Privacy policy
1.1 Who Are We. We are FOLIG FROG, s. r. o., a company having its registered office at Antala Staška 1859/34, 140 00 Prague, Czech Republic, Company ID: 174 12 838, registered in the Commercial Register maintained by the Municipal Court in Prague under Insert C 371345 and duly incorporated under the laws of the Czech Republic (“Company” or “we”) which has developed a lead generation service “Flinne.io” available at https://flinne.io (“Flinne.io”).
1.2 What Does Flinne.io Do. Flinne.io allows its users (“User” or “you”) to formulate their target audience and find valid business contacts (“Prospect” or “you”) through personalized e-mail campaigns (“Campaigns”) intended to contact the Prospects. The Campaigns, along with the list of contacted Prospects, are made available to the User in the form of a report (“Report”; Campaigns and Reports altogether as “Services”).
1.3 Our Privacy Values. Your privacy is important to us. It is our policy to respect your privacy regarding any information and personal data we may collect from you or about you during our cooperation through Flinne.io, as well as other sites we own and operate or sites we use to provide our Services. We strive to collect and use only the personal data that have a connection to your business activity, and we strictly delete any personal data relating to consumers.
1.4 Personal Data Protection Regulation. As we care about the protection of your personal data, we have prepared the following information about the processing of your personal information, which complies with Regulation (EU) No. 2016/679 of the European Parliament and of the Council on the General Data Protection Regulation (“GDPR”), the United Kingdom General Data Protection Regulation (“UK GDPR”) and with the California Privacy Rights Act of 2020 (“CPRA”), respectively, based on the Prospects residence.
1.5 What You Can Find in This Document. This Privacy Policy explains how we collect, use, process, disclose, and secure information and personal data we obtain from and about the Users and/or the Prospects, including information we collect when you visit our websites, use Flinne.io or other Services, or which we obtain through our partners. It also tells you about your rights and choices with respect to your information and how you can contact us if you have any questions or concerns.
2. Who is the Controller of Your Personal Data?
2.1 Who is the Controller. The controller is generally a person who, alone or together with others, determines the purpose of collection and decides how the personal data will be processed.
2.2 Controller of User Data. We are a controller of Users´ personal data (“User Data”).
2.3 Controller of Prospect Data. The Company and the User are joint controllers (“Joint Controllers”) of Prospects´ personal data (“Prospect Data”). Both the Company – as a controller – and the Company and the User – as joint controllers – are further in this Privacy Policy referred to as “data controller”.
2.4 Personal Data. If any part of this Privacy applies to both Users and Prospects, we call the User Data and Prospect Data together just as “personal data”.
3. How do We Collect Personal Data?
3.1 Obtaining User Data. We obtain the User Data directly from the User. Mostly from filled-in forms, mutual communication, or concluded agreements in accordance with the User's use of our Services and our Terms of Use.
3.2 Obtaining Prospect Data. We obtain the Prospect Data from third parties we cooperate with, which are entitled to access and process the Prospects’ personal data related to their business activities and from publicly accessible sources or social or other online platforms that are used by businesses and individuals in relation to their business activities. We never collect any Prospect Data related to their consumer or personal status. We meticulously control if any such consumer or personal data are not included in our datasets by accident.
4. What Personal Data do We Process?
4.1 The Scope. The scope of the processed personal data is based on your relation to the Services (whether you are a User or a Prospect).
User Data
4.2 Log Data. When you visit our website or use any Service or Flinne.io, our servers may automatically log the standard data provided by your web browser. It may include your computer's Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details. These data are vital to your use of Flinne.io and our Services as they enable us to provide our Services and to monitor any security or other risks related to Flinne.io and our Services.
4.3 Device Data. We may also collect data about your device to access our website or Flinne.io. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking your device manufacturer's or software provider's policies to learn what information they make available to us.
4.4 Identification, Contact, Address, and Billing Information. We process your data, such as your name and/or business name, address, and VAT or ID number. We may also process your telephone number and/or e-mail address if they have been provided. Data regarding invoicing details, billing conditions, and payments received with billing details may also be processed by us. We do not process your debit/credit card details as we use external payment processing providers. These data are necessary to know who we are entering into a contract with, invoice our Services, and fulfill our legal and other obligations.
4.5 Company Information. We collect general information about your company, such as company name and approximate company size, if it has been provided while creating an account on Flinne.io. This information is necessary to ensure we provide you with adequate Services in relation to your business field and company size.
4.6 Information From Our Mutual Conversations. We may also collect and process other data you share with us through mutual communications by e-mails, phone calls, and contact forms, as well as through Flinne.io itself.
Prospect Data
4.7 Identification and Contact Information. As Joint Controllers, the User and we collect and process Prospect Data, such as names and surnames of Prospects, their occupation, information about the business or company for which they work or provide their services, e-mail address, website, location, and industry, that has been provided to us by the User or generated or collected through publicly available third-party tools and business social networks under instructions provided by the User.
4.8 Business Data. We also collect and process information about businesses, including the business or company name, location, address, website, e-mail addresses and phone numbers, company size, and company social media presence. Some of these business data may contain personal data if included in the company's names, addresses, websites, or other information.
5. Legal Basis and Purposes for Processing Personal Data
5.1 Basic Information. We process User Data and Prospect Data lawfully, fairly, and in a transparent manner. We collect and process information about Users and Prospects only when we have a legal basis for doing so. The legal basis depends on whether you are a User or a Prospect.
5.2 User Legal Basis. If you are a User, we collect and process the User Data only when one of the following conditions is met:
5.2.1 It is necessary for the performance of an agreement concluded between us or to take steps at your request before entering into such an agreement (for example, when we provide you with Services you have requested from us);
5.2.2 You grant us consent to do so for a specific purpose (for example, you might grant consent to receive our newsletter) or
5.2.3 We must process your data to comply with a legal obligation.
5.3 Prospect Legal Basis. If you are a Prospect, we (as Joint Controllers) collect and process the Prospect Data only when the following criteria are met:
5.3.1 As we alluded to earlier, we only process prospect data that is related to a business activity. We strictly control and stop any processing of personal data related to Prospects' consumer or personal status. We also do not process any sensitive personal data (e.g., data about Prospects’ race, ethnicity, medical conditions) or personal data of children.
5.3.2 As we limit the processing of Prospect Data, we conclude that we are allowed to process these data on the basis of our, the Users’, and even the Prospects’ legitimate interest.
5.3.3 As both the Users and the Prospects present themselves and their services in a business environment, we reckon our Services and Flinne.io generally contribute to business activities and cooperation between Users and Prospects.
5.3.4 Such contribution enables both Users and Partners to discover new business opportunities, to expand their information about the market and potential business partners, which are trustworthy and verified, and to simplify business interactions.
5.3.5 We consider these benefits of our Services to be beneficial for Users and Prospects as well. We reviewed our legitimate interests in relation to Prospects’ data protection interests and concluded that these legitimate interests prevail.
5.3.6 If you are a Prospect who does not care for and does not value these possible benefits, please feel free to unsubscribe from any of our communication channels. Contact us at hello@flinne.io or in any other way. We will never contact you again.
5.4 Consent. If you provide us with your consent to use information about you for a specific purpose, you have the right to change your mind at any time (however, this will not affect any processing that has already taken place). You can withdraw your consent to processing your personal data by sending us an e-mail at hello@flinne.io.
5.5 Protection of Personal Data. We do not keep your personal data for any longer than necessary. While we retain this data, we protect it within commercially acceptable means to prevent any loss or theft and protect it from any unauthorized access, disclosure, copying, use, or modification. We advise that no electronic transmission or storage method is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information to comply with a legal obligation or protect our or your vital interests.
6. For How Long do We Process Your Personal Data?
6.1 User Data. User Data will be processed and stored for the duration of the agreement on the provision of the Services between the User and the Company, then for the next three years after the contractual relationship is terminated unless otherwise provided.
6.2 Protection of Our Interests. We process some basic User Data (generally name, surname, name of the company, address, and e-mail address) to defend our legal claims in judicial or similar proceedings. These data may be processed for a period of up to 15 years following contract termination or for any other period set as a statute of limitation by law.
6.3 Legal Obligations. User Data that are processed on the grounds of our legal obligations arising from accounting, tax, and other statutory regulations are stored for the time limit set out in these regulations.
6.4 Subscription Cancellation. Please note that we are not obliged to delete all of your User Data if you cancel the subscription. We may still keep the data obtained during your use of Flinne.io, such as your e-mail address, name, and surname, to maintain compliance with our legal obligations.
6.5 Consent. If you grant us consent to process your personal data, you are entitled to withdraw it at any time. However, we would like to inform you that if you withdraw your consent, keeping some of your data might be necessary to maintain compliance with our legal obligations. Please note that we may also keep the data if our legitimate interest entitles us to do so.
6.6 Prospect Data. We store Prospect Data provided to us by the User or collected by us for the entire period when the User uses our Services and for six months after the Services are terminated. The User takes into account and agrees that Prospect Data may be deleted without notice when we receive a deletion request from a Prospect.
7. Commercial Messages
7.1 Newsletters Subscription. If the User or other visitor to our website is interested in subscribing to our newsletters, we can send you those regularly based on your consent given to us for this specific purpose on Flinne.io. We will then process your e-mail address, name, and surname for a period of 3 years from the time the consent is granted. We can extend this period if you express interest in doing so before it expires.
7.2 Relevant Commercial Messages. If you use our Services as a User, we can send you commercial messages related to relevant offers to your e-mail address for a period of 3 years from the provision of the Services unless you extend this period. This will be done on the basis of legitimate interest.
7.3 Unsubscribing. You can refuse to receive these messages at any time by any means, for example, by sending an e-mail to hello@flinne.io or by clicking on the link in the commercial message.
8. Disclosure and Transfer of Personal Data to Third Parties
8.1 Involving Third Parties. In order to provide you with the best possible services, we may involve other entities in processing your User Data and/or Prospect Data without your consent.
8.2 Data Processors. However, you do not have to worry about your User Data and/or Prospect Data safety or privacy. Our suppliers are in a position of the so-called “data processors” and can only handle your data in the context of the activities and services they provide to us. We will also still be the ones who decide what happens to your personal data. We also strive to use only verified and trustworthy providers to ensure your data will be safe.
8.3 To whom may we disclose your data? We may disclose personal data to:
8.3.1 third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, CRM providers; ad networks, analytics; error loggers, debt collectors, maintenance or problem-solving providers; marketing or advertising providers; professional advisors and payment systems operators; and
8.3.2 our employees, contractors, and/or related entities generally ensure that our Services may be provided to the Users.
8.4 Currently Engaged Processors. Below is a list of the engaged processors who may receive your personal data from us. This list may be changed at any time if we decide to utilize different third-party service providers:
8.5 Transferring Data Outside EEA. We may transfer some of your personal data outside of the European Economic Area (EEA) via some entities we cooperate with. This transfer is made only if it complies with the terms and conditions of the legal provisions for such transfer.
8.6 Where is the Personal Data Stored? The personal data we collect is stored and processed in the European Union, or where we or our partners, affiliates, and third-party providers maintain facilities. By providing us with your personal data, you acknowledge that the data may be disclosed to these overseas third parties.
8.7 Data Transfer Conditions. We will ensure that any transfers of personal information from countries in the European Economic Area (EEA) made to countries outside the EEA will be protected by using the appropriate safeguards, for example, by applying standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
9. What are Your Rights if You are a Resident of the European Union or the United Kingdom?
9.1 Territorial Scope. You can utilize your rights as per this section of the Privacy Policy if you reside in the European Union (as per GDPR) or in the United Kingdom (as per UK GDPR).
9.2 Exercising Your Rights. We make sure the processing of all personal data is done properly and safely. You can exercise the rights guaranteed to you in this section at our e-mail address by unsubscribing from our e-mail communications or by reacting through the e-mail addresses used to deliver these communications.
9.3 Providing Information. We provide any information about your personal data free of charge unless the request for information is clearly unreasonable or inadequate, especially for its repetitive or excessive nature. In this case, we are entitled to charge a reasonable fee, taking into account the additional administrative costs of providing the requested information. Also, in case of repetitive requests for providing copies of processed personal data, we have the right to charge appropriate fees as administrative costs.
9.4 Reaction Times. We will provide you with comments and, if applicable, information about the measures taken after you exercised your rights as soon as possible, but at the latest within a month. Considering the complexity and number of applications, we are entitled to extend the period by two months if necessary. We will inform you of such an extension, including reasons for such an extension.
Right to Be Informed About the Processing of Personal Data and the Right to Access the Data
9.5 What This Right Means. You are entitled to require information about whether any of your personal data is processed or not. If the personal data is processed, you have the right to require information about the data controller and his representatives, about the purpose of processing personal data, categories of personal data, recipients or categories of recipients of personal data, data controllers, enumeration of your rights, option to enquire the Office for Personal Data Protection about the sources of processing personal data and automated decision-making and profiling.
9.6 Copy of Personal Data. You have the right to be provided with a copy of processed personal data. The right to obtain this copy cannot interfere with the rights and freedoms of other persons. Where possible, we will provide this information in .CSV format or other easily readable machine format.
9.7 Additional Data Processing. If the data controller intends to use the personal data for a different purpose it was originally collected for, the data controller will provide you with additional information about the intended purpose before any additional data processing.
9.8 Information in this Privacy Policy. The above-mentioned information you have the right to be provided with is part of this Privacy Policy.
9.9 Information from Third Parties. If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such a person's consent to provide the personal data to us.
Right to Restrict the Collection or Use of Your Personal Data
9.10 What This Right Means. You may choose to restrict the collection or use of your personal data. If you have previously agreed to use your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or Services.
Right to Erasure (Right to Be Forgotten)
9.11 What This Right Means. You have the right to request the erasure of personal data where one of the following grounds applies, for example, when the personal data are no longer necessary in relation to the purposes for which they were collected. Your request shall be reviewed individually, and you will be informed about the outcome. In some cases, we might still be legally required to process the personal data.
Right to Correction of Personal Data
9.12 What This Right Means. Please contact us if you believe any information we hold about you is inaccurate, outdated, incomplete, irrelevant, or misleading. We will take reasonable steps to correct any personal data.
Complaints
9.13 How Can You Complain? If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details above and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Right to Unsubscribe
9.14 How Can You Unsubscribe. To unsubscribe from our e-mail database or opt out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
10. What are Your Rights if You are a Resident of California?
10.1 The CPRA grants California residents special rights regarding the collection, use, and sharing of their personal information by businesses. When you use Flinne.io, we may collect various categories of personal information from clients, visitors, related persons, and third-party prospects.
10.2 Additional Information. A detailed description of the personal information we collect from you can be found in the 4. What Personal Data do We Process? section and the categories of third parties we share your personal information with are outlined in 8. Disclosure and Transfer of Personal Data to Third Parties section above. The terminology used in these sections complies with GDPR definitions in consideration of the definitions established in CPRA.
10.3 CPRA Rights. As a California resident, you have the following rights to the extent provided for by CPRA.
10.4 Right to Obtain Information About and Access Personal Data. You can request information about what categories of personal data have been collected about you, as well as information about the purposes of the collection. You can also request to receive access to the personal data. Where possible, we will provide this information in .CSV format or other easily readable machine format.
10.5 Right to Correct Inaccurate Personal Data. If you find out that we maintain inaccurate personal data about you, you may require us to correct such inaccurate personal data.
10.6 Right to Delete Personal Data. You can request us to delete the personal data that we have collected from you and about you unless we need to maintain it for certain reasons under the CPRA, such as protection against malicious, deceptive, fraudulent, or illegal activity or to comply with a legal obligation.
10.7 Right of No Retaliation Following Opt-out or Exercise of Other Rights. We take your privacy seriously and will not discriminate against you for exercising any of the above-mentioned rights granted by CPRA.
10.8 Right to Know What Personal Data is Sold or Shared and to Whom. We do not sell any personal data to third parties. We jointly process Prospect Data with the User and share the personal data with third parties to enable us to provide our Services as per 8. Disclosure and Transfer of Personal Data to Third Parties.
10.9 Exercising the Rights. You can exercise your rights under CPRA by sending us an e-mail or by any other means of communication listed in 15. Feel Free to Contact Us! section below. But, please note that we may need to confirm your identity before processing your requests. As we work mainly online, please consider contacting us through e-mail as it is the most effective way.
11. Automated Decision Making
11.1 What is Automated Decision Making. Automated decision making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
11.2 Use of Automated Decision Making. We do not make any decisions with regard to personal data based solely solely on automated processing that would have legal effects concerning the data subject or that may similarly significantly affect the data subject.
12. Security
12.1 Security Measures We Use. In an effort to maximize the security of your personal data, we are taking the appropriate technical, physical, legal and organizational measures in accordance with applicable laws on privacy and data security. If you have any reason to believe that your communications with us are no longer secure (for example, if you feel that the security of any personal data you have entrusted to us has been compromised), please notify us immediately via the contact details listed below.
13. Limits of Our Policy
13.1. Third-party Sites. Our website may link to external sites that are not operated by us. Please, be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
14. Changes to This Policy
14.1 Reasons for Change and Informing About the Changes. At our discretion, we may change our Privacy Policy to reflect current acceptable practices and new regulations. We will take reasonable steps to let users know about changes via our website. Your continued use of our website and the Services after any changes to this Privacy Policy will be regarded as acceptance of our practices around privacy and personal data.
14.2 Significant Changes. If we make a significant change to this Privacy Policy, for example changing a lawful basis on which we process your personal information, we will inform you about these changes.
15. Feel Free to Contact Us!
15.1 In case of any questions, please, contact us via e-mail at: hello@flinne.io.
15.2 Mailing Addresses. You can also reach us at our mailing addresses:
15.2.1 New York City: 80 Broad Street, 5th Floor, New York, NY 10004;
15.2.2 London: 3rd Floor, 86-90 Paul Street, London EC2A 4NE;
15.2.3 Prague: Antala Staska 1859/34, Prague 4, 14000, Czechia.
The following "Privacy policy" was put into effect on January 6th, 2023."
Your Flinne.io Team.