Privacy and Cookie Policy

PRIVACY POLICY

Effective Date: 25 May 2018

InFlowRadio.com and Flowdreaming, Inc. (” InFlowRadio“, “Flowdreaming, Inc.”, ” we“, ” our“, ” us“) are committed to protecting and respecting your privacy. We are an incorporated company established in the US with a registered office in California, United States.

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

www.inflowradio.com
www.flowdreaming.com
www.my.flowdreaming.com

(the ” Websites“), our mobile apps, Flowdreaming and (the ” Apps“) and your use of our training courses, audio programs, books, M.E. School, live broadcast, podcasts, blogs, and related services and content (” Flowdreaming, Inc. Content“) (collectively ” the Services“).

Individual Customers: If you are using our Services for your own personal purposes as opposed to in connection with your employment, your data controller for the purpose of the EU General Data Protection Regulation (the ” GDPR“) is Flowdreaming, Inc.

Corporate Customers: If you are using our Services in connection with your employment, your employer is your data controller for the purposes of the GDPR, and we are data processor collecting and use that data only to provide the services to your employer. Your employer may have their own privacy notices that will apply to your use of our Services. Your employer will have access to your usage information, such as courses taken and results.

Please read this Privacy Policy carefully so that you understand how we process your personal information and what your rights are in relation to your personal information. If you do not agree with this Privacy Policy in general or any part of it, you should not access our Websites or Services.

What personal information do we collect from the people that visit our blog, website or app?

We collect certain information or data about you when you use our Services:

This includes:

• when you create an account with us, or submit questions, queries or feedback via our Websites, App, email or social media, including your email address if you send an email to us, as it is in our legitimate interests to provide our Services, communicate with you and provide customer support per your request;
• your country and IP address, as it is necessary for our compliance with legal obligations to identify where our users are located in connection with US laws;
• where you have provided your consent, you email address so you can receive our newsletters;
• where you post information on our Websites chat forum, as it is in our legitimate interests to provide our Services;
• when you provide evidence of purchases of “Flowdreaming, Inc” or “InFlowRadio” subscriptions, products, or courses on third-party platforms via our Websites, as it is in our legitimate interest to provide our Services and validate your purchase per your request;
• when you inquire about our product via our Websites, App, email or social media, including your email address if you send an email to us, as it is in our legitimate interests to provide our services, communicate with you and contact you about our product as per our request;

information we automatically collect from your computer, mobile phone, or other access device on how you use the Websites, including your IP address; device information including, but not limited to, identifier, name, and type of operating system; and standard web information, such as your browser type and the pages you access on our Websites (” Technical Usage Information“).

We collect Technical Usage Information as it is in our legitimate interests to provide effective services and useful content to you, in order to:

• personalize our Websites to ensure content from the Websites is presented in the most effective manner for you and your device;
• monitor and analyze trends, usage and activity in connection with our Websites and Services to improve the Websites;
• administer the Website, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
• keep the Websites safe and secure; and

measure and understand the effectiveness of the content we serve to you and others

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

• To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To quickly process your transactions.
• To send periodic emails regarding your order or other products and services.

How do we protect visitor information?

Transmitting information over the internet is generally not completely secure, and we can’t guarantee the security of your data.

Any data you transmit is at your own risk.

Our website is periodically scanned for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through an encrypted gateway and are not stored or processed on our servers.

Do we use ‘cookies’?

We use cookies, pixel tags, web beacons and similar files or technologies to collect and store the information we automatically collect about your computer, mobile device, and use of the Websites. Cookies are files containing small amounts of information which that are downloaded to your computer or mobile device when you visit a certain webpage. Cookies are then sent back to the originating webpage on each subsequent visit, or to another webpage that recognizes that cookie. Cookies are used in order to make our Websites work, or to work more efficiently, and to improve your experience of our Websites.

In addition to cookies that are strictly necessary to operate the Websites, we use the following cookies:

• Functional cookies, which are set by us and the following third parties to enhance your experience on our Websites.
• Performance Cookies provided by the following third parties including: ClickFunnels and Google Analytics, which enable us to provide a better user experience based on how our you use our Websites.
• Targeting or Advertising Cookies which are set by us and the following third parties, including but not limited to: Google AdWords, ClickFunnels, and Infusionsoft to tell us and those third parties about your browsing habits, so you can be provided with advertising that is more relevant to you.
• Social Media Cookies which are set by the following third parties including but not limited to: Facebook, and allow you to share what you’ve been doing on the Websites on social media.

If you do not accept the use of these cookies, please disable them by changing your browser settings so that cookies from the Websites cannot be placed on your computer or mobile device. These browser settings will typically be found in the “options” or “preferences” menu of your browser; otherwise you should use the “Help” option in your browser for more details. If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:

• Network Advertising Initiative ( http://www.networkadvertising.org/)
• Digital Advertising Alliance ( http://www.aboutads.info/consumers)

Third Party Disclosure

We share your information with a number of third parties described underneath that process and store data on how you interact with the Websites. Use of those services is governed by their respective terms of use and privacy policies as detailed below.

We will not submit your data to any third parties except as described in this Privacy Policy. We use:

• cloud storage and server providers including but not limited to AWS, Nexcess, GSuite and Google to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
• service providers for analytics services to help understand your usage of our Services including but not limited to Google Analytics, Facebook, and ClickFunnels, and provide a limited amount of your information to these service providers to collect data for analytics purposes when you visit our Websites. Google Analytics and ClickFunnels analyze your use of our Services websites and/or products and tracks our relationship so that we can improve our service to you. We may also use InfusionSoft as a medium for communications, either through email, or through messages within our Services.
• service providers for authentication services to authenticate, identify and grant access to our Services; and
• service providers for payment services including Paypal, Authorizenet, InfusionSoft and merchant accounts to handle receipt of payment for products and services at our Websites.

We will pass on your personal information if we have a legal obligation to do so; if we have to enforce or apply our terms of use and other agreements; to detect, prevent or otherwise address security, fraud or technical issues; or to protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

• if you are an employee of one of our corporate customers, we will share data generated from your use of the Services with your employer;
• in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; and
• if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

What Are Your Privacy Rights?

Where you sign up for our Services as an individual, you have certain rights including to find out what information we hold about you and review, update, and correct the personal information you provide us by logging into your account.

Corporate Customers: If you are an employee of one of our corporate customers, please contact your employer to exercise your rights.

Individual Customers: You have certain rights in regard to your personal information. You have the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your information and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete and we will endeavor to do so without undue delay.

In certain circumstances, you have the right to ask us to delete the personal information we hold about you:

• where you believe that it is no longer necessary for us to hold your personal information;
• where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
• where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; or
• where you believe the personal information we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:

• where you believe the personal information we hold about you is inaccurate and while we verify accuracy;
• where we want to erase your personal information as the processing is unlawful but you want us to continue to store it;
• where we no longer need your personal information for the purposes of our processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
• where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

At any time you have the right to object to our processing of information about you in order to send you marketing, including where we build profiles for such purposes, and we will stop processing the data for that purpose.

To exercise any of these rights above, please contact support@flowdreaming.com.

Please note that these rights above are limited, for example, where fulfilling your request would adversely affect other individuals, our trade secrets or intellectual property, where there are overriding public interest reasons, or where we are required by law to retain your personal data.

International Transfers

If you are located in the EU, your personal information will be transferred to and processed by:

• Flowdreaming, Inc. personnel located in the United States under the terms of the EU Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2010/87/EU. Please contact support@flowdreaming.com, if you would like to see a copy of the model contracts; and
• our third party suppliers (as described above) located outside the EEA where such transfers will either be: (i) to a recipient certified to the US Department of Commerce’s EU-US Privacy Shield; or (ii) subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses). For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. ”“ See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website. Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.

Users will be notified of any privacy policy changes:

• On our Privacy Policy Page

Users are able to change their personal information:

• By logging in to their account

How does our site handle do not track signals?

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

To be accordance with CANSPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Monitor third party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can

• Follow the instructions at the bottom of each email.

Policy Updates

Any changes we will make to this Privacy Policy in the future will be posted on this page. Please check back frequently for any updates or changes.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@flowdreaming.com.

Flowdreaming, Inc.
PO Box 230519
Encinitas, CA 92024