Privacy Notice

Privacy Notice

1 Preamble

Flow Momentum Limited Ltd (FM) is committed to protecting and respecting your privacy. This Privacy Notice together with our Terms of Use and any other documents referred to on it, set out the basis on which any Personal Data (as defined below) we collect from you or which you provide to us will be processed by us as a result of using or interacting with our website as set out below.  We aim at all times to process and collect your data lawfully, transparently, fairly and without adversely affecting your rights as a Data Subject.  Please read the following carefully to understand our practices and procedures.  

Please note:

By giving your consent, you are accepting and consenting to the practices described in this policy. If you do not give your consent, please navigate away from the FM website.

You may withdraw your consent at any time. An explanation of your rights is set out below.

This Privacy Notice applies to all services offered by FM in relation to the https://flow-momentum.com/ website.

Flow Momentum Ltd, is a limited company registered in England under company number 15513519, whose registered address is c/o DoES Liverpool, 1st Floor, The Tapestry, 68-76 Kempston Street, Liverpool, L3 8HL, United Kingdom.

Our Data Protection Officer for the purpose of the Data Protection Legislation can be contacted by email at contact@flow-momentum.com or by post at Flow Momentum Ltd, c/o DoES Liverpool, 1st Floor, The Tapestry, 68-76 Kempston Street, Liverpool, L3 8HL, United Kingdom.

The company reserves the right to adjust the statement if necessary. In case of such adjustments, you should check whether you agree with the changes.

This privacy policy also applies to persons who do not have a contractual relationship but whose data is processed for other reasons (e.g. persons who write to us or otherwise contact us; visitors to our websites; recipients of information and marketing communications; contact persons of our suppliers; customers and other business partners; participants in competitions, prize draws and customer events; visitors to our premises).

FM’s Services are not intended for minors (i.e., persons under the age of 18), and we do not knowingly collect personal information from minors. If you are under the age of 18 or under the age of majority in your jurisdiction, you are not eligible to apply for, register for, or use FM’s Services.

It is imperative that the personal information we have about you is accurate and up-to-date at all times. Failure to do so will affect our ability to provide you with our Services. Please inform us if your personal data changes during your relationship with us. For your right to correct the data processed, please refer to Section 3a of the Privacy Policy.

Our Services may contain links to third-party websites, plug-ins, and applications. When you click on these links or enable these connections, third parties may collect or share information about you. We have no control over these third party websites and are not responsible for their privacy notices, statements or policies.

2 Scope of the processing of personal data

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details
  • Purchase or account history
  • Website user information (including user journeys and cookie tracking)
  • Records of meetings and decisions
  • Chat conversations

We collect or use the following information for the operation of customer accounts and guarantees:

  • Names and contact details
  • Purchase history
  • Account information, including registration details
  • Marketing preferences

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Call recordings
  • Relevant information from previous investigations
  • Correspondence

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: We provide coaching services that help our customers to increase their performance and productivity – both in the forms of individual and peer coaching. To have a meaningful dialog, requires an exchange of relevant information.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from:

  • Directly from you

3 How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

4 Hosting

External hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the hoster’s servers. This may include IP addresses, contact requests, meta and communication data, contract data, contact data, names, website accesses and other data generated via a website.

The hoster is used for the purpose of fulfilling the contract with our potential and existing customers and in the interest of a secure, fast and efficient provision of our online offer by a professional provider. 

Our hoster will only process your data to the extent necessary to fulfill its service obligations and will follow our instructions regarding this data.

We use the following hoster:

Infomaniak Network Inc.
Rue Eugène Marziano 25
CH-1227 Les Acacias (GE)
Switzerland

5 Cookie Management with the DSGVO Pixelmate

In order to make the best use of the services we use and to respect your decision in accordance with the law, we use DSGVO Pixelmate, developed by Christian Wedel (https://wp-dsgvo-plugin.com) and Sabrina Keese-Haufs (https://lawlikes.de/). When you visit our website, you can use Pixelmate to control which of the services we use you want to agree to. For each service we use, your decision is stored separately. You can change this setting at any time by using the “cookies” link located at the bottom left of the website. Pixelmate does not store any personal data.

6 Use of Facebook social media plugins

No social media plugins are currently used on this website.

7 Use of contact details

The use of contact data published within the scope of the imprint obligation for the transmission of not expressly requested advertising and information materials is hereby contradicted. We expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

8 Who we share data with (data prcessors)

Payment services

We offer the option of processing payment transactions via the following payment service provider:

Stripe Technology Europe, Limited (Stripe)
The One Building. 1
Lower Grand Canal Street
Dublin 2
Ireland

This corresponds to our legitimate interest in offering an efficient and secure payment method. In this context, we pass on the following data to Stripe insofar as it is necessary for the fulfillment of the contract.

– Cardholder name

– E-mail address

– Customer number

– Order number

– Bank details

– Credit card data

– Credit card validity period

– Credit card verification number (CVC)

– Date and time of the transaction

– Transaction amount

– Provider name

– Place

The processing of the data provided under this section is not required by law or contract. We cannot process a payment via Stripe without the transmission of your personal data.

Stripe has a dual role in data processing activities as a controller and processor. As a controller, Stripe uses your submitted data to fulfill regulatory obligations. This corresponds to Stripe’s legitimate interest (pursuant to Art. 6 (1) lit. f DSGVO) and serves the performance of the contract (pursuant to Art. 6 (1) lit. b DSGVO). We have no influence on this process.

Stripe acts as an order processor in order to be able to complete transactions within the payment networks. Within the scope of the order processing relationship, Stripe acts exclusively according to our instructions and has been contractually obligated within the meaning of Art. 28 DSGVO to comply with the provisions of data protection law.

Stripe has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).

For more information on opt-out and removal options with respect to Stripe, please visit: https://stripe.com/privacy-center/legal

Your data will be stored by us until the completion of the payment processing. This also includes the period required for the processing of refunds, claims management and fraud prevention.

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the specified e-mail address and agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter we use newsletter service providers, which are described below.

We use MailPoet on our website, a WordPress plugin for our email marketing. The service provider is the Irish company:

Aut O’Mattic A8C Ireland Ltd
Grand Canal Dock
25 Herbert Pl
Dublin, D02 AY86
Ireland

You can find out more about the data that is processed through the use of MailPoet in the privacy policy at https://automattic.com/privacy/.

If you become a subscriber to our newsletter via our website, you confirm your membership of an e-mail list by e-mail. In addition to your IP address and e-mail address, your title, name, address and telephone number may also be stored. However, only if you consent to this data storage. The data marked as such is necessary so that you can participate in the service offered. Providing this information is voluntary, but if you do not provide it, you will not be able to use the service. In addition, information about your device or your preferred content on our website may also be stored. We record your declaration of consent so that we can always prove that it complies with our laws.

The data you provide for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after unsubscribing from the newsletter or after the purpose has ceased to exist. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest.

After you have unsubscribed from the newsletter distribution list, your e-mail address will be stored by us or the newsletter service provider in a blacklist, if necessary, to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters. The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

Contact form

If you send us inquiries via contact form or e-mail, your data including the contact information you provided will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of the entered data is therefore based exclusively on your consent. You can revoke this consent at any time. For this purpose, an informal communication by e-mail to us is sufficient (the contact details are given in this statement). The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.

Courses, coaching and community

For bookings of our courses, coachings and for participation in our community you have to register once and define a username and a personal password. On future visits to our website, you can log in with your username and password and do not have to re-enter your address and payment information for each order process. Your password is stored in encrypted form and cannot be viewed by us.

When registering, you must provide your name and email address, and for individual services, your dates of birth or the date and place of incorporation of your company. For payment transactions we use the provider Stripe (see above). In order for us to store the registration data (as your personal customer account), your express consent is required. At the appropriate place on the registration page, we first inform you comprehensively about the purpose and scope of data processing. You can then give your declaration of consent by activating a checkbox. Your declaration of consent will be logged by us; in doing so, we will store your name, e-mail address, the corresponding location on the website, as well as the date and time.

You have the option to informally revoke your declaration of consent at any time. The revocation is to be sent to the address in chapter 1 of this privacy policy.

The data of your orders will also be stored in your customer account.

We use the personal data collected during registration and ordering exclusively for the proper processing of your order.

You can view the data in your customer account at any time and change it yourself. If you update information, we keep a copy of your original information stored to clarify any issues between you and us.

You can object to the use of the data for the purpose just mentioned at any time. In this case, a complete registration is required again for each order. The objection should be sent to the address in chapter 1 of this privacy policy.

We delete all data that we do not have to keep due to legal requirements, e.g. in accounting, as soon as the order is completed.

You have the option to delete your customer account at any time, as soon as no booking is open.

OpenAI Playground

We use OpenAI Playground via API to provide you with an improved user experience in our online service. The data transmitted to OpenAI via the API is used to respond to your requests, answer your questions and personalize your user experience. The data transmitted to OpenAI via our API may include text messages, user interactions and other information needed to provide the chat function in our Service.

OpenAI is responsible for data processing:

OpenAI Ireland Limited
“The Liffey Trust Center”
117-126 Sheriff Street Upper
Dublin 1, D01 YC43
Ireland

Please refer to OpenAI’s privacy policy on their website for information on how OpenAI processes your data. The processing of your data is based on our legitimate interest in improving our services and fulfilling our contract with you as a user of our online service.

Privacy policy of OpenAI

The data processed by OpenAI is stored for the period required to fulfill the above-mentioned purposes. We delete this data when it is no longer required or if you so request. We have implemented appropriate security measures to protect your data from unauthorized access or misuse. You have the right to access, rectify, erase and object to the processing of your personal data.

Youtube

This website contains at least one plugin from YouTube, which belongs to Google Inc. based in San Bruno/California, USA.

We use the YouTube no-cookies function, i.e. we have activated extended data protection, videos are not accessed via youtube.com, but via youtube-nocookie.com.

YouTube provides this itself and thus ensures that YouTube does not initially store any cookies on your device. However, when the relevant pages are accessed, the IP address and the other data mentioned in section 4 are transmitted and thus, in particular, which of our Internet pages you have visited. However, this information cannot be assigned to you if you are permanently logged in to YouTube or another Google service when you access the page.

As soon as you start playing an embedded video by clicking on it, YouTube only stores cookies on your device through the extended data protection mode, which do not contain any personally identifiable data, unless you are currently logged in to a Google service. These cookies can be prevented by making the appropriate browser settings and extensions.

The body responsible for data processing at Google/YouTube:

Google Ireland Limited
Gordon House
Barrow Street
Dublin 4
Ireland

Privacy policy: https://policies.google.com/privacy
Opt-out: https://adssettings.google.com/authenticated
Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Cookies

This website uses the YouTube embedding function to display and play videos from YouTube. We use the extended data protection mode, which, according to the provider, only starts storing user information when the video is played. The moment playback of the embedded video is started, YouTube uses cookies to collect information about user behavior.

According to information from YouTube, these are used, among other things, to record video statistics, improve user-friendliness and prevent abusive behavior.

Irrespective of playback of the embedded videos, a connection to the Google “DoubleClick” network is established each time this website is accessed, which may trigger further data processing operations without our influence.

Further information on data protection at YouTube can be found in the provider’s privacy policy at: https://www.google.de/intl/de/policies/privacy/

Contact

When contacting us by e-mail or other electronic message, your information will only be stored for the processing of the request and possible related further questions and used only in the context of the request. The legal basis for processing your request is Art. 6 para. 1 p. 1 lit. b DSGVO. We will delete your email address after your request has been dealt with.

If you have any questions regarding data protection and data processing, please contact the person responsible or the data protection officer in writing.

Last updated

16 October 2024