Privacy Policy
Updated June 22, 2020
Updated June 22, 2020
Flatfile Inc. 1624 Market Street Suite 202 PMB 9138 Denver CO 80202
Owner contact email: compliance@flatfile.com
Among the types of Personal Data that Flatfile collects, by itself or through third parties, there are: Cookies; Usage Data; various types of Data; email address; phone number; Data communicated while using the service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Flatfile. Unless specified otherwise, all Data requested by Flatfile is mandatory and failure to provide this Data may make it impossible for Flatfile to provide its services. In cases where Flatfile specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by Flatfile or by the owners of third-party services used by Flatfile serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Flatfile and confirm that they have the third party's consent to provide the Data to the Owner.
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Flatfile (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union, United Kingdom, or Switzerland, or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Data transfer outside the EU, UK, or Switzerland, Remarketing and behavioral targeting, User database management, Handling payments, Displaying content from external platforms, Tag Management and Interaction with live chat platforms.
For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior
Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google utilizes the Data collected to track and examine the use of Flatfile, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Flatfile. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on Flatfile.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below. Users can inquire with the Owner to learn which legal basis applies to which specific service.
If this is the legal basis, the transfer of Personal Data from the EU, UK, or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield. In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce. Personal Data may be transferred from within the EU, UK, or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
The Privacy Shield list may be found at the Department of Commerce's website.
Personal Data processed: various types of Data.
Category of personal data collected according to CCPA: internet information.
If this is the legal basis, Personal Data of Users shall be transferred from the EU, UK, or Switzerland to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards. In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Flatfile.
Personal Data processed: various types of Data.
Category of personal data collected according to CCPA: internet information.
This type of service allows you to view content hosted on external platforms directly from the pages of Flatfile and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts is a typeface visualization service provided by Google LLC that allows Flatfile to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows Flatfile to incorporate content of this kind on its pages.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Payment processing services enable Flatfile to process payments by credit card, bank transfer or other means. To ensure greater security, Flatfile shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This type of service allows Users to interact with third-party live chat platforms directly from the pages of Flatfile, for contacting and being contacted by Flatfile support service. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
The Drift Widget is a service for interacting with the Drift live chat platform provided by Drift.com, Inc.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
This type of service allows Flatfile and its partners to inform, optimize and serve advertising based on past use of Flatfile by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain remarketing features by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
AdRoll is an advertising service provided by AdRoll, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
This type of service helps the Owner to manage the tags or scripts needed on Flatfile in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Flatfile, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Flatfile. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Flatfile.
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Category of personal data collected according to CCPA: identifiers; internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
For use cases in which Flatfile acts as a service provider for financial institutions, Flatfile will not disclose or use information other than the purposes for which you have disclosed the information.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Flatfile uses Cookies and other Identifiers. To learn more, the User may consult the Cookie Policy.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Flatfile or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
In addition to the information contained in this privacy policy, Flatfile may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, Flatfile and any third-party services may collect files that record interaction with Flatfile (System logs) use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Flatfile does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Flatfile and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Flatfile and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term "personal information" as it is defined in The California Consumer Privacy Act (CCPA).
In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled "Detailed information on the processing of Personal Data" within this document.
We have collected the following categories of personal information about you: identifiers and internet information.
We will not collect additional categories of personal information without notifying you.
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Flatfile.
For example, you directly provide your personal information when you submit requests via any forms on Flatfile. You also provide personal information indirectly when you navigate Flatfile, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of Flatfile and features thereof.
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.
To find out more about the purposes of processing, please refer to the relevant section of this document.
For our purposes, the word "sale" means any "selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration".
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.
If you'd like to know more, or exercise your right to opt out in regard to all the sales carried out by Flatfile, both online and offline, you can contact us for further information using the contact details provided in this document.
We may use your personal information to allow the operational functioning of Flatfile and features thereof ("business purposes"). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section "Detailed information on the processing of Personal Data" within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
You have the right to request that we disclose to you:
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Flatfile, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it's necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12 month period.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Flatfile complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. Flatfile has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Flatfile is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to compliance@flatfile.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to compliance@flatfile.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Flatfile's accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Flatfile remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Flatfile proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Flatfile commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Flatfile by email at compliance@flatfile.com
Flatfile has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through Flatfile (or third-party services employed in Flatfile), which can include: the IP addresses or domain names of the computers utilized by the Users who use Flatfile, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using Flatfile who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Flatfile. The Data Controller, unless otherwise specified, is the Owner of Flatfile.
The means by which the Personal Data of the User is collected and processed.
The service provided by Flatfile as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to Flatfile, if not stated otherwise within this document.