Privacy Policy
About us
The Floww Group is made up of different companies (as stated below). The Floww company providing the relevant product or service to you will be responsible for processing your personal data for that product or service and will be known as the “controller” of your personal data.
There are instances where different Floww companies will act as both the “controller” and the “processor” in relation to your personal data. In these instances, the relevant Floww company will process your personal data on behalf of the other Floww company.
For example, if you sign up to “Floww Markets” they will act as your “controller”, as they determine the purposes and means of processing your personal data. Fomtech (Floww) are the owners of the platform (websites); therefore when you submit your personal data on the platform, they (Floww) will act as the “processor” as they will process your data on behalf of Floww Markets.
We’ll let you know which company you have a relationship with when you provide us with your information or when we get in touch.
- Fomtech Limited trading as Floww, registered at 9th Floor, 107 Cheapside, London, United Kingdom, EC2V 6DN
- Floww Markets Limited, registered at 9th Floor, 107 Cheapside, London, United Kingdom, EC2V 6DN
- Floww Pool Limited, registered at 2nd Floor, 4 Matthew Parker Street, London, SW1H 9NP
How this Privacy Policy applies to you
This privacy policy applies to:
- Your use of our website and platform;
- Your use of our mobile application; and
- All services available through our website, platform, and mobile application.
This privacy policy does not affect or override any privacy policy that you have in place with your firm, wealth manager(s), venture capital firm, investor, family office and/or broker (in this privacy policy, all are referred to as “firms”) or any investee company (“companies”), and therefore does not replace any privacy policy that it/they have issued to you.
Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting personal data about you will supplement this privacy policy. They are not intended to override it.
We review our use of your personal data regularly. In doing so, we can change what personal data we collect, how we keep it and what we do with it. As a result, we can change this privacy notice from time to time to keep it relevant and up to date with legal and regulatory requirements.
We will endeavour to alert you to these changes; however, we encourage you to check this privacy policy for changes whenever you visit our website or the Floww platform.
How to contact us
If you have any data-related queries or questions about this privacy notice, including any requests to exercise your legal rights relating to your personal data or to make a complaint about how your personal data is being handled, please contact us at [email protected].
Our offices are located at 2nd Floor, 4 Matthew Parker Street, London, SW1H 9NP.
How your personal data is collected, handled and used
How is your data collected?
We use different methods to collect personal data from and about you, such as:
Direct interactions. We will collect a certain amount of your personal data from your navigation and use of our website, platform and mobile application. This includes personal data you provide, or which is generated about you, when you:
- Complete our web forms;
- Request a demonstration;
- Subscribe to our publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey;
- Give us some feedback.
Automated technologies or interactions. As you interact with our website and the Floww platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns, and your Usage Data. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Indirect interactions. We may receive information about you from other Floww platform users — for example, representatives from firms or companies. In most cases, this will be where the Floww platform user has input information about you onto the Floww platform on your behalf and with your approval. If you do not wish to be contacted, please let us know.
Third-party service providers. We may instruct third parties to assist us to collect, handle and use your personal data on our behalf. Those third parties will carry out those activities in accordance with this privacy policy. A description of the type of third-party service providers that we currently use and what we use them for is set out in Appendix 1. We will update this from time to time.
Third-party hyperlinks & connectors. Our website and/or services may include links to third-party websites, plug-ins and applications. Clicking on those links, or enabling those connections, may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their data protection compliance. When you leave our website or connect to a third party from us, we encourage you to read their privacy policy or notice.
What personal data do we collect?
Personal data means any information about an individual from which that person can be identified. It does not include data where the person is no longer identifiable (anonymous data).
We will collect, use, store, share and transfer the different kinds of personal data and associated information about you which we have grouped together below (referred to generically in this policy as “personal data”):
- Identity Data — your title, first name, maiden name, last name, date of birth, gender, nationality, and job information;
- Contact Data — your billing address, delivery address, email address and telephone numbers, and contact details history;
- Opinions — where a user of the Floww platform may have uploaded comments about potential or actual investments within the Floww platform;
- Technical Data — your internet protocol (IP) address, MAC address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile phone location data, and other technology on the devices you use to access our website and the Floww platform;
- Usage Data — information about how you use and navigate around our website and the Floww platform; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; the types of (and specific) ventures, assets, transactions and investments within the Floww platform that you have shown an interest in, those that you have invested in, and when you have sold those investments. We will also keep records of your contact with us and any feedback and survey responses that you have submitted;
- Marketing Data — your preferences in receiving marketing from us and our third parties, and your communication preferences;
- Aggregated Data — statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law, as it does not directly or indirectly reveal your identity. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data; and
- Anonymised Data — data created from your personal data where your identity has been removed so that you are no longer identifiable.
What personal data we do not collect
Special category data. We do not collect any Special Categories of Personal Data about you, which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
Children’s data. We do not intentionally collect personal data relating to children. The services we offer are not directed towards children, and we do not purposely collect personal information from or about individuals under the age of thirteen (13). In the event that we become aware or discover that we have collected such personal information, we shall ensure that the processing of such personal information is for a lawful and legitimate purpose. Upon the expiration or termination of the lawful and legitimate purpose, we shall make reasonable efforts to delete and remove such personal information from our systems.
Do you have to provide the information we request?
We require certain personal data from you if you wish to be registered on the Floww platform. However, you do not have to provide us with this information if you do not want to be registered as a user. We collect the same types of personal data from all users of our website and the Floww platform, and so cannot filter what we collect from individual users.
What we do with your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests;
- Where you have provided us with your consent;
- Where it is necessary for the performance of the contract; and
- Where we need to comply with a legal or regulatory obligation.
The personal data handling activities we carry out include:
Marketing purposes. You may receive marketing communications from us via post, telephone, email or other electronic means such as social media, paid media and other digital channels. We will provide you with information, products or services that you request from us or which we feel may interest you, and may use your Usage Data to help ensure that this messaging is personalised and relevant to you.
Cookies. We may also use your Technical Data to show you adverts while you are online that are relevant to you. You can find out more about this, and how to turn off cookies, by reading our Cookie Policy. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly.
Promotional/marketing communications. We may use your Identity, Contact, Technical and Usage Data to form a view on what information we think may be of interest to you. You will receive promotional/marketing communications from us if you have requested information from us, you are a registered user of the Floww platform, or there is a legitimate interest — and, in each case, you have not opted out of receiving that promotion.
Tracking activities. Where you are a client of a firm, we will track, for and on behalf of that firm, when you are navigating around or using our website and the Floww platform and what you are looking at. We will provide this information (together with your Identity and Usage Data) to this firm in order for them to service their clients better. Using Anonymised Data, and in order to optimise distribution channels, we will keep track of what types of users are interested in the different ventures, investments, transactions and assets on the Floww platform.
Monitoring purposes. This refers to listening, recording, viewing, intercepting or taking and keeping records of calls, email, text messages, social media messages, in-person meetings and other communications between us. We’ll do this where the law requires it, to comply with regulation, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, and for quality control and staff training purposes.
Data sharing purposes. Information uploaded to the Floww platform by you or on your behalf may be shared with other Floww platform users, including firms and companies (e.g. to inform investment decisions).
Your choices
- Preferences. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- Opting out / withdrawing consent. You can ask us, or the third parties with whom we (as a data controller) share your personal data, to stop sending you promotional or marketing messages at any time.
- Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Who we share your personal data with
We may share your personal data with the following entities for the purposes set out above and in Appendix 1:
- Firms, where we act as a data processor for and on their behalf;
- Other Floww platform users, including firms and companies, in accordance with our terms of business;
- Market research organisations who help us to develop and improve our products and services;
- Third-party marketing companies (we will obtain your consent before we share your personal data with any company outside our group for marketing purposes);
- Governmental and regulatory bodies such as the Financial Conduct Authority, the Prudential Regulation Authority, the Financial Ombudsman Service and the Information Commissioner’s Office;
- The entities listed in Appendix 1; and
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
We may process your personal data without your knowledge or consent, in compliance with the above, where this is required or permitted by law. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Legal grounds for our use of your personal data
| Purpose / activity | Type of personal data | Controller / processor | Legal basis |
|---|---|---|---|
| Marketing / promotional offers | Identity, Contact, Usage, Marketing | Controller | Legitimate interest / your consent |
| Cookies | Technical | Controller | Your consent |
| Tracking activities | Identity, Usage | Processor | Legitimate interests / consent |
| Monitoring purposes | Identity, Contact, Technical, Usage, Marketing | — | Compliance with a legal obligation |
| Data sharing purposes | Identity, Contact | Controller | Legitimate interests |
Data sharing
| Shared with | What is shared | Purpose | Legal basis |
|---|---|---|---|
| Third-party firms | Identity, Usage | To fulfil data processor duties | For and on behalf of the firm as controller |
| Floww platform users | Identity, Contact | To inform investment decisions | Legitimate interests |
Where we send your personal data
We’re based in the UK and will not transfer your personal data outside the EEA other than in accordance with the law. We will send your personal data for processing to our third-party service providers who may be based outside the EEA, including South Africa and Jersey. If we do so, we’ll make sure that suitable safeguards are in place — for example, by using approved contractual agreements — unless certain exceptions apply. We cannot control where other Floww platform users may access the Floww platform from, but any such access will be in accordance with the applicable terms of service.
How we look after your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know; they will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority where we are legally required to do so.
Keeping your personal data up to date
It is important to us that the personal data we hold about you remains accurate and up to date at all times, but we need your help in doing this. Please let us know as soon as anything needs updating or correcting.
How long we keep your personal data
We will not retain your personal data for longer than necessary for us to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We carry out a review of all the personal data that we hold on a regular basis and determine whether to securely delete it or anonymise it so that it cannot be linked back to you. We will keep and use Anonymised Data indefinitely without further notice to you.
Your rights
You have the following legal rights under data protection laws in relation to our handling of your personal data (they don’t apply in all circumstances):
- Right to be informed about your personal data and the handling and processing of it;
- Right of access to your personal data and information about how we handle and process it;
- Right to rectification of inaccurate or incomplete personal data;
- Right of erasure of your personal data (the “right to be forgotten”);
- Right to restrict handling and processing of your personal data;
- Right to move, copy or transfer your personal data (“data portability”);
- Right to object to the handling and processing of your personal data for certain purposes, in particular direct marketing;
- Right to withdraw consent that you have previously provided;
- Rights in relation to automated decision making where it has a legal or similarly significant effect on you; and
- Right to complain to us and to the Information Commissioner’s Office, which enforces data protection laws (ico.org.uk).
How to exercise your rights
- Contact us. If you wish to exercise any of your legal rights, please contact [email protected] or write to us at 2nd Floor, 4 Matthew Parker Street, London, SW1H 9NP. We’ll first explain whether the right you wish to exercise applies and whether we are the data controller in that respect. If we are not the data controller, we will direct you to the appropriate entity.
- Fees. You will not have to pay a fee to access your personal data or to exercise any other rights. We may charge a reasonable fee, or refuse to comply, if your request is clearly unfounded, repetitive or excessive.
- Verification. We may need to request certain information from you to confirm your identity and ensure your right to access. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
- Response time. We will respond to all legitimate requests as soon as we can, and in any event within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Spam protection
We use Google reCAPTCHA v3, a spam protection service provided by Google. This service analyses the traffic of our signup website (only potentially containing your personal data) with the purpose of filtering out traffic, messages and content that are recognised as spam. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Appendix 1 — Third-party service providers
- Data storage providers — we store our data with at least one data storage provider.
- Visitors to our websites — when someone visits floww.io we use Google Analytics to collect standard internet log information and details of visitor behaviour patterns. This information is only processed in a way that does not identify anyone, and we do not make (or allow Google to make) any attempt to find out the identities of those visiting our website.
- Company data processing — where we have outsourced data processing to a third party for purposes such as due diligence checks.
- Third-party payment providers — when someone makes an online payment to us, in particular as part of a subscription to access the Floww platform.
- Cloud platform providers — the Floww platform is hosted in the cloud using a third-party platform provider.
- Integrated authentication and authorisation providers — to ensure that only authorised users are able to access the Floww platform.