Flockler ("Flockler", "we" and "us") refers to Flockler Oy, a limited liability company registered in Tampere, Finland.
When Flockler is providing Services, depending on the circumstances Flockler may process personal data either as a data controller or as a data processor.
Flockler as a data controller - Individual Users
Legal basis for the processing of Individual User Information
As a data subject the Individual User has the right to withdraw his or her consent at any time. Individual User may easily withdraw his or her consent by choosing to do so in Flockler’s service.
Storage and deletion of Individual User Information
As a basic principle, Flockler will not store Individual User Information any longer than is necessary to fulfill the purposes for which the Individual User Information was collected, unless longer storage is required by applicable laws or regulations.
Flockler’s current storage practice for Individual User Information is that such personal data will be deleted within ninety (90) days after end of subscription period. Thereafter, Flockler maintains backups for a period of sixty (60) days before permanent deletion.
Flockler as a data processor – Customer Users
Should you have a question about purposes of using Services determined by Flockler’s Customer, please contact directly the Customer entity in question.
Collection of Customer User Information
As a data controller, the Customer in question determines the means and purposes of processing Customer User Information. As Services are being used by many Customer entities, these purposes may vary as they are determined by the Customer in question. The Customer is responsible for ensuring that the collection and processing of Customer User Information is carried out in accordance with the applicable legislation and the GDPR.
Processing of Customer User Information
Flockler will not process Customer User Information for any other purposes or by other means than those instructed by the Customer in question.
Legal basis for the processing of Customer User Information
The Customer is responsible for ensuring that a legal basis under the GDPR is established prior to collecting and processing any Customer User Information on Services, such as consent or legitimate interests of the Customer as a data controller.
Storage and deletion of Customer User Information
Since the Customer as a data controller has control over determining the purposes for which Customer User Information is collected, as well as for the duration for which the Customer User Information is stored, the Customer is responsible for determining when to delete the Customer User Information.
After the end of provision under the agreement between Flockler and the Customer, Flockler commits to either delete or return all Customer User Information to the Customer, based on Customer’s choice. Flockler deletes existing copies of Customer User Information unless legislation requires storage of Customer User Information.
What we collect and how we use it
Account Information: When you create an account on the Services (an "Account"), we’ll ask you for information such as your name, password and email address ("Account Information"). We may use Account Information, alone or together with other information, to enhance and improve the Services. We use your email address to verify your Account and to communicate with you.
Email Communications: As part of the Services, you may occasionally receive email and other communications from us. Administrative communications relating to your Account (e.g., for purposes of Account recovery or password reset) are considered part of the Services and your Account, which you may not be able to opt-out from receiving. We also may send you other kinds of emails, provided always that you have given your prior consent to opt-in for receiving such emails (e.g. direct marketing material). You can opt-out of receiving such emails either from your Account Settings page or by using the "Opt-Out" link in the emails themselves. Note that we will never email you to ask for your password or other Account Information; if you receive such an email, please forward it to us.
Information about Your Accounts on Third Party Services: You can link your Account to certain Third Party Services. In order to do so, you may provide us with your username or other user ID for a Third Party Service, and you may then be required to log into that Service. After you complete this login process, we will receive a token that allows us to access your account on that service so that you can, for example, curate content published on that Service. We do not receive or store your passwords for your Third Party Service accounts.
Information Obtained from Third Party Services: In some cases, we partner with Third Party Services that may provide information about you. Such information could include, for example, your gender, if you have disclosed that information to that third party and made it available for Flockler to access. To the extent we obtain such information, we may use it to develop new Services or to improve or enhance the Services.
When you connect other services to your Flockler account, those services might share information about you with us. What gets shown to us is determined by their privacy policies.
User Content: By default, all sharing through the Services is public, and when you provide us with content it is published so that anyone can view it. Content published and shared publicly is accessible to everyone and you may lose any privacy rights you might have regarding that content. In addition, information shared publicly may be copied and shared throughout the Internet
Information About User Content: In some cases, we may collect information about content you provide to the Services. For example, when it’s included as part of your images, we may collect information describing your camera, camera settings etc. This information allows us to improve the Services and provide additional features and functionality.
Information Related to Use of the Services: We collect information about how people use the Services, including those with an Account. This type of information may be collected in our log files each time you interact with (i.e., make a request to) the Services. We use internal tools and third party applications and services (like Google Analytics) to collect and analyze this information. Some of this information may also be associated with the Internet Protocol Address ("IP Address") used to access the Services; some may be connected with your Account; and some may only be collected and used in aggregate form (as a statistical measure that wouldn’t identify you or your Account). We may use this information about how you and others interact with the Services for a number of things generally related to enhancing, improving, protecting, and developing new Services, including but not limited to: identifying trending or popular content; fighting spam, malware, identity theft and generally keeping our users safe; and for legal and safety reasons.
Information Related to Your Web Browser: We automatically receive and record information from your web browser when you interact with the Services, such as your browser type and version, what sort of device you are using, your operating system and version, your language preference, the website or service that referred you to the Services, the date and time of each request you make to the Services, your screen display information, and information from any cookies we have placed on your web browser (as described below). We also sometimes detect whether you are using certain web browser extensions and store that information in a manner associated with your Account. We use web browser-related information to enhance and improve the Services.
Location Information: In some cases we collect and store information about where you are located, such as by converting your IP Address into a rough geolocation.
Information Related to Your Mobile Device: We may collect and store information related to your mobile device. In some cases, we may receive, generate, or assign your mobile device a unique identifier for the purposes described above in "Information Related to Use of the Services." We may also ask you to provide your phone number to enable new products and improve the Services, such as by enabling multi-factor authentication for Account login. We will always ask you whether it’s OK for us to collect and store your phone number.
Information Shared with the Public Through the Services: content published through the Services and many actions you take on the Services are shared with the public. Because this kind of information can be seen by anyone and may be indexed by search engines (like Google Search) you should be careful about what you choose to disclose publicly and make sure it’s information you want to share with everyone. The content you create on Flockler is, by default, public.
Information Shared Between the Services: We may, if possible, aggregate information about your use of multiple Services and use that consolidated information to enhance and improve the Services, and to develop new Services.
Recipients of Personal Data: List of Flockler’s subcontractors processing personal data are enclosed in https://flockler.com/subcontractors as well as the appropriate transfer mechanisms.
Furthermore, in connection with providing customized services, we may transmit Customer User Information to third-party service providers based on a specific assignment by our respective Customer in question.
The security of your information
Your Account Information is protected by a password for your privacy and security. We may enable additional security features in the future, like multi-factor authentication. You need to prevent unauthorized access to your Account and information by creating a unique, secure, and protected password and limiting access to your computer and browser by signing off after you have finished accessing your Account on the Services.
We seek to protect your information (including your Account Information) to ensure that it is kept private; however, we can’t guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.
Flockler implements appropriate technical and organizational measures and procedures in such a way that ensures the protection of data subject’s rights, and always in accordance with applicable data protection law, as well as to protect personal data against accidental or unlawful destruction, loss, alteration, disclosure, access and other unlawful forms of processing. Flockler ensures that all persons processing personal data under its authority and supervision have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
In case of a data security breach leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, Flockler will inform data subjects of the breach without undue delay, including a summary description of the potential impact and a recommendation on measures to mitigate the possible adverse effects of the breach.
Flockler ensures that personal data has been pseudonymized or anonymized wherever possible. Services contain appropriate authorization mechanisms to avoid unlawful access, as well as effective encryption has been used to mitigate the risk of data security breaches. Flockler will inform when an updated version of the service is available, and if the update is security critical, Individual Users will be prevented from using the old version of the service.
Furthermore, Flockler recommends that data subjects take additional measures to protect information privacy, by keeping confidential account information and passwords.
What information you can access
If you are a registered user, you can access most information associated with your Account by logging into the Services and checking your Account Settings page. Registered and unregistered users can access and delete cookies through their web browser settings.
Rights of data subjects
As a data subject you have the right to access, rectify, cancel, and object to the processing of your personal data by directing any such requests to Flockler. Flockler allows data subjects to exercise these rights by submitting a data subject request through Services or by contacting Flockler at info(at)flockler.com
Furthermore, you have the right to lodge a complaint with a data protection supervisory authority.
Questions and concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter please contact us by email email@example.com.
Business ID 2365844-6
Rautatienkatu 21 B
Rautatienkatu 21 B