1. Within this Notice
   1. ‘Company’ means Flostream Ltd. Mailing Services and Fulfilment House, Unit 2 Blackthorne Point, Blackthorne Road, Colnbrook, SL3 0DA.
   2. The visitor/user of the Website is referred to as ‘you’ or ‘Your’.
   3. ‘Personal Data’ means any information from which you can be personally identified, including online identifiers like email address and I.P address (a digital address which identifies the device you access the internet with).
   4. ‘Website’ means https://www.flostream.co.uk
2. The Company is a Data Controller under Data Protection Regulations and is committed to safeguarding the privacy of visitors to the Website.
3. This Notice is to ensure that you have all the information regarding how the Company may collect and process your Personal Data when using the Website and to comply with our obligations and your rights created by applicable law.
4. Using the Website will be accepted as an affirmative action by you to confirm that you are over 13 years of age and agree to this Privacy Notice. If you are under 13 years of age or do not agree with anything within in this Privacy Notice, you should not use the Website.
5. The Company takes pride in keeping up to date with advances in technology and legal developments, this can result in changes to this Privacy Notice so you should refer to them on a regular basis to ensure that you are aware of our policies that are current at the time of your visit to the Website.
6. You can be assured any Personal Data will only be collected, processed and stored in accordance with this Privacy Notice.

Your Personal Data

7. Personal Data is defined as any data from which (either on its own or when combined with other data) you can be personally identified.
8. We will not gather, collect, process or store any Personal Information except –
   1. with a lawful purpose as provided in Data Protection Regulations;
   2. that processing is necessary for the purpose that it was collected, for example
      • to deal with an enquiry from you;
      • to take the necessary steps to enter into a contract with you;
      • for the performance and administration of a contract;
      • for the recording of a financial transaction.
      • for internal records that we are legally obliged to keep;
      • to deal with complaints, disputes and legal actions;
      • where necessary to protect the vital interest of you or another person;
      • to send commercial communications from us (including the availability of new Products, special offers and discounts, newsletters, notifications), where you request or consent to such communications or in some circumstances you do not inform us that you do not want to receive such communications;
      • To send commercial communications from selected partners, associates or affiliates only where you expressly request or consent to such communications.
9. If you Contact Us during or after your use of the Website to make an enquiry, we will need to collect and process your name, company/business name, telephone number or email address.
10. This Personal Data is processed
    1. for a legitimate interest in order that the Company can respond to your enquiry or provide the requested information;
    2. with your consent to send newsletters or notifications, where you request or permit such communications.
11. If a third party is used to process or store your Personal Data who is based outside the EU we will ensure that the third party meets standards in relation to the security of your Personal Data which are consistent with Data Protection Regulations, for example a third party based in the U.S.A must subscribe to the EU-US Data Privacy Framework. Any third Party who is not based in a country that provides or meets the recognised standards the third party will be subject to the model contract provided by the European Commission.
12. The Company does not use automated processing of your Personal Data to form or make decisions.
13. The Company will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of Personal Data, including storing of data on a secure, password and firewall protected servers.
14. In the event of a breach of the security measures taken to protect your Personal Data the Company will inform you as soon as is reasonably practical.
15. In order that the Company is able to provide you with an optimum service and to ensure that all obligations under UK Data Protection legislation are complied with, you must let the Company know if any Personal Data which you have provided changes or becomes inaccurate or out of date.

Advertisements

16. The Company may permit third parties to advertise on the Website. These third parties may use tracking features to enable them to record the number of views, clicks and the referral source.
17. If you visit an advertiser’s website they will have their own Privacy Notice which you should read and accept.

Sharing your Personal Data

18. The Company may share your Personal Data with our employees, officers, agents, consultants, suppliers or subcontractors only insofar that it reasonably necessary
    1. in order to deal with an enquiry or to provide requested information;
    2. to consider whether to enter into a contract with you;
    3. for the performance of a contractual obligation between you and the Company;
    4. under a legitimate interest that is stated within this Privacy Notice;
    5. required by Law or order of a Court;
    6. necessary for the prevention of fraud or other criminal activity;
    7. for the purposes of establishing, exercising or defending legal rights;
    8. required to by a purchaser in the event of selling the Company;
    9. otherwise with your consent, request or instruction.

Data retention

19. Except where an enquiry progresses into a contract to provide services; or you request or consent to receiving commercial communications; or required by law; or for the purposes of exercising or defending a legal right; the Company shall not normally retain your Personal Data for more than six months.

Non-Personal Information

20. Like most other websites, the Company uses analytical software to gather and collect anonymous information (from which you are not personally identifiable) whilst you browse the Website.
21. This includes information about the device and software that you use to access the Website including the geographical location (Country) of the server used for access, browser type, pages viewed, length of visit and referral source (how you arrived at our Website).
22. This anonymised information is collected by third party processors helps us to generate reports to monitor usage and performance of the Website, identify errors, analyse and maintain the security of the Website and trace inappropriate or malicious use, monitor trends, and enables us to maintain a Website that is user friendly and compatible with popular equipment and software.

Your rights

23. Data Protection Regulation provides you with rights in relation to your Personal Data.
24. The Company shall not normally make a charge where you exercise your rights, however where a request is manifestly unfounded or excessive (for example it is a repetitive request, or where the Company needs to process large amounts of data) the Company may make a charge for reasonable administrative costs in dealing with the request.
25. As the Company takes the issue of protecting your Personal Data seriously, the Company shall follow strict storage and disclosure procedures which mean you may occasionally be required to confirm or provide proof of identity prior to dealing with a request.

Withdraw consent

26. Where processing of your Personal Data is based on your consent you may withdraw your consent at any time by informing the Data Controller or by using a link provided for that purpose in each commercial communication that the Company sends.
27. Upon receipt of a notice withdrawing your consent to process your Personal Data the Company shall stop processing the Personal Data except:
    1. where there are compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or
    2. the processing is for the establishment, exercise or defence of legal claims.
28. Where you withdraw consent the Company shall inform all third parties who your Personal Data has been shared (if any) that your consent to processing has been withdrawn.

Restrict processing

29. The Company shall restrict the processing of your Personal Data if the following circumstances arise
    1. Where you contest the accuracy of the Personal Data, the Company shall restrict the processing until the accuracy of the Personal Data has been verified.
    2. Where you have objected to the processing where it was necessary for the performance of a public interest task or purpose of legitimate interests, and the Company is considering whether the legitimate grounds override your grounds.
    3. When processing is unlawful and you opposes erasure and you request restriction instead.
    4. If the Company no longer needs the Personal Data but you require the information to establish, exercise or defend a legal claim.
30. Where processing of your Personal Data is restricted, the information shall be stored but no further processing shall occur and the Company shall
    1. inform any third party to whom your Personal Data has been disclosed or shared that processing is restricted;
    2. inform you when any restricted period comes to an end.

Access to Personal Data

31. You may require the Company to provide you with
    1. Confirmation whether or not your Personal Data is being processed; and
    2. Access to any Personal Data that the Company holds about you.
32. These requests are commonly known as a Subject Access Request, or SAR.
33. A SAR can be made at any time and in any format, it does not need to be in writing as long as it is clear that you are requesting your Personal Data.
34. The Personal Data will be provided free of charge except where a request is manifestly unfounded or excessive (for example it is a repetitive request, or where the Company needs to process large amounts of data) in which case we may make a charge for reasonable administrative costs in dealing with the request or refuse to respond but we must provide a justifiable reason for refusing to respond.
35. We shall search our systems and files for any file or document which contains your Personal Data and provide a copy to you within one month of receipt of the request, however where there is a substantial amount of information or it is difficult to collate we may extend this time frame by one month by providing you notice.
36. Where Personal Data is stored electronically we may make arrangements which allow you to access the data via a secure connection to an electronic file.
37. We take the issue of protecting your Personal Data seriously and may require proof of identity from you prior to disclosing such information.

Data Portability

38. Any Personal Data that you provide for the performance of a contract which is stored electronically shall be held in a portable format (readable in a format that will be commonly used on other computer systems) and the Company shall provide this Data to you or directly to another organisation (where technically feasible) upon your request.

The right to rectify errors

39. Where any Personal Data that is processed is inaccurate or incorrect you have the right to instruct the company to correct the Personal Data.
40. The Company may, where the Company believes that the Personal Data is correct ask you for evidence to clarify or confirm that the Personal Data is wrong.

Right to erase Personal Data

41. You have the right in certain circumstances to instruct the Company to erase your Personal Data where
    1. The Personal Data is no longer necessary for the purpose for which it was originally collected or processed.
    2. The Personal Data was processed with your consent and you withdraw your consent.
    3. You object to the processing and there is no overriding legitimate interest for continuing the processing.
    4. The Personal Data was unlawfully processed or obtained.
    5. The Personal Data has to be erased in order to comply with a legal obligation.
    6. The Personal Data is processed in relation to the offer of information services to a child.
42. Where you have the right and you issue an instruction to erase your Personal Data the Company shall use all reasonable efforts to
    1. Inform all third parties to whom the Company has disclosed or shared your Personal Data of the requirement to erase your Personal Data which they hold;
    2. In the event that your Personal Data has been published online the Company shall endeavour to ensure that any links or references are also removed;
43. The Company may refuse to erase your Personal Data only
    1. the processing is necessary for the performance of a contract;
    2. to exercise the right of freedom of expression and information;
    3. to comply with a legal obligation;
    4. the processing is for the performance of a public interest task or exercise of official authority;
    5. for public health purposes in the public interest;
    6. archiving purposes in the public interest, scientific research historical research or statistical purposes; or
    7. the exercise or defence of legal claims.
44. You can exercise any of your rights by contacting the Data Controller at Flostream Ltd. Mailing Services and Fulfilment House, Unit 2 Blackthorne Point, Blackthorne Road, Colnbrook, SL3 0DA.

Complaints

45. You can make a complaint about our processing of your Personal Data by contacting the Data Controller at Flostream Ltd. Mailing Services and Fulfilment House, Unit 2 Blackthorne Point, Blackthorne Road, Colnbrook, SL3 0DA
46. If you have cause or reason to make a complaint about any aspect of our collection, usage, processing, storage, or retention of your Personal Data you can do so by contacting us in any way you chose and making it clear your communication is a compliant.
47. Methods of communication include by telephone, or email, or post, or using a specific ‘contact us’ form (if available). All contact details are available on the Website, it will help if you address the complaint to the IT Manager but if you do not it should not delay your complaint.
48. When submitting a complaint you should include
    1. your name and contact details or if you are complaining on behalf of another person your name and contact details, the name of the Data Subject and a written confirmation that you have the authority to act for and on behalf of the Data Subject;
    2. the details of your complaint;
    3. any documents or evidence to support or help to explain your complaint (these can be provided at a later date if you are making the complaint verbally);
    4. the remedy you are seeking;
49. We will aim to acknowledge receipt of your complaint in writing within 5 days.
50. We may ask for confirmation of your identity ensure that we do not disclose or discuss any of your personal data with anyone except you or a person authorised to act on your behalf.
51. We may ask for more information or documents to clarify or help us to understand your complaint.
52. We will consider and investigate your complaint and let you know the outcome within 30 days, if it is not possible then we will contact you and let you know when you can expect a full response.
53. If you are not satisfied with the outcome you can ask us to review our decision by explaining what you believe we misunderstood or got wrong.
54. If you are not satisfied with the outcome you can make a complaint to the Information Commissioners Office at https://ico.org.uk/make-a-complaint/data-complaints-complaints/