Flux Medical Systems BV (“Flux,” “we,” “our”) offers an Health Management System (HMS) available online, including via a mobile application (collectively, the “Service”), and websites, including but not limited to www.joinflux.nl (the “Websites”). As you interact with the Websites, Flux collects and processes information from and about you in order to provide you with access to the Service, enhance your experience while using the Service, and interact with you.
References to “Flux” throughout the Policy means that Flux as an entity acts as the data controller of your information, as explained in more detail below. If you do not agree with this Policy, please do not use the Websites, or any other part of Flux’s business.
Flux is located at Molengraaffsingel 12 B3 1.14, 2629 JD Delft, the Netherlands. If you have any questions about this Policy, please email us at firstname.lastname@example.org.
Flux Site Privacy Terms
If you visit the Websites, regardless of whether you are also a user of the Service, the following rules apply to you. To eliminate any confusion, please note that the terms in this section apply only to use of Flux’s Websites, not to use of the Service. If you are a Site Visitor located in the European Union, Flux is the data controller with respect to the processing of your personal data pursuant to the EU General Data Protection Regulation (“GDPR”).
Collection and Use of Site Information
- When you use the Websites, we collect the following information about you:
- Contact Information. If you submit a request for information or a question through the Websites, you may be asked to provide us with basic information including your name, email address, phone number, and postal address. We will also keep records of the communication, the question/request you raised, and how it was resolved. If you choose to participate in a Flux sweepstakes, contest, or research study offered through the Websites, we will also collect basic contact information from you in connection with such activity.
- Websites Usage Information. As you browse the Websites, we and our service providers (which are third party companies that work on our behalf to provide and enhance the Websites) use a variety of technologies, including cookies and similar tools, to assist in collecting information about how you use the Websites. For example, our servers automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Websites, domain names, landing pages, pages viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the Websites, date and time stamp information and other such information.
- Location Information. We collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).
Cookies and Similar Technologies
- To collect the Websites Usage Information discussed above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. A web server log is a file where website activity is stored. An SDK is a section of code that we embed in our applications and software to allow third parties to collect information about how users interact with the Websites. A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to:
- (I) recognize your computer and login session;
- (II) store your preferences and settings;
- (III) understand which pages of the Websites you have visited;
- (IV) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests;
- (V) perform analytics; and
- (VI) assist with security and administrative functions.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, email open rates, measure popularity of the Websites and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).
Use of Information Collected from Site Visitors
- We use the information collected from Site Visitors for a variety of purposes including to:
- (I) maintain, provide, and improve the Websites and the Service;
- (II) respond to your requests for information;
- (III) in accordance with applicable legal obligations, communicate with you about promotions, offers, and news about Flux. You have the ability to unsubscribe from such promotional communications;
- (IV) prevent or address technical or security issues;
- (V) investigate in good faith alleged violations of our User Terms of Service;
- (VI) help us better understand Site Visitor interests and needs, and customize the advertising and content you see on the Websites; and
- (VII) engage in analysis and research regarding use of the Websites and the Service.
- If you are located in the EU, please note that the legal bases under the GDPR for using the information we collect through your use of the Websites as a Site Visitor are as follows:
- (I) where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the User Terms of Service which you accept by browsing the Websites);
- (II) where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Websites; operate our Websites; prevent fraud, analyze use of and improve our Websites, and for similar purposes);
- (III) where use of your information is necessary to comply with a legal obligation; and
- (IV) where we have your consent to process data in a certain way.
We may aggregate and/or de-identify information collected through the Websites so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
You agree that, for the purposes discussed in this Policy, we may combine the information that we collect through the Websites with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy. If, however, the collection of any information about you is governed by a Subscriber Agreement, information will only be combined and used in accordance with such Subscriber Agreement and the sections of this Policy applicable to Subscribers.
Analytics and Advertising
We may use third-party web analytics services on our Websites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.
Notice Concerning Do Not Track (“DNT”)
DNT is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Websites for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.
Sharing of Site Information
- We share the information we collect through the Websites with the following:
- Affiliates and Subsidiaries. We may share the information we collect within the Flux family of companies.
- Service Providers. We may provide access to or share your information with select third parties that use the information only to perform services on our behalf. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, and other services.
- Business Transfers. If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Flux will comply with such restrictions.
- Public Forums. The Websites may make it possible for you to upload and share comments or feedback publicly with other users, such as on a Flux community forum. Any information that you submit through such public features is not confidential, and Flux may use it for any purpose (including in testimonials or other Flux marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Such information can be read, collected and/or used by other users, and it could be used to send you unsolicited messages. Accordingly, please take care when using these features of the Websites.
- Consent. We may also disclose your information to third parties with your consent to do so.
Retention of Your Information
We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
Data Subject Rights
- EU legal requirements may afford you additional rights. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Flux Contact Info” section below at any time. EU laws may permit you to request that we:
- (I) provide access to and/or a copy of certain information we hold about you;
- (II) prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
- (III) update information which is out of date or incorrect;
- (IV) delete certain information which we are holding about you;
- (V) restrict the way that we process and disclose certain of your information;
- (VI) transfer your information to a third party provider of services; and
- (VII) revoke your consent for the processing of your information.
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
Third Party Links And Services
The Websites may contain links to third-party websites and functionalities. If you choose to use these third party services, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Because these third-party websites and services are not operated by Flux, Flux is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third-parties.