

We are committed to the following principles:

Transparency in the collection and processing of your personal information:

We ensure that you are always well informed so that you can make informed choices about how your data is used on the website or when you interact with third-party platforms. We use various methods to give you precise and timely information about the processing of your data.

If we need to provide you with specific information, we make sure it is delivered at the right time and place.

We are also available to answer questions or provide clarifications, within applicable laws. You can reach us by email: [email protected]

Processing of personal information only for the purposes stated in this policy:

We may process your information to make the website available, connect you to third-party trading platforms (“Services”), improve user experience, develop the platform, protect our rights, carry out administrative processes and meet legal requirements.

We also process information to better understand your needs and preferences.

Resources to uphold your rights:

We dedicate significant resources to ensure that you can exercise your rights as a data subject. You can request access, correction, deletion or restriction of your information, or request to have it transferred at any time. We will follow up in accordance with applicable legislation.

Protection of your personal information:

Although we cannot guarantee absolute security, we use modern security methods and measures to protect your information and will continue to improve them.

Our full privacy policy

1. Scope

This policy describes the types of data we collect, how we process them, share them with third parties, and the security measures we apply.

“Personal information” means any information that can be linked to an identified or identifiable person. “Processing” means any operation such as collection, storage, use, sharing, adjustment or deletion.

Our services are intended for a general audience and are not directed at persons under 18 years of age. We do not knowingly collect information from minors. If we discover that such information has been registered, we will delete it promptly.

2. When do we collect information?

We collect data when you use our services, visit the website or interact with our channels. Some information is provided by you, other is collected automatically through analysis of your activity or via third-party partners.

3. No obligation to provide data – but consequences

You are not required to give us information. But without certain data we may not be able to offer you all our services or give you full access to the website.

4. What types of information do we collect?

This may include activity logs, IP addresses, timestamps, language, browser type, device information and error logs. Some of this may not directly identify you and is therefore not considered personal information.

Information you give us directly: name, phone number, email address when you contact us or use the platform.

5. Purposes of processing and legal basis

Flow Capital processes information only when we have a lawful basis, for example to deliver services, improve the experience, protect your data, or fulfil legal obligations.

• You have given consent to the processing of your personal information for specific purposes. This applies when you consciously share information via the website so that we can forward it to a third-party trading platform.
• Processing is necessary to protect legitimate interests pursued by Flow Capital or a third party. For example, this may include improving our services or handling legal claims.
• Processing is necessary to comply with a legal obligation to which Flow Capital is subject.

If you want a more detailed explanation of how processing of your personal information protects legitimate interests for Flow Capital or a third party, you can contact us at any time by email.

Below is an overview of why we may process your information, together with the legal bases:

6. Transfer of personal information to third parties

Flow Capital may share your information with third-party providers that assist with storage, hosting, IP information, user experience analysis, research and other technical or diagnostic services.

If you request it yourself, we may also transfer certain information to third-party trading platforms. In such cases, they will process the information in accordance with their own privacy policies. We may share information with multiple trading platforms.

Flow Capital may also share information with affiliated companies and business partners that contribute to improving the quality of our services.

We may disclose information to public authorities if this is necessary to protect our or third parties' interests, rights or assets, including in connection with legal proceedings.

Information may also be shared with potential buyers, investors or lenders in connection with merger, acquisition, reorganization or bankruptcy proceedings.

7. Cookies and third-party services

We use certain third-party services, for example analytics and advertising providers. These may use cookies or similar technology, governed by their own policies.

A cookie is a small text file stored on your device when you visit the website. It can collect information about usage patterns, preferences and technical data, and is used to improve your experience, remember settings and deliver more relevant content.

We may use both session cookies (deleted when the browser is closed) and persistent cookies (that remain on your device until they expire or are manually deleted).

Types of cookies:

Blocking and deleting cookies

You can change your browser settings to block or delete cookies. Here are links to instructions for the most popular browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some functions on the website may stop working if you block cookies.

NOTE ON ONLINE TRACKING

This service does not currently support “Do Not Track” signals.

8. Storage of personal information

Flow Capital will store your information for as long as it is necessary for the purposes described in this policy, or as required by law, regulation or authority.

If you have given consent, we may share information with third-party trading platforms for up to 12 months, with the possibility of extension after new consent.

We regularly review stored information to ensure it is not kept longer than necessary.

9. Transfer of personal information to third countries or international organizations

Your personal information may be transferred to a third country (outside the EEA) or to international organizations. In such cases, Flow Capital will implement appropriate safeguards to ensure that the information is protected and that you retain your rights and effective remedies.

If you are resident in the EEA (the European Economic Area), such protective measures will apply if one of the following criteria is met:

• The transfer is to a third country or an international organization that the European Commission has recognized as having an adequate level of protection for personal information, cf. GDPR Article 45(3).
• The transfer is carried out on the basis of a legally binding and enforceable agreement between public authorities or bodies, cf. GDPR Article 46(2)(a).
• The transfer is based on standard data protection clauses adopted by the European Commission, cf. GDPR Article 46(2)(c). You can find these clauses on the European Commission's websites.

If you want more information about the safeguards we use when transferring personal information, you can contact us by email: [email protected]

10. Protection of personal information

We use technical and organizational security measures to protect personal information against unauthorized access, alteration, loss or destruction. These measures are adapted to the risk of the processing.

We cannot guarantee absolute security for data transmission over the internet. Flow Capital disclaims responsibility for indirect or unintended damages that may arise as a result of data loss or unauthorized access outside our reasonable control.

In some cases we may be legally obliged to share information with public authorities. Then our level of control over the protection of the information may be limited.

11. Links to third-party websites

The website may contain links to external websites or applications operated by third parties. Flow Capital has no control over these and is not responsible for their processing of personal information. We recommend that you always read through their privacy policies before providing information.

12. Your rights related to personal information

You have the right to request access to the information we process about you, demand correction of errors, request deletion of data that is no longer necessary, and restrict or withdraw consent to certain processing.

Right of access

You have the right to confirmation of whether Flow Capital processes personal information about you. If we do, you have the right to access the information as well as information about: purposes, data types, recipients (including in third countries), storage period, rights, complaint access and which security measures have been implemented for transfers.

You may receive a copy of the processed information. If you request additional copies, we may charge a reasonable fee. If the request is sent electronically, you will normally receive the data in a common electronic format.

The right of access shall not infringe the rights and freedoms of others. If this occurs, we may limit the access or refuse the request.

Right to rectification

You may request that Flow Capital correct inaccurate or incomplete information about you. If necessary, you may supplement with an explanatory statement.

Right to erasure (“right to be forgotten”)

You have the right to request deletion of your information when it is no longer necessary to process it, when you withdraw consent, or if the processing is unlawful. We will follow up in accordance with applicable legislation.

Right to erasure (“right to be forgotten”)

This right applies if: (a) the personal information is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or third parties' legitimate interests, and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the information has been processed unlawfully; or (f) the information must be deleted to comply with a legal obligation under EU or Canadian law.

The right does not apply if the processing is necessary (a) to comply with a legal obligation, or (b) to establish, exercise or defend legal claims.

Right to restriction of processing

You may request that we restrict the processing of your information if: (a) you contest the accuracy, for a period that gives us time to verify; (b) the processing is unlawful, but you want restriction instead of erasure; (c) we no longer need the information, but you need it for legal claims; (d) you have objected to the processing, pending assessment of our legitimate interests; (e) the information is processed for direct marketing, including profiling.

If processing is restricted, the information may only be used with your consent, for legal claims, to protect the rights of others or for important public interests.

Right to data portability

You have the right to receive personal information you have given us in a structured, commonly used and machine-readable format. You may also request to have the information transferred directly to another data controller if it is technically feasible, and if the processing is based on consent or contract and is carried out automatically.

Right to withdraw consent

You may withdraw consent to processing at any time, without affecting the lawfulness of the processing based on consent before it was withdrawn.

Right to object

You may object to the processing of your information when the processing is based on legitimate interests. This also applies to profiling. We will then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests and rights, or if the processing is necessary for legal claims.

You may also object at any time to the processing of information for direct marketing, including profiling related to such marketing.

Right to lodge a complaint with a supervisory authority

You may lodge a complaint with the Office of the Privacy Commissioner of Canada or another supervisory authority if you believe that the processing of your personal information violates applicable law.

We will respond to requests to exercise rights within one month of receipt. If necessary, the deadline may be extended by up to two months, depending on the complexity and number of requests. You will then be informed of the reason for the delay.

Information related to the exercise of rights is provided free of charge, unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse the request.

Flow Capital may request additional information to confirm your identity if we have reasonable grounds to doubt it.

13. Updates to this policy

We reserve the right to update this privacy policy. Changes will be published on the website, and significant updates will be notified in a clear manner. Unless otherwise stated, the changes take effect when the updated policy is published.