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PRIVACY POLICY

the dtx company dba Flowcode‍

Effective Date October 30th, 2023


1. INTRODUCTION - HOW THIS PRIVACY POLICY WORKS

This is the Privacy Policy for the dtx company dba Flowcode (“dtx”) and its
business operations, including Flowcode and Flowpage.  It covers how we use the
personal information we obtain in connection with our websites (“Sites”),
Flowpages, and other services, features, content, technology and applications
(desktop and mobile), including, for example, our QR Codes known as Flowcodes,
our Flowtags, our API, our Flowleads tool and our Flowcode Conversion Pixel (all
of which we refer to as our “Services”). We help participating companies
(Brands) and other creators of Flowcodes, Flowtags, Flowpages, Flowcode
Conversion Pixels and/or other dtx-powered offerings (“Creators”) build
connections. Sometimes we do this – and provide other aspects of our Services to
Brands, Creators and other consumers using our Services – by collecting
information through Flowpages, Flowtags, Flowcodes or through the websites,
applications or other online properties of Brands and Creators that use our
Services.  

If you represent a Brand or are a Creator or a consumer who uses our Services,
this Privacy Policy sets out how we look after your personal information and
contains information regarding your privacy rights when using our Services or
otherwise interacting with dtx. This Privacy Policy also covers the personal
data we collect in the context of our other business-to-business interactions
and marketing efforts. Dtx respects your privacy and is committed to protecting
your personal information.

For the purposes of the relevant privacy and data protection law in the United
Kingdom, European Union, or locations with similar law, in most cases (except
where we have agreed to act solely as a “processor” of your information on
behalf of a Brand or Creator you are interacting with as discussed below), dtx
is considered the “controller” of your personal information. This means that we
are responsible for deciding how we store and use personal information about you
and providing you with the information contained in this Privacy Policy.
However, this Privacy Policy only applies to dtx’s handling of your personal
information. Brands, Creators and other third parties collect and handle
personal information pursuant to their own policies and procedures, which differ
from this Privacy Policy and for which they are responsible. Clicking on
third-party links or enabling connections to third parties through our Services
(including by using or visiting their Flowcodes, Flowpages or Flowtags) may
allow third parties to collect or disclose personal information about you. These
third parties typically act as separate and independent controllers of your
personal information, including with respect to information they collect on
Flowpages and through Flowcodes and Flowtags. We do not control these third
parties and are not responsible for their privacy policies and procedures.

By using a Site or other Services, such as by scanning a dtx-powered QR code
(including one labeled Flowcode, Flowtag or Flowpage), creating a personalized
Flowcode QR code (“Personal QR code”), creating a Flowpage (“Personal Flowpage”)
or Flowtag, or visiting, scanning, tapping, entering information into or
clicking on a Site, Flowpage, Flowcode or Flowtag, you authorize the collection
and handling of your information as described in this Privacy Policy.

The types of information we collect are described in the Key Privacy Details
section below. You disclose some of that information with us using the
information collection technology described below. We also may use that
technology to collect information about you automatically. We may also receive
personal information from Brands, Creators, service providers and data partners
(e.g., Google), trade associations and industry partners, event organizers,
joint marketing partners, public agencies, as well as other publicly available
sources such as websites. If you disclose your Personal QR code or you disclose
any other dtx-powered QR code (including through your Personal Flowpage) to
another person who then scans that QR code, we may collect from that person’s
device the same categories of information as described in the Key Privacy
Details section below and the rest of this Privacy Policy, and that collection
of information will be subject to the terms of this Privacy Policy. In addition,
if a Flowpage uses our contact collection form or other information collection
widget, another person (for example, a Flowpage visitor) may enter additional
information into that widget. In that case, our own collection and handling of
such information will be subject to the terms of this Privacy Policy, but the
Flowpage Creator’s handling of the information will be subject to their own
privacy policies and practices.

It is important that you read this Privacy Policy together with any other
privacy policy or notice we provide on specific occasions so that you are aware
of how and why we are using your personal information. This Privacy Policy is
not a contract.

We will update this Privacy Policy from time to time and may also notify you in
other ways from time to time about how we handle your personal information.


2. KEY PRIVACY DETAILS - HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

This section of our Privacy Policy sets out some key details about how the dtx
company dba Flowcode (“dtx”) and its business operations, including Flowcode and
Flowpage, collect and use your personal information.  It does not apply to the
handling of personal information by our customers (such as Brands and Creators).
 For full context and details, we recommend reading this entire Privacy Policy
from the top.

To understand dtx’s handling of personal information, you need to know a few
things about how our QR codes work:

QR CODES

When you point the camera on any modern phone or tablet at a QR code, you’ll
either be given an option to take some action, or your device will automatically
take that action. For example, when you point the camera at the QR code below,
you’ll see the option to visit a webpage. Some QR codes can do other things,
like download some content or install an app.




PERSONAL INFORMATION WE COLLECT

Personal Information that could be collected or generated when you scan one of
our QR Codes (including on a Flowtag):

 * a record of the specific QR Code you scanned;

 * information about your device, such as its current IP address, the operating
   system and the browser used by the device;

 * unique cookie IDs we assign to your browser (but cookie usage is reduced or
   unavailable in some countries outside the United States)

 * precise geolocation; and

 * inferences drawn from any of the above, such as your general location based
   on your IP address, or an inference about your interests or your attributes
   based on the fact that you scanned that particular QR Code.

Personal Information collected in other contexts, such as through other use of
our Sites or interactions with our business contacts or other counterparties:

 * contact information, such as name, username, email address, phone number and
   address, and professional or employment-related data (such as title);

 * information about your purchases in accordance with your contract with us
   under our Terms of Service;

 * payment details, such as payment card number in accordance with our Terms of
   Service or other contract with us;

 * records of services carried out and business relationships;

 * information about your interests and marketing preferences;

 * information about your device or browser, that we collect through automatic
   means such as cookies and other technology (e.g., unique browser identifiers,
   IP address, browser and operating system information, device identifiers
   (such as the Apple IDFA or Android Advertising ID), geolocation information,
   list of installed apps, local Wi-Fi network name; and internet connection
   information);

 * details you provide through forms or other interactive content that we host,
   such as a Flowpage contact collection form or check-in form, including name,
   phone, address, age, gender;

 * other information collected through automatic means about your interactions
   with Brands, Creators and other partners, and about your interactions with
   our Sites and Services; and

 * inferences drawn from any of the above.

For more information about the information we collect through cookies and how it
is used, please see the Cookie Notice section of our Privacy Policy below.


HOW WE USE PERSONAL INFORMATION

We use personal information for the following purposes:

 * provide our Services to Brands, Creators, users, and others;

 * conduct product and service development (including to improve our Services
   and create new ones);

 * respond to questions, concerns, or customer service inquiries;

 * send information about our current and future Services (or the offerings of
   customers such as Brands or Creators), including marketing communications, by
   phone, email, online display advertising, and other channels;

 * conduct other marketing;

 * analyze market conditions and use of our Services;

 * customize the content and advertising individuals see on our Sites, across
   the Internet, and elsewhere;

 * conduct investor relations;

 * enforce the legal terms that govern our business relationships;

 * conduct audits and other internal and external investigations;

 * detect and take measures against fraud, cybersecurity violations and other
   risks (e.g., security assessments);

 * comply with law, protect rights and ensure safety; and

 * create appropriately aggregated or de-identified data, which is not subject
   to this Privacy Policy, and which we may use or disclose for any purpose.


The California Consumer Privacy Act (“CCPA”) defines the “sale” of personal
information to include selling user data to random third parties for money, like
a data broker does. But it also defines “sale” and “sharing” in a broader sense
that includes some common practices that we have engaged in during the last 12
months. For example, under the CCPA, these terms include the use of certain
advertising services, like when we pay an ad tech company to place a cookie on
the browser of a visitor to our website so that the user can see an ad for our
services on other websites. The ad tech company can see the website visitor’s IP
address and other browser/device/cookie data as part of that process. Under the
CCPA, we also are “selling” personal information when we allow vendors that
assist us with our Services (like certain analytics providers) to also use IP
addresses and browser/device/cookie data to improve their services in certain
ways.  The terms “sale” and “sharing” also cover some of our other uses of other
advertising services, like if we were to pay a third-party website to serve ads
for us to individuals that we specify by giving that website a list of those
individuals’ email addresses (or hashes of those email address). This would be
considered a “sale” and “sharing," even though we’d be the ones who would pay
for it.  We don’t engage in other “sales” or “sharing” of California personal
information (as those terms are defined under the CCPA), but we do engage in
other disclosures of personal information about Californians and others, as
described further below.  We don’t “sell” or “share” personal information (as
those terms are defined under the CCPA) if we have actual knowledge that the
consumer is less than 16 years of age.  Californians can opt out of our CCPA
“sales” and “sharing” by following the instructions on our Your Privacy Choices
form.


3. COOKIE NOTICE – WHAT COOKIES WE USE AS PART OF OUR SERVICES

Through our Sites and other Services (including on Flowpages and in some Brands’
and Creators’ online properties and communications, such as via the Flowcode
Conversion Pixel), we and third parties collect information from your device by
automated means such as cookies, web beacons, local storage, JavaScript,
mobile-device functionality and other computer code.

This information may include unique browser identifiers, IP address, browser and
operating system information, device identifiers (such as the Apple IDFA or
Android Advertising ID), geolocation, other device information, Internet
connection information, as well as details about your usage and interactions
with the relevant website, application, email or other online property (for
example, the URL of the third-party website from which you came, the pages and
content on our Site that you view, how frequently you access or use the
Services, and how you engage with or navigate our Services (including the links
you click on), error logs, and other similar information). In some cases (such
as cookies), the tools described here involve storing unique identifiers or
other information on your device for later use.

These technologies help:

 * Display personalized content;

 * Facilitate online marketing;

 * Remember your settings on the pages you visit so that we can display your
   preferred content the next time you visit;

 * Perform analytics, measure traffic and usage trends, and better understand
   the demographics of users;

 * Diagnose and fix technology problems;

 * Plan for and enhance our business; and

 * Facilitate the other uses and disclosures described in this Privacy Policy.

For example, in some cases, we assist with the collection of information by
advertising services provided by third parties. We and ad services may track
your online activities over time by collecting information through automated
means such as cookies, and we or they may use this information to show you ads
that are tailored to your individual interests or characteristics, your prior
visits to certain websites, or other information we or they know, infer, or have
collected from people like you.

In addition, when you scan a dtx-powered QR code, dtx may use cookies and the
other information collection technology described above to collect information
about that interaction (as further described above in the QR Codes section of
our Privacy Policy).


4. RETENTION – HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

In general, we will retain your information in identifiable form only for the
time necessary to fulfill the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
 Because we may collect and use the same category of personal information for
different purposes and in different contexts, there is not typically a fixed
retention period that always will apply to a particular category of personal
information. Therefore, to determine the appropriate retention period for
personal information, we may consider factors such as the potential risk of harm
from unauthorized use or disclosure of your personal information, the amount,
nature, and sensitivity of the personal information, the purposes for which we
process your personal information, to determine if we can achieve those purposes
through other means, and the applicable legal requirements. Examples of how long
we normally intend to retain personal information that we collect about
residents of California in certain situations are set forth below. Information
may also persist in copies made for backup and business continuity purposes for
longer than original copies.

Category of personal information collected from Californians
Examples of how long we normally plan to keep this information
Identifiers, such as your name, username, email address, phone number and
address
We plan to retain certain identifiers associated with points of contact for
Brands and Creators for the duration of the customer’s contract with dtx, and
for 2 years after that for related administration and sales purposes.
Commercial information, such as information you provided to us in your
communications (some of which is personal information) and information about
your purchases or interactions with our Services.
We plan to retain certain information on an individual’s interest in our
services for up to 1 year after the person’s last interaction with dtx, or 2
years after the end of a Brand’s or Creator’s contract with dtx for sales and
marketing purposes.
Financial information, such as your payment card number.
We may retain financial information for 7 years in support of financial
statements/filings and key financial or business process controls.
Internet or other electronic network activity information, such as technical
data about your device and your interactions with our Sites and Services, and
with Brands and Creators.
We plan to retain the California IP address associated with account logins on
our own websites for several years for account authentication, fraud detection,
and other cybersecurity purposes.
Professional or employment related data, such as your title.
We plan to retain various forms of professional related data received in the
sales context for 1 year after the person’s (or their organization’s) last
interaction with dtx, or 2 years after the end of a Brand’s or Creator’s
contract with dtx for sales and marketing purposes.
Inferences drawn from any of the above.
We often retain inferences for the same period of time for which we retain the
underlying data.


5. DATA TRANSFER – HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties as follows:

 * To Brands and Creators: We disclose information to Brands and Creators. For
   example, when we collect information about you in the context of your
   relationship with (or interaction with) a Brand or Creator, we may disclose
   that information to the Brand or Creator. When you connect your Flowpage to a
   Brand or Creator by activating one of their Flowtags, we disclose your
   information to that Brand or Creator. In some cases, Brands, Creators or
   their suppliers may collect information directly from you, such as via forms,
   cookies, or other technology on Flowpages. We may also disclose personal
   information to Brands or Creators in other situations.

 * To Vendors: We may disclose your information to companies that provide
   services to us, including, without limitation, facilitating some aspects of
   our Sites or Services such as sending emails and fulfilling customer service
   requests.

 * To Affiliates: We may disclose information to other members of our corporate
   family for the purposes described in this Privacy Policy.

 * To Business Partners: Where we are permitted to do by applicable privacy laws
   and with your consent if required by law, we may disclose information to
   businesses with which we partner to offer you certain products, services, and
   promotions which may be of interest to you.

 * To Customers: If you sign up for an individual account using an email address
   containing an email domain controlled by a current or future customer, we may
   disclose certain information about your account status to that customer (for
   example, whether you have responded to an invitation to convert your account
   from an individual account to an enterprise account). If you consent to
   converting your account to the customer’s  enterprise account, all
   information associated with your account may be disclosed to the applicable
   customer.

 * To other customers: Similar to the “To Customers” sentence above, if you have
   an account that is managed by another account, we may disclose your personal
   information to that account manager.

 * Legal Proceedings: We disclose information when we believe disclosure is
   appropriate due to a subpoena or similar investigative demand, a court order,
   or other request from a law enforcement or government agency; to establish or
   exercise our legal rights; to defend against legal claims; or as otherwise
   required by law;

 * Compliance: We disclose information when we believe disclosure is appropriate
   in connection with efforts to investigate, prevent, or take other action
   regarding illegal activity, suspected fraud or other wrongdoing; to protect
   and defend the rights, property or safety of our company, our users, our
   employees, or others; to comply with applicable law or cooperate with law
   enforcement; or to enforce our Services’ terms and conditions or other
   agreements or policies.

 * Corporate Transactions: We may disclose your information as part of, or to
   take steps in anticipation of, a sale of all or a portion of our business, a
   divestiture, merger, consolidation, or asset sale, a bankruptcy, or other
   significant corporate event.

When applicable, we comply with legal requirements for transfers of personal
information to third countries, such as by making transfers under the following
conditions:

 * Transfers to countries that have been deemed to provide an adequate level of
   protection for personal information by the relevant authorities.

 * Transfers using specific approved contracts, such as the EU Standard
   Contractual Clauses for transfers of personal information to third countries,
   with appropriate modifications for other jurisdictions.

 * Transfers in reliance on e EU-U.S. Data Privacy Framework, the UK-U.S. Data
   Bridge, or other programs approved by relevant authorities.

 * Transfers based on appropriate consent.

 * Transfers necessary to perform a contract with the data subject.

 * Transfers that are legally mandated in appropriate circumstances.

Please contact us at privacy@flowcode.com if you would like further information
on the specific mechanism used by us when transferring your personal information
out of the United Kingdom or Europe.


6. LEGAL BASIS FOR PROCESSING – JUSTIFICATION FOR PROCESSING UNDER THE GDPR AND
SIMILAR LAWS

We will only use your personal information when the law allows us to. If you are
based in the United Kingdom or Europe, when we act as a data controller we will
only use your personal information if we have one of the following legal bases:

 * where we need to perform the contract we have entered into with you (for
   example the Terms of Service);

 * where it furthers our legitimate interests (or of our customers, business
   partners, or suppliers) in business activities such as the ones listed below,
   and because that handling of data does not unduly impact your interests,
   rights, and freedoms, such as:
 * using identifiers and financial information to protect business activities,
   individuals, and property;
 * using identifiers to communicate for customer service;
 * using identifiers for marketing and advertising (including sending certain
   direct marketing);
 * using commercial information to analyze and improve our business activities;
 * using identifiers and Internet or other electronic network activity
   information to  provide cybersecurity, manage information technology assets,
   and manage risks and legal issues;

 * where we need to comply with a legal obligation;

 * where we need to protect your interests (or someone else’s interests); and/or

 * where we have obtained your consent.  (We may request your consent before
   engaging in certain activities described in this Privacy Policy.  For
   example, visitors to flowcode.com in the EU will see a request for consent
   before ad targeting cookies are used on that website.)


7. DATA SECURITY 

We urge you to use a unique password for each of the Services, to keep them in a
safe place and not to give them to anyone. Also remember to sign off your
account and close your browser window when you have finished your visit to the
Sites or your other use of the Services. We use various physical, technical, and
organizational safeguards in an effort to protect personal information. However,
no security method is perfect, and even if you take those steps, we cannot
guarantee that any personal information will remain secure.


8. COOKIES – OPTIONS FOR CONTROLLING COOKIES

To opt out of the non-essential cookies on flowcode.com, please select ‘Cookie
Settings’ from the link in that website’s footer to manage your preferences.

To learn more about interest-based advertising generally, or to opt out of
targeted, interest-based ads by some of our current ad service partners, visit
aboutads.info/choices from each browser you use.

For controls relating to the data collected from mobile applications, please
read your operating system's instructions for complete instructions.  Some of
the options may be found here:

 * iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising >
   Enable the "Limit Ad Tracking" setting.

 * For Android devices with OS 2.2 or higher and Google Play Services version
   4.0 or higher: Open your Google Settings app > Ads > Enable "Opt out of
   interest-based advertising".

 * See the NAI guide to mobile device options for additional suggestions for
   managing ad-related preferences.

You can also opt out of Google Analytics and customize the Google Display
Network ads by visiting the Google Ads Settings page from each browser. Google
also allows you to install a Google Analytics Opt-out Browser Add-on for each
browser.

In addition, you may be able to set your browser to refuse certain types of
cookies, or to alert you when certain types of cookies are being used. Some
browsers offer similar settings for HTML5 local storage and other technologies.
However, if you block or otherwise reject our cookies, local storage, JavaScript
or other technologies, certain websites (including some of our own Sites) may
not function as expected.

If you replace, change, upgrade or reset your browser or device, or delete your
cookies, or use a browser that automatically deletes cookies, you may need to
use these opt-out tools again. We do not respond to browser-based do-not-track
signals.


9. MARKETING – WHAT CHOICES YOU HAVE REGARDING MARKETING YOU RECEIVE FROM US

You can unsubscribe from dtx marketing emails at any time. If you have
established an online account with our Services, you may also be able to login
to that account to access or change your personal information, or to use certain
privacy preference settings.

If you do not want us to see or access your device location, you can turn off
location sharing on your device and browser, change your device privacy
settings, and change your device’s location settings for our Sites and
applications. Please note that disabling such features may result in you not
being able to access or receive some of the present or future content available
in the Services.

If you would like to opt out of receiving marketing or promotional emails from
dtx, please contact privacy@flowcode.com or follow the instructions in those
messages. Please note that if you opt out, we may still send you non-promotional
or non-marketing messages, such as communications regarding Services you have
requested.


10. PRIVACY RIGHTS – WHAT RIGHTS YOU HAVE REGARDING YOUR PERSONAL INFORMATION

In addition to exercising your choices regarding cookies and direct marketing as
described in the Privacy Policy sections above, depending on where you live, you
may have the right to make certain other requests related to your personal
information.  For example, if you are located in the United Kingdom, European
Union, or an area with similar laws (including, to some extent, certain states
in the U.S.), you have the right to:

 * Request access to your personal information (commonly known as a “data
   subject access request”). This enables you to receive a copy of certain
   personal information we hold about you and to check that we are lawfully
   processing it.

 * Request correction of the personal information that we hold about you. This
   enables you to have any incomplete or inaccurate information we hold about
   you corrected.

 * Request erasure of your personal information. This enables you to ask us to
   delete or remove personal information where there is no good reason for us
   continuing to process it. You also have the right to ask us to delete or
   remove your personal information where you have exercised your right to
   object to processing (see below).

 * Object to processing of your personal information where we are relying on a
   legitimate interest (or those of a third party) and there is something about
   your particular situation which makes you want to object to processing on
   this ground. You also have the absolute right to object where we are
   processing your personal information for direct marketing purposes.

 * Request the restriction of processing of your personal information. This
   enables you to ask us to suspend most or all processing of personal
   information about you, for example if you want us to establish its accuracy
   or the reason for processing it.

 * Request the transfer of your personal information to another party.

 * Withdraw your consent for specific processing at any time, in the limited
   circumstances where we rely on your consent for such processing. Once we have
   received notification that you have withdrawn your consent in such
   circumstances, we will no longer process your information for the purpose or
   purposes you originally agreed to, unless we have another legitimate basis
   for doing so in law. Your withdrawal of consent does not affect the
   lawfulness of processing that occurred before your withdrawal.

If you want to exercise any of these rights, please contact us.

In addition, residents of California, Virginia, Colorado, Connecticut, Nevada,
and a growing number of other jurisdictions have a right to opt out of what the
laws in those states call a “sale” of personal information.  In most of those
states, the law also provides for a right to opt out of certain uses and
disclosures of personal information for certain targeted advertising purposes.
To exercise those rights, residents of those states can visit our Your Privacy
Choices page and follow the instructions there.  California residents’ rights,
and the specific methods of contact that they must use to exercise those rights,
are described in the next section of this privacy policy.

All the rights described above (except the direct marketing opt-out) are subject
to important exceptions.

You will not normally have to pay a fee to access your personal information (or
to exercise any of the other rights). However, depending on which laws apply, we
may charge a reasonable fee if your request for access is clearly unfounded or
excessive, or we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information (or to exercise any of
your other rights). This is a security measure to ensure that personal
information is not disclosed to any unauthorized people.

All individuals also have a right to complain to their local data protection
supervisory authority about any company’s handling of their personal
information.  If you have a concern about our data practices, we invite you to
please contact us first so that we can do our best to address your concern.

To exercise a right to appeal a decision we have made regarding your personal
information (such as under Colorado, Connecticut, or Virginia law), you can
contact us at privacy@flowcode.com with an explanation of why you believe we
should reach a different decision. Your appeal under one of those laws will be
reviewed by our privacy team, including in certain circumstances our General
Counsel. We will respond with a decision and a written explanation of the
reasons for the decision within 45 days of your appeal.


11. DETAILS FOR CALIFORNIANS

This section applies only to “personal information” about California residents,
as that term is defined in the California Consumer Privacy Act (CCPA), and it
supplements the information in the Key Privacy Details section above and the
rest of this Privacy Policy. Personal information about individuals who are not
residents of California may be handled differently and is not subject to the
same California rights described below. This section also does not apply to
personal information that we handle solely on behalf of certain Brands or
Creators, even when such information is about a resident of California.

Collection and Disclosure of California Personal Information During Past 12
Months

We describe in the two charts below the categories of California personal
information we have collected, and the categories of third parties to whom we
have disclosed such information for a business purpose, during the 12 months
leading up to the effective date of this Privacy Policy:

Information collected when you scan a Flowcode:
Category of personal information collected
Categories of third parties to which it was disclosed for a business purpose
Identifiers, such as IP address
Affiliates, customers (including Brands and Creators), and service providers,
contractors or agents who perform functions on our behalf, such as (depending on
the data and the situation) data storage and hosting providers, email service
providers, analytics providers, network and system management providers,
communications tools, IT support providers, CRM providers, incentive providers,
accounting services. 
Commercial information, such as information about your use of our QR codes
Same as first row
Internet or other electronic network activity information, such as technical
data about your device and information about your use of QR codes and your
interactions with our Sites and Services, and with Brands, Flowcodes, Flowtags
and Flowpages
Same as first row
Inferences drawn from any of the above information
Same as first row
Other personal information
Category of personal information collected
Categories of third parties to which it was disclosed for a business purpose
Identifiers, such as your name, username, email address, phone number and
address
Affiliates, customers (including Brands and Creators), and service providers,
contractors or agents who perform functions on our behalf, such as (depending on
the data and the situation) data storage and hosting providers, email service
providers, analytics providers, network and system management providers,
communications tools, IT support providers, CRM providers, incentive providers,
accounting services. 
Professional or employment-related information, such as your title
Same as first row
Commercial information, such as information you provided to us in your
communications (some of which is personal information) and information about
your purchases or interactions with our Services
Same as first row
Financial information such as your payment card number
Handled directly by payment card processors and payment service providers
Internet or other electronic network activity information, such as technical
data about your device and your interactions with our Sites and Services, and
with Brands and Flowpages
Same as first row
Inferences drawn from any of the above information
Same as first row

CCPA Information and Deletion Rights

If you are a California resident, California law may permit you to request that
we:

 * Inform you of the categories of personal information we have collected about
   you in the last twelve months; the categories of sources of such information;
   the categories of personal information (if any) that we sold or disclosed
   about you for a business purpose, the business or commercial purpose for
   collecting or (if applicable) selling your personal information; and the
   categories of third parties to whom your personal information was sold or
   otherwise disclosed for a business purpose.

 * Provide a copy of certain information we hold about you.

 * Delete or correct certain information we have about you.

Certain information is exempt from such requests under applicable law. You also
may have the right to receive information about the financial incentives that we
offer to you (if any). You also have certain rights under the CCPA not to
receive discriminatory treatment by dtx for the exercise of your CCPA rights. 

To request to exercise those CCPA rights, please email us at
privacy@flowcode.com. For security and legal reasons, dtx may not accept
requests that require us to access third-party websites or services. We do not
respond to browser-based do-not-track signals or similar mechanisms. We will
take steps to verify your identity before responding to your request, which may
include confirming that the browser in your possession matches the one
associated with the relevant QR Codes, requesting that you respond to an email
that we send to you, or otherwise verifying your name, email address or other
information that will help us to confirm your identity.

If you are an agent making a request on behalf of a consumer, you must verify
that you are authorized to make that request, which may include requiring you to
provide us with written proof that satisfies CCPA requirements, such as an
appropriate letter signed by the consumer or a power of attorney. We also may
require the consumer to verify their identity directly with us.

CCPA “sale” and “sharing” of California personal information

As mentioned earlier in this Privacy Policy, you can request opt out of what the
CCPA calls “sales” and “sharing” by using our Your Privacy Choices form, which
is the fastest and best option.  You also can start the process by emailing us
at privacy@flowcode.com  and then following the instructions we send you.

Your browser may also offer a way to activate the Global Privacy Control signal
(“GPC”). Flowcode.com treats qualifying browsers for which the user has
activated the GPC signal as having opted out of what CCPA calls a “sale” and
“sharing” of any California personal information that is collected on that site
from that browser using cookies and similar technology. You can override that
treatment for a GPC-enabled browser by using the cookie controls available from
the website’s footer.

We do not use or disclose “sensitive personal information” covered by this
Privacy Policy and as defined in the CCPA in a manner that requires us to offer
a special right to limit our use of this data under the CCPA due to its
sensitive nature.

California Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right
under certain circumstances to request information from us regarding the manner
in which we shared certain categories of “personal information” with third
parties for their “direct marketing purposes” (as defined in the Shine the Light
law) in the prior calendar year. To exercise that right, please contact us as
described below.


12. CHILDREN’S DATA 

Our Services are not directed at and should not be used by children under the
age of 16. If we learn that we have collected the personal information of a
child under the age of 16, we will delete it or take other steps if required
under applicable law. Please inform us if you believe we have collected the
personal information of a child under the age of 16 by emailing us at
privacy@flowcode.com. 


13. CONTACT DETAILS – HOW TO GET IN TOUCH WITH US

If you have any questions about this Privacy Policy, including any requests to
exercise your legal rights, please contact us via:

 * email at privacy@flowcode.com

 * mail at:
   the dtx company
   Attn: Privacy Team
   233 Spring St.
   West 3rd Floor
   New York, NY 10013

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