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FreeFlow Privacy Policy

Effective: 25th May 2018

This Privacy Policy describes how FreeFlow as a data controller collect, use and disclose information, and what choices you have with respect to this.

When we refer to "FreeFlow" we mean the business entity that acts as the controller or processor of your information. The data controller is Web Component Trading t/a FreeFlow.

How to contact us

Please feel free to contact us if you have any questions about this Privacy Policy or if you are seeking to exercise any of your statutory rights.

Email: privacy@freeflow.com

What and who does this Privacy Policy apply to?

This Privacy Policy applies to both individuals and companies who are our registered members, customers, purchasers and delegates of our online content, any other registered-user content we provide, along with any other interactions (e.g. customer enquiries) you may have with FreeFlow.

Why we process your data

We may process your data for a number of different purposes:

  • To keep you up to date with the latest, relevant content we have posted.
  • To administer any membership you have with us.
  • To administer any product you have bought from us.
  • To keep you up to date with and invite you to any of our latest, relevant auctions and/or events we are providing.
  • To collect your feedback and seek your insight through online survey invitations.
  • To give you access to content and auctions/ events provided by our approved third party partners.


Our lawful basis for processing your data

It's in FreeFlow's legitimate business interest to keep its customers, members and contacts informed of our latest content, products and services and to manage and administer their memberships and purchases.

We process customer and client data and use direct marketing as part of this legitimate interest. It's necessary for us to use a variety of direct marketing channels and messages to ensure our contacts are kept informed, and wherever possible we make sure the messages we send are targeted and relevant. Any direct marketing we undertake complies with e-privacy rules on consent so you can opt out at any time by following the unsubscribe instruction in our marketing communications (See "Right to Object" below).

We will keep your data safely and securely, typically for the period of your relationship with us plus a period of six years for any audit, legal or evidentiary purposes that may arise. If you'd like more information about how we store your data, please contact us directly.

Types of data we collect

When you register on our website we'll collect the kind of standard, non-sensitive information you would expect an online business to business supplier of product and services to request. For example, information we may collect directly from you may include:

At registration:

  • Your name;
  • Your company name;
  • Your email address;
  • Your Website domain;
  • Your postal address;
  • VAT / Tax ID Number;
  • Your phone number;
  • Your fax number;
  • A FreeFlow user ID;
  • A password (for FreeFlow website access);
  • Confirmation that you have agreed to the terms and conditions of the website;
  • Your preferences in relation to registering on our non-instant access marketplaces;
  • Your category preference requirements;
  • Your stock location preferences; and
  • Email contact preferences


During and after auction completion:

  • Bidding data associated with your Freeflow user ID


When purchasing from our platform:

  • If your bids placed on our action site are successful, you will need to provide us with billing and payment information which may include:
  • Full name;
  • Company name;
  • VAT / Tax ID number (corresponding certificates for verification purposes may be requested);
  • Billing/shipping address;
  • Shipping method / carrier details / carrier account number; and
  • Credit card details if paying by credit card


(If you do not provide us with the information requested and the corresponding payment, you may be unable to complete your order and access to our websites may be restricted and/or removed.)

After the completion of your order:

  • We will collect and store data on the transactions and purchases you make with us;
  • Proof of delivery documents and signed delivery statements; and
  • In the case where a credit note is issued we may require banking or credit card details in order to process a refund


Website Analytics / Cookies

FreeFlow uses third party tracking technologies in our websites that help us collect other information about our customers' and users' preferences.

Why does Freeflow use cookies and similar technologies?

Analytics and Research: To help us better understand how people use our Services, we work with a number of analytics partners, including Google Analytics; and to help us improve and understand how people use our services.

These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our websites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties. To find out more about how Google uses data when you visit a website that uses Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

Third party data

FreeFlow may receive data about organisations, industries, website visitors, marketing campaigns and other matters related to our business from our partners, affiliates or others, that we use to make our own information better or more useful. This data may be combined with other information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

Additional information provided to FreeFlow

We may receive and store other information when submitted to our websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with FreeFlow.



Recipients of the data we collect

In some cases we will share the data we collect from you with trusted third party content providers to support our business. Recipients of your data will be bound to use the data only for the contracted purposes which will be consistent with this Privacy Policy.

Our expectations of our content partners

Any personal data we share with our content partners is shared only on the basis that the data will be used by the partner under a lawful basis of legitimate interest and according to the requirements of the GDPR. We specify this in our contracts with all our content partners.

Data processing partners

FreeFlow may provide your personal information to any affiliated companies or other trusted businesses or persons, acting under a confidentiality agreement, for the purpose of processing personal information on behalf of FreeFlow. These parties are required to process such information based on instructions from FreeFlow and in accordance with this Policy. They do not have any independent right to share this information.

FreeFlow may transfer your data if FreeFlow is acquired by or merged with another company. FreeFlow will provide notice before this occurs and will email notification of the new Policy if necessary.

Credit and company background checking

FreeFlow may share your personal information with a credit and company background checking company. These third parties do not retain, share, or store any personally identifiable information except to provide these services and are bound by strict confidentiality agreements which limit their use of such information.

Your rights over the personal data we hold

You can reasonably request access to the personal data we hold on you, at any time, and we will respond to that request within one month of your request at the latest.

You can request inaccurate or incomplete personal data held on you to be rectified or completed or for your personal data to be suppressed or erased, and we will respond within one month of your request at the latest.

We will supply any data you request in an appropriate file format.

Your right to object

You have the right to opt out of our direct marketing at any point, and we will deal with your request right away. You can unsubscribe from our emails automatically by clicking on the unsubscribe link. Alternatively, you can amend your email preferences via our preference centre by logging into your account on our website.

To opt out of our direct mail or telephone marketing please call us on +353 (0)66 718 5400 or email info@FreeFlow.com

Data security

To secure your personal information, Freeflow utilise a secure high performance cloud environment to host our websites. Our hosting partner has adapted a multi-layer security methodology. Access to your data is password protected. It is your responsibility to keep your password confidential and not to share this information with anyone. Whilst FreeFlow will ensure all data is held securely, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.

Changes to this Privacy Policy

Freeflow may update this Privacy Policy to reflect changes to our privacy practices. If you are a Freeflow customer and we make any material changes that affect the way we treat information that we have previously collected from you, we will notify you by email (to your registered email address). We encourage you to periodically review this Policy for the latest information on our privacy practices.

Data Transfers outside the EEA

From time to time, Freeflow may transfer Personal Data outside the EEA. For example, our cloud environment is such that your data may be stored within or outside the EEA at any time. Such transfers will be subject to appropriate safeguards in accordance with applicable Data Protection Law (for example through the use of EU-approved Model Contract Clauses) and in accordance with this Privacy Policy.

Contact / Dispute Resolution

If you have any questions or concerns regarding the way in which your personal data is being processed or you want to exercise your rights above, please reach out to Freeflow using the contact information below:

Freeflow's data protection team can be contacted at:

Email: privacy@freeflow.com

Mailing Address:
Data Protection Team
Freeflow
Innovation Works 1
Kerry Technology Park
Tralee
County Kerry
Ireland

If you remain dissatisfied, you have the right to contact the data protection authority in your jurisdiction. We do ask that you please attempt to resolve any issues with us first, although you have a right to contact the data protection authority at any time. This policy was last modified on the 25/05/2018.