PRIVACY POLICY

FloStack website privacy policy

Revision Date: Sep 29th, 2023

LeadSquared, its affiliates and subsidiaries (“we,” “us,” “our”), thank you for using our service – FloStack. This Privacy Policy aims to inform you about the collection, use, and disclosure of personal information when you use the FloStack website, software, and services, collectively referred to as the”Service.” We are committed to protecting your privacy and ensuring compliance with relevant data protection laws in the countries we operate in.

Google API Disclosure
FloStack’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

As a business service, we neither target our Services toward nor knowingly collect any personal information from any individuals under the age of 13. By accessing this Website, you represent and warrant that you are 13 years of age or older. If you are under the age of 13, please do not use the Website without the supervision of a responsible adult.

Article 1 – DEFINITIONS:
a) REVISION DATE: “Revision Date” means the date this Privacy Policy (“Policy”) was last updated on. We may change or update this policy at any time, and the same will be updated here.
b) PARTIES: The parties to this privacy policy are the following data controller: Virupi Labs, a Firm incorporated under the laws of India, and all related entities including FloStack Inc., a Delaware Corp (“Data Controller”) and you, as the user of the FloStack platform or Website. Hereinafter, the parties will individually be referred to as “Party” and collectively as “Parties.”
c) DATA CONTROLLER: Data Controller is the publisher, owner, and operator of the FloStack Platform and Website, and is the Party responsible for the collection of information described herein. Data Controller shall be referred to either by Data Controller’s name or “Data Controller,” as listed above. If Data Controller or Data Controller’s property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, FloStack, etc.
d) YOU: Should you agree to this Privacy Policy and continue engaging with FloStack, you will be referred to herein as either you, the user, or if any second-person pronouns are required and applicable, such pronouns as ‘your”, “yours”, etc.
e) SERVICES: “Services” means any services that FloStack offers, including but not limited to, the FloStack platform, which you may engage with as a customer or a user, and the website, which you engage with as a visitor.
f) CUSTOMER, USER, VISITOR: Your personal data relationship with FloStack varies based on the capacity in which you interact with us/avail of our products and solutions (“Services”). You could be: (i) a visitor to flostack.io (“Website”) or any pages thereof (“Visitor”); (ii) a person/entity availing of one of our Services (“Customer”); or (iii) an employee/agent/representative/appointee of a Customer who uses the said Service (“User”)
g) PERSONAL DATA: “Personal DATA” means personal data and information that we obtain from you in connection with your use of the Website that is capable of identifying you in any manner.​​

Article 2 – GENERAL INFORMATION:
a. This privacy policy (hereinafter “Privacy Policy”) describes how we collect and use the Personal Data that we receive about you, as well as your rights in relation to that Personal Data, when you visit our Website or use our Services. This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Services. The Website may link out to other websites or mobile applications, but this Privacy Policy does not and will not apply to any of those linked websites or applications.

b. We are committed to the protection of your privacy while you use our Services. By continuing to use our services, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of our Services.

c. This Policy details the critical aspects governing your personal data relationship with the FloStack platform which is owned and operated by MarketXpander Services Private Limited, a company incorporated under the laws of India, and having its registered office at #33, Sector 6, H S R Layout, Bangalore – 560 102, Karnataka, India and shall include its affiliates;

d. Your personal data relationship with LeadSquared varies based on the capacity in which you interact with us/avail of our products and solutions (“Services”). You could be:

(i)        a visitor to our website flostack.io, (“Website”) or any pages thereof (“Visitor”);

(ii)        a person/entity availing of one of our Services (“Customer”);or

(iii)       an employee/agent/representative/appointee of a Customer who uses the said Service (“User”);

e. Based on whether you are a Visitor, Customer or User, the type of data we collect and the purpose for which we use it will differ and this Policy details such variations;

f. This Policy is a part of and should be read in conjunction with our Terms of Service (https://www.flostack.io/terms-of-use), and

g. This Policy will clarify the rights available to you vis-à-vis the personal data you share with us.

If you have any queries or concerns with this Policy, please contact us at the details mentioned in Section 12 below. If you do not agree with the Policy, we would advise you to not visit/use the Website or the FloStack application(s)/platform(s) (collectively “Platform”).


Article 3 – CONTACT AND DATA PROTECTION OFFICER:
The Party responsible for the processing of your personal data is as follows: Virupi Labs, and all related entities including FloStack Inc.
The Data Controller may be contacted as follows:-
support@flostack.io
The Data Controller and operator of the Website are one and the same.The Data Protection Officer is as follows: Vikram Patil. The Data Protection Officer may be contacted as follows:
vikram@flostack.io


Article 4 – LOCATION:
Please be advised the data processing activities take place in the United States, outside the European Economic Area. Data may also be transferred to companies within the United States, but will only be done so in a manner that complies with the EU’s General Data Protection Regulation or GDPR. The location where the data processing activities take place is as follows: Oregon, United States


Article 5 – MODIFICATIONS AND REVISIONS:
We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.


Article 6 – THE PERSONAL DATA WE RECEIVE FROM YOU:
Depending on how you use our Website, you will be subject to different types of Personal Data collected and different manners of collection:

(i) Visitor:

What data we may collect: Your IP Address; Your location; How you behave on the Website, (what pages you land on, how much time you spend, etc.); What Device you use to access the Website and its details (model, operating system, etc.); Cookies and Web Beacon data; and Data from third parties who have your explicit consent to lawfully share that data.

If you submit an inquiry through the Website, we will ask for your: Name; and e-mail.

How and why we use it: We use this information to analyse and identify your behaviour and enhance the interactions you have with the Website. If you submit your details and give us your consent, we may use your data to send you e-mails/newsletters, re-target FloStack advertisements or re-market our Services using services from third-parties like Facebook and Google.

(ii) Customer:

What data we may collect: The name and e-mail of your representative who signs up for a Service on your behalf; and Credit Card/Debit Card/Other Payment Mode information to check your financial qualifications, detect fraud and facilitate payments for our Services.

How and why we use it: We collect this data in order to help you register for and facilitate provision of our Services. We also use this data to enable you to make payments for our Services. We use a third-party service provider to manage payment processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of payment processing on our behalf.

If you give us your consent, we may send you newsletters and e-mails to market other products and services we may provide.

(iii) User:

What data we may collect: Your name, e-mail; Your IP Address; Your location; How you behave in the relevant product environment and use the features; What device you use to access the Website/App and its details (model, operating system, etc.); Cookies and Web Beacon data; Data from third parties who have your explicit consent to lawfully share that data

How and why we use it: We collect this data in order to facilitate provision of our Services. We will occasionally send you e-mails regarding changes or updates to the Service that you are using. If you give us your consent, we may send you newsletters and e-mails to market other products and services we may provide. We may also conduct anonymized usage behaviour analysis at the aggregate level to determine how the features of a particular Service are being used.

WHAT ARE THE COOKIES AND WEB BEACONS REFERRED TO ABOVE?

(i) Cookies: Cookies are text files which are sent from our server and downloaded to your Device when you visit our Website.They are useful because they allow us to recognize your Device when you return. You can disable them through your browser should you so wish.

You can find more information about cookies at: www.allaboutcookies.org

(ii) Web Beacons: Web Beacon (also known as Clear GIF, Web Bugs or Pixel Tag) is a tiny picture file embedded on the Website/App that tracks your behaviour and navigation. It is similar to a cookie in what it does, but it doesn’t get downloaded on to your Device.You can find more information about Web Beacons at: http://www.allaboutcookies.org/faqs/beacons.html

– What Cookies and Web Beacons won’t do?

Harvest any personally identifiable information; or Contain any executable software, malicious code or virus.

FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW.

Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time by emailing us at privacy@leadsquared.com

Accordingly, the grounds on which we can engage in processing are as follows:

(i) Visitor Data: Consent; Performance of a Contract; and Legitimate Interest

(ii) Account Registration Data: Performance of a Contract; and Legitimate Interest

(iii) Payment Data: Performance of a Contract; Compliance with applicable laws; and Legitimate Interest

(iv) Service Usage Data: Performance of a Contract; and Legitimate Interest

(v) Data for Marketing our Services: Consent; and Legitimate Interest

Article 7 – YOUR RIGHTS AS A DATA SUBJECT

In accordance with the requirements of the California Consumer Privacy Act (CCPA), you may have the following rights:

(i) Right to Know

You have the right to know about the personal information we have collected from you and the manner in which we use and share this information

(ii) Right to Notice

You have a right to be informed at or before the point of collection what categories of personal information will be collected and the purposes for which these categories will be used which we have endeavoured to do by way of this Policy

(iii) Right to Correct

You  have a right to request us to amend or update your personal data if it is  inaccurate or incomplete.

(iv) Right to Delete

You have the right to request us to delete the personal information we hold about you, subject to certain restrictions.

Please note that we may have legal obligations to preserve certain data which could prevent us from deleting certain data.

(v) Right to Opt out of sale or sharing of data

You have the right to opt-out of us sharing your personal information. We do not sell any data of our users/customers/leads.

(vi) Right to Limit

You have the right to direct us to use your sensitive personal information only for limited purposes

(vii) Right to Non- Discrimination

We assure no discrimination against consumers exercising their right of privacy under CCPA

In case you want to exercise any of the rights set out above you can reach us at privacy@leadsquared.com. If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may lodge a complaint with your local supervisory authority. The data provided by you as a Visitor, or when you sign up as aCustomer / User or register for our Services will be processed by us for the purpose of rendering Services to you or in order to take steps prior to rendering such Services, at your request. You can choose to withdraw this consent at any time, by reaching us at privacy@leadsquared.com

Additionally, please note:

If you are a Customer/User using one of our Services to collect data about a data subject from third-parties, it shall be your sole obligation to inform such data subject about the source of such data in accordance with applicable law.

Article 8 – THIRD PARTIES:
We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or all the time, to help serve you.

We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy.

We may use Third-Party Service Providers to assist with information storage (such as cloud storage).

We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, our Services.

We may use Third-Party Service Providers to host the Website. In this instance, the Third-Party Service Provider will have access to your Personal Data.

Your Personal Data will not be sold or otherwise transferred to other third parties without your approval.

Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or to third parties in order to protect the rights, property or safety, of us, our customers or third parties, or as otherwise required by law.

We will not knowingly share your Personal Data with any third parties other than in accordance with this Privacy Policy.

If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information.

In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.​

Article 9 – HOW PERSONAL DATA IS STORED:
We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data (such as a credit card number or your geo-location), it is encrypted using industry-standard cryptographic techniques including but not limited to SSL,TLS, RSA, and AES.

Your password is your first line of defense once you set up a FloStack account, so we recommend that you set a strong password which you never share with anyone and ensure you sign out of your FloStack account once you have used the same.

Retention:

a. We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes –these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes.

b. We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements.

c. If you are a Customer, please be advised that: (i) you will need to inform your users about how you store and deal with any data you collect from them using one of our Services, in compliance with applicable laws including the CCPA; and (ii)after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you (including user information) from our servers.

Article 10 – DISCLOSURE OF PERSONAL DATA:
Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:
a) To satisfy any local, state, or Federal laws or regulations
b) To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies
c) To bring legal action against a user who has violated the law or violated the terms of use of our Website
d) As may be necessary for the operation of our Website
e) To generally cooperate with any lawful investigation about our users
f) If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our terms or other applicable rules

Article 11 – OPTING OUT OF TRANSMITTALS FROM US:
From time to time, we may send you informational or marketing communications related to our Website such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email: support@flostack.io.
You may also click the opt-out link which will be provided at the bottom of any and all such communications.
Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Website or about your account with us.
By providing any Personal Data to us, or by using our Website in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.

Article 12 – MODIFYING, DELETING, AND ACCESSING YOUR INFORMATION:
If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may email us at support@flostack.io

Article 13 – ACCEPTANCE OF RISK:
By continuing to use our Services in any manner, including using the Product, you manifest your continuing asset to this Privacy Policy. You further acknowledge, agree and accept that no transmission of information or data via the internet is not always completely secure, no matter what steps are taken. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk.

Article 14 – RIGHTS RELATING TO CUSTOMER DATA:
a. We also process personal information submitted by or for a customer to our Services. We process such personal data as a processor on behalf of our customer, who is the controller of such data. We are not responsible for the compliance of our customers with the applicable data protection law. We request you to refer to their respective privacy statements to understand their privacy and security practises.

b. As a processor, we may only access and process customer data based on their instructions. Therefore, if your data has been submitted to us by or on behalf of the Customer, we request that you contact the customer directly. If you wish to make any requests to us directly, please also provide us with the name of the customer who provide your data to us. We will refer your request to the customer and support them as needed in responding to the request.

Article 15 – CONTACT INFORMATION:
If you have any questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address: privacy@leadsquared.com