Last update: Feb 20, 2019

FLANER PRIVACY POLICY

Thank you for choosing Flaner!

At Flaner, we want to give you the best possible experience to ensure that you always make the most of our service. To do so and to act as a true digital extension of your memory, we need to have access to the content that you share with us, your preferences and contextual information so we can deliver an outstanding and personalized service specifically for you.

We believe in creating a personal product with a social experience, not a social product with personal features - it's a subtle, but critical difference. We transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.

That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below. We hope this helps you to understand our privacy commitments to you.

This Policy applies to all products and services created by Flaner (“the Company”, “us”, “we”, “our”)

WHAT PERSONAL DATA AND HOW WE COLLECT

When you use or interact with Flaner products and services, we collect different types of data from or through our products and services. The legal bases for Flaner processing of personal data are primarily that the processing is necessary for providing our products and services in accordance with Flaner’s Terms of Service and that the processing is carried out in Flaner’s legitimate interests, which are further explained in the section “How we use your data” of this Policy. We may also process data to comply with legal obligations. In some cases, we base our processing on your explicit consent, which we may ask for, and you may revoke at any time, without affecting the lawfulness of processing based on consent before your withdrawal.

Data you provide or you give us permission to obtain it

We collect certain data you provide us when using Flaner, such as when you create an account and profile, send us an email or add information or other content to Flaner. We collect certain personal information, like your name, picture, email address and phone number, as well as certain non-identifying information, like your gender, birthday and postcode.

If you link your Facebook or Google account or accounts from other third-party services to Flaner, we also get information from those accounts (such as your name, email, city, age, birthday and contacts). The information we get from those services depends on your settings and their privacy policies, so please check what those are.

Data we collect automatically

Whenever you use any website, mobile application or other internet service, certain data gets created and logged automatically. The same is true when you use Flaner. Here are some of the types of data we collect:

Activity data: when you access our services and use the application and its features, data on the way you use them may be collected and processed. More specifically, this includes your registration date, last connection, date and time, any content you visualize and save (including but not limited to content, places and placelists), the Placelist you create, visualize or follow/unfollow, the places and Placelists you share, contacts you have shared any content from Flaner with, the searches you make and the results you choose.

Device and equipment data: In an effort to improve the quality of our services, we collect information from the devices and equipment you use to access our Services, including server logs, which may contain information like IP addresses, version of the application, mobile model, mobile ID, language used, operating system, application crashes, and advertisement ID.

Location data (geolocation): You will be asked to authorize the collection and processing of your location data to allow Flaner to provide location-aware information and functionality for you. You can enable or disable location services when you use Flaner at any time, through your mobile device settings. This information is not treated as personal information unless we combine it with or link it to any of the personally identifiable information mentioned above.

Location-related information can be based on things like precise device location, IP addresses, and information from your use of Flaner products and services.

Cookie data:  We also use “cookies” (small text files which include an anonymous unique identifier) or similar technologies to capture log data. When we use cookies or other similar technologies, we use session cookies (that last until you close your browser) or persistent cookies (that last until you or your browser deletes them). For more detailed information about how we use cookies, please review our Cookies Policy.

Data we receive from third Parties

We may receive data about you from third parties, including our partners, ad platforms and other third parties we work with, or other publicly available sources.

Some websites use Flaner features such as our embedded Placelist map. When you use embedded Places or Placelists by Flaner, it's just like as you were browsing Flaner products and services and similar data will be logged, such as IP address, browser information, the placelist and places you were browsing as well as the website with the embedded placelist.

HOW WE USE YOUR DATA

We use the data we collect to provide the best possible service and products to you as well as to develop and further improve our services and products. In order to do that, we need to use your data to:

Provide, maintain, personalize and improve our products and services

We use your data to deliver our products and provide our services, including to personalize features and content (including Placelist carousels) and make relevant suggestions, including places and Placelists you may be interested in. To create personalized products and services that are relevant to you, we use your preferences, interests, search history and activities based on the data we collect and learn from you and others; how you use and interact with our products and services; and the Placelists, places, people or publishers you're connected to and interested in.

Taking into consideration the nature of our Service and Products, when you share information about your preferences or when you share a specific Placelist, we will inform you about other contents and Placelist that have common elements with the ones you have shared. We will also share the contents you provide or Placelists with users who have your common interest or that you’re connected to. This profiling is necessary to deliver you products and services based on the information we collect about you or that you have provided to us.

We may also use your data to develop, test and improve our products and services, including by conducting surveys and research, and testing and troubleshooting new products, features and tools. For example, we may redesign the interface to make it easier for you to create Placelists in the Flaner app or create a new feature to make it easier to you to exchange information with other users. Likewise, if you consent to sharing crash data, we may use it to help us analyze the cause of the crash and fix it. 

Communicate with you and respond to your questions or comments

We use your data to communicate with you about our products and services, and let you know about our policies and terms. We also use your data to send you marketing communications or anything else we think may be of your interest. We also use your information to respond to you when you contact us. You can opt out of receiving marketing communications, contact us via privacy@flaner.com from the email address you used to register with Flaner and let us have enough information to identify you and specify your request.

Provide measurement, analytics, and other business services

We may use your information (including your activity) to help partners, advertisers and others measure the effectiveness and distribution of their content, services and advertisements and understand the types of people who use their content, services and how people interact with them.

Promote safety, integrity and security

We may use your information to verify accounts and activity, combat abusive conduct, detect and prevent spam and other practices, in order to maintain the integrity of our products and services. For example, we use data we have to investigate violations of our terms or policies.

Ads and other sponsored content

We use the information we have about you - including information about your interests, activities, places and Placelists - to select and personalize sponsored content, ads and offers that we may show you. This helps us and our partners to make sure that the content and ads you see are relevant to you.

Location data

We use location data - such as your current location (if you've allowed us to collect it), where you live, the places you like to go, and the businesses you're near - to provide, personalize and improve our products and services, including notifications about your places and placelists, ads and sponsored content, for you and others. For example, if we know that you are based in Paris, we could show you local places and Placelists.

Research and innovate for social good

We may use your data (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest and well-being. For example, we may analyze information we have about city usage patterns to help cities plan improvements.

HOW WE SHARE YOUR DATA

We neither sell or license data about users without their consent unless anonymized or pseudonymized. Except as described in this Policy, we will not intentionally disclose your personal data or client data that we collect or store to third parties without your consent. If you give us your consent, we may share with third parties the personal data collected or generated through your use of our products and services in the following circumstances:

Publicly available data

Anyone can see the basic profile data you give us (your name and photo) and your public Placelists. For example, when you create Placelists, you might want those Placelists to be visible to others and so you can make them public and searchable by anyone. However, you can also make your Placelists secret at any time, and in this case, they will no longer be visible neither searchable to other users. You may also make your Placelists shareable, which means that anyone with the link to such placelist will have access to it. Shareable Placelists are not publicly searchable. It's important to notice that if you share a shareable Placelist with a friend and such friend sends the link of your Placelist to someone else, that other person, who now has your Placelist link, will also be able to see your shareable Placelist.

Personal data you may choose to share

Your Content: If you choose to share a Placelist, anyone with the link to your shareable Placelists will be able to see them.

Support community: when you opt to join our Support Community, any questions or comments you post will be visible to other Flaner users.

Your contacts and other users: You can ask us to share your personal data (like your email address, a destination or a favorite place) with your contacts, other Flaner users or partners who may want to directly send you comments, reviews, Placelists or promotional offers. 

Information we may share

Service providers and others: We use technical service providers which may operate the technical infrastructure that we need to provide Flaner products and services, in particular providers which host, store, manage, and maintain the Flaner application, its content and the data we process. We use technical service providers to help us communicate with you and to provide you support. We use marketing and advertising partners to show you more tailored content, or to help us understand your use of Flaner products and services and to provide you with a better service. We also may share personal data with certain marketing and advertising partners to send you promotional communications about Flaner. When our Service Providers process personal information on our behalf, we call them data processors. We will only use data processors that provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the General Data Protection Regulation ("GDPR") and ensure the protection of your rights. In order to ensure these obligations, all relations between Flaner and service providers regarding your data processing, will be governed by contract or other legal act under Union or Member State law, that is binding on the processor with regards to Flaner and that sets out all GDPR obligations for processors. 

Law Enforcement and Legal Process: We will share your personal data if required to do so by law or if in good-faith we believe that it is necessary for us to comply with a legal obligation under applicable law, or respond to valid legal process, such as, a court order, or a judicial or other government subpoena or warrant or to otherwise cooperate with law enforcement or other governmental agencies.


Flaner Partners: We also may share your personal data in a pseudonymised format with our partners to help them understand how the content they produce is performing.
We also share your personal data in a pseudonymised format with marketing partners who help us with promotional efforts and with advertisers or sponsors that allow us to offer a free service.

Academic Researchers: We may share your personal data for activities such as statistical analysis and academic study but only in anonymised or pseudonymised format.

Promote safety, integrity and security: We also reserve the right to disclose your data or other information that we believe, in good faith, is appropriate or necessary to protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of our products and services or protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

Change of Ownership: Data about users and visitors, including personal data, may be disclosed and otherwise physically or electronically transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the user or visitor data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

TRANSFERRING YOUR DATA

In principle, we store the personal data that we hold about you in the European Union (“EU“). However, since some of our service providers are based in countries outside of the European Union (“third countries”), personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such circumstances, Flaner shall ensure that the transfer of your personal data is performed in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

HOW LONG WE KEEP YOUR DATA

We keep your information only as long as necessary to provide Flaner products and services to you, fulfilling the purposes described in this policy, and for essential business purposes, such as making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.

We keep some of your personal data for as long as you are a user of the Flaner products and services. For example, we keep your places, Placelists, and account information.

This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your personal data and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that it can't be used to identify you. 

If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data.

CHOICES AND RIGHTS YOU HAVE

Our goal is to give you simple and meaningful choices and control regarding your data. If you have a Flaner account, many of the choices you have on Flaner are built directly into our products and services. For example, you can:

In compliance with the GDPR, every Flaner user has the right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to contest or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. If you wish to access an account of a deceased relative, family or friend, please send us your request to privacy@flaner.com. You will make our decision process easier, if you attach to your e-mail all the relevant and adequate information that sustains your request.

Your rights in respect of your personal data are:

Right of Access - the right to be informed of and request access to the personal data we process about you.

Right to Erasure - the right to request that we delete your account and your personal data.

Right to Rectification - the right to the correction of inaccurate or incomplete personal data. You can update your information in your settings. If you have problems updating the information or if you would like us to delete it, contact us.

Right to Object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation by asking us to delete your account. The right to object to your personal data being processed for direct marketing purposes.

Right to Restrict - the right to restrict the processing of your personal data: (i) for the period needed to verify the accuracy of the personal data, when you have contested the accuracy; (ii) if the processing was unlawful and you oppose to the erasure of your personal information; (iii) when Flaner no longer needs the information for the performance of the service, but you request us to retain it for the establishment, exercise or defense of legal claims; or (iv) if in your opinion our legitimate interests for processing the information, do not override your interests, for the period needed to review our position.

Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.

Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

In some cases, the exercise of your rights may hinder Flaner form delivering you the Service and you will may have to delete your account for an affective exercise of your right.  We will always notify you in these cases and let you decide.

If you would like to exercise any of those rights, contact us via privacy@flaner.com from the email address you used to register with Flaner and let us have enough information to identify you and specify your request.

HOW WE KEEP YOUR DATA SAFE

We are committed to protecting and respecting our users’ personal data and have appointed a Data Protection Officer that conveys our commitment towards your privacy rights. We implement appropriate technical and organisational measures designed to protect your data in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. However, please note that, given the nature of communications and information processing technology, no system is ever completely secure. Be aware, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.

LINKS TO THIRD PARTS

As part of our product and services, we may provide links to other sites. Any information you provide on those sites is provided directly to the owner of that site and is subject to that party’s privacy policy. Our privacy policy does not apply to such sites, and we are not responsible for the content or privacy and security practices and policies of those sites. We encourage our users to read the privacy statements of other websites before proceeding to use them.

AGE OF OUR USERS

Anyone under the age of 16 years is not allowed to use Flaner. If you are based in the EEA, you may only use Flaner if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of Flaner has been provided to us. If you are a parent and you learn that your child is using Flaner and you don't want them to, please contact us at privacy@flaner.com.

CHANGES TO THIS POLICY

We may change this Privacy Policy from time to time. Laws, regulations and our products and services evolve, which may make those changes necessary. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed.

If we make changes that materially alter the way we use your data, Flaner will provide additional notice, by posting an announcement on our Products and Services (including our apps) and/or by sending you an email (if you have informed one).

If you disagree with the changes to this Privacy Policy, you should deactivate your Flaner account. Write to us at privacy@flaner.com if you wish to request the removal of personal data under our control and delete your account.

DATA CONTROLLER AND DATA PROTECTION AUTHORITY

Flaner LDA (whose registered office is at Rua Vitor Cordon, no 10-A, 5o 1249-202 Lisboa, Portugal) is committed to protecting and respecting your data as a data controller. If you are a resident of the European Economic Area and believe we maintain your personal data within the scope of the GDPR, you may direct questions or complaints to our lead supervisory authority:

Comissão Nacional de Protecção de Dados
(‘National Commission for the Protection of Data’, also known as ‘CNPD’).
Rua de São Bento n°. 148, 3°
1200-821 Lisbon - Portugal

Phone: +351 21 392 84 00
Fax: +351 21 397 68 32
Email: geral@cnpd.pt
www.cnpd.pt

HOW TO CONTACT US

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer at privacy@flaner.com or by writing to us at

Flaner LDA.
Rua Vitor Cordon, no 10-A, 5o 1249-202 Lisboa
Portugal

We hope you enjoy Flaner!

© Flaner LDA.