FindMyFlow Platform & Website Privacy Policy

Effective date: 1 November 2024

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Overview

At FindMyFlow, we’re committed to taking a transparent and responsible approach to handling your personal data. We respect and value the privacy of everyone who interacts with our website, contacts us, or uses our eLearning platform. We will never sell your Personal Data to third parties.

This policy's primary purpose is to ensure FindMyFlow complies with information disclosure obligations under data protection legislation. It explains how and why we use your personal data, and outlines your privacy rights.

Changes to this policy

FindMyFlow may change this Privacy Policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. We will update the ‘effective date’ at the top of the page whenever changes are made.

General Data Protection Regulation (UK GDPR)

FindMyFlow is based in the UK and must comply with Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR) when processing personal data. Under UK GDPR legislation, FindMyFlow is identified as a Data Controller.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases and your rights on the website of the UK Information Commissioner’s Office (ICO).

FindMyFlow’s basis for collecting and using the personal information depends on the Personal Information we collect and the specific context in which we collect the information:

🔹FindMyFlow needs to perform a contract with you, or organisation acting on your behalf (employer, higher education provider, or a government scheme such as Disabled Students Allowance [DSA])
🔹You have given FindMyFlow consent to do so
🔹Processing your personal information is in FindMyFlow’s legitimate interests
🔹Legal and regulatory compliance

Personal data we collect and process

The kind of personal data we collect from you varies based on how and where you interact with us. The headings below provide more detail, including how and why the data is collected.

FindMyFlow and FindMyFlow Pro Website

Please check our Cookie Policy to see what information we may collect.

FindMyFlow Platform

When you sign up to use the FindMyFlow eLearning platform, we ask you to provide the following information:

🔹Name and surname
🔹Email address
🔹The name of your University, College, or Workplace
🔹Your course subject area, and start and end date of your course
🔹Information about assistive technology software you use
🔹(Optional) information about your level of knowledge about Assistive Technology, and about your study priorities

FindMyFlow Pro Platform

When you sign up to use the FindMyFlow Pro eLearning platform, we ask you to provide the following information:

🔹Name and surname
🔹Email address
🔹Information about assistive technology software you use
🔹(Optional) information about your level of knowledge about Assistive Technology

FindMyFlow online event attendees & social media users

When you interact with our website, engage with us on social media, or attend an online meeting or webinar hosted by FindMyFlow we may collect the following information about you:

🔹Name and surname
🔹Email address
🔹Job title
🔹The name of your University, College, or Workplace
🔹Your response to any feedback forms
🔹Only with your explicit consent, we may also contact you via email for marketing purposes

Why we process personal data

We use the information you provide to understand your needs and provide you with a better service, and in particular for the following reasons:

🔹Internal record keeping
🔹Contractual performance, such as sending account confirmation emails, password reminder emails, or other necessary transactional emails.
🔹To provide you with technical support
🔹To identify popular content and develop new content for specific user groups.
🔹We may collect and analyse usage information that may include when your account was first activated, when you were last active, the number and identifier of Flows, Modules, Chapters, and Steps viewed, the number of Notes added, the number of Reflective Journal entries added, the Steps added to Favourites, Progress Data and Achievements Data.
🔹We may use the information you provide on your University or Workplace to count how many users we have at each institution. We may use this information to develop our product and services.
🔹Only with your explicit consent when you opt-in via this website, we may periodically send promotional material about new features, content, or other information which we think you may find interesting using the email address which you have provided.
🔹Only with your explicit consent when you opt-in via this website, from time to time we may also contact you via email for product- or market-research purposes.

We do not analyse the following information

We do not export, analyse, share or otherwise use any content you create within FindMyFlow platform. This includes:

🔹Notes
🔹Reflective Practice Journal entries.
🔹Any future features that may contain user-created content not already identified above

Such data would be accessed by us only to fulfil a specific request from you, or in order to perform debugging or other urgent technical work to identify and repair errors that impact intended functionality or your user account.

Does FindMyFlow share my Personal Data?

We want to reiterate that we respect and value your privacy, and FindMyFlow will never rent or sell your personal data. No personal data is made publicly available on our Website or Platform. The content you create, such as Notes in our Platform, is not made available to others.

There are instances when we'll need to share your personal data with other parties. In these instances we will share only the minimum amount of data necessary for legitimate business or contract purpose. We'll describe these here:

🔹We may share your data with trusted third-party service providers that process personal data on our behalf (our ‘Third-Party Data Processors’).
🔹Where you've purchased access to our platform through a reseller, we may share limited personal data with the reseller to make sure that payment for and access to the platform have been completed correctly and successfully.
🔹Where your access to the platform is provided by your organisation, we may share individual or generalised usage data with your organisation, including when you last visited the Platform. This data sharing forms part of our agreement with your organisation.

In the Event of a Change of Control:

In the event of a merger, sale, acquisition, reorganisation, or similar transactions or proceedings involving all or parts of our business, data covered by this Privacy Policy may be transferred in connection with that business event. You will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Data Security

FindMyFlow is committed to safeguarding the confidentiality, integrity, and availability of your personal data. We have put in place physical, technical, and managerial processes to safeguard your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed when it shouldn't be.

We store your data on secure third party servers within the UK. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot warrant the absolute security of any information you transmit to FindMyFlow, or guarantee that your information on the FindMyFlow website / platform will not be accessed, disclosed, altered or destroyed by breach of our physical, technical, or managerial safeguards. We will promptly notify you and any applicable regulatory body of a breach where we are legally required to do so.

Data retention and right to erasure

When you create your FindMyFlow account, you have control over the data you create. This data may include notes, reflective practice journal entries, favourites, achievement badges, linked access history, or any and other features that may be introduced by FindMyFlow platform from time to time. If you wish to delete this data, you can delete your FindMyFlow account; this will remove all user-generated data. Depending on your FindMyFlow licensing arrangement, for compliance and contractual reasons, we may need to retain data associated with your Licence Key for 5 years and any invoice records for 7 years.

In some circumstances, we may completely anonymise your personal data (so that it can no longer be linked to you) for research or statistical purposes, or to help us to keep improving our platform and services. In these cases, we may use this data indefinitely without having to keep communicating with you about it.

If you require further information on retention periods for your personal data, please contact us by email at contact@findmyflow.co.uk.

Sharing information outside the UK

FindMyFlow and our Third Party Processors currently process all personal data in the UK and European Economic Area (EEA).

As a software company that provides services globally, we may transfer, store and process your personal data with third-party service providers based outside of the country in which you're based. Laws in those countries might be different from the laws of the country where you live. Where we transfer, store and process your personal data outside of the UK or EEA, we'll make sure that the appropriate safeguard is in place to protect your personal data. These safeguards include:

🔹Where appropriate, we'll work with third-party providers based in the UK or EEA, or, that are deemed to provide an adequate level of protection for personal data by the European Commission and UK Information Commissioner's Office (ICO).
🔹Where we need to work with providers based outside of the UK, EEA or other approved adequacy country, we'll make sure that we have a Data Processing Agreement in place with the third-party provider.

Links to other websites

Our website, platform and services may provide links to websites and services provided by third parties. Any information you provide on third-party websites, apps, or services is provided directly to the operators of those websites, apps, or services, and is subject to their policies governing privacy and security, even if accessed via our website or in connection with our services.