Owner and Data Controller
1015 Aviation Parkway
Morrisville, NC 27560
Owner contact email: [email protected]
FloLogic is committed to protecting your privacy and enabling a positive user experience. This Privacy Statement for FloLogic Services and Products describes information and data that FloLogic, Inc. collects and uses to operate the FloLogic System. By using our Application (App) or websites, you are providing us with certain personal information and are consenting to the information and data collection described in this privacy statement.
Types of information collected
Data collection from users is required for the proper operation of FloLogic Services and Products. Third parties are used for data processing, product installation, and subsidizing the purchase of these services and products. Third parties include, but are not limited to, insurance companies, property managers, plumbers, cloud services, App stores, technical support services and personnel.
FloLogic uses industry standard security measures for protecting information, data collected, and data storage.
Among the types of Information that FloLogic collects, by itself or through third parties include:
Email address, city, first name, last name, phone number, property address, country, state, ZIP/Postal code, Contacts permission, Precise location permission (non-continuous), Phone permission, SMS permission, and Usage information.
Information may be freely provided by the User, or, in case of Usage information, collected automatically when using the App.
Usage information includes water flow, volume, and date/time of flow as well as product settings, including alert notification settings, that control the operation of water leak detection. Product settings include allowable drip rate flow, home and away shutoff timer settings, bypass timer settings, and override settings.
Usage information can also include system data obtained by the FloLogic system from third party systems, including security alarms, irrigation systems, hot water heaters, water conditioners and other water related appliances.
Unless specified otherwise, all information requested by the FloLogic system and App is mandatory and failure to provide this Information may make it impossible for the system to provide its services. In cases where the App specifically states that some Information is not mandatory, Users are free not to communicate this Information without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Information is mandatory are welcome to contact FloLogic.
Users are responsible for any third-party Information obtained, published or shared through the App and confirm that they have the third party’s consent to provide the Information to FloLogic.
Mode and place of processing the Information
Methods of processing
FloLogic takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Information.
The Information 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 FloLogic, in some cases, the Information may be accessible to certain types of persons in charge, involved with the operation of the App (administration, sales, marketing, legal, system administration) or external third parties appointed, if necessary, as Information Processors by FloLogic. The updated list of these parties may be requested from FloLogic at any time.
Legal basis of processing
FloLogic may process Information relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations FloLogic may be allowed to process Information until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Information is subject to European information protection law;
- provision of Information is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which FloLogic is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in FloLogic;
- processing is necessary for the purposes of the legitimate interests pursued by FloLogic or by a third party.
In any case, FloLogic will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Information is processed at FloLogic’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, information transfers may involve transferring the User’s Information to a country other than their own. To find out more about the place of processing of such transferred Information, Users can check the section containing details about the processing of Information.
Users are also entitled to learn about the legal basis of Information transfers to a country outside the European Union 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 FloLogic to safeguard their Information.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with FloLogic using the information provided in the contact section.
Information shall be processed and stored for as long as required by the purpose they have been collected for.
FloLogic may be allowed to retain Information for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, FloLogic may be obliged to retain Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
The purposes of processing
The Information concerning the User is collected to allow FloLogic 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, Contacting the User, and Hosting and backend infrastructure.
For specific information about the Information used for each purpose, the User may refer to the section “Detailed information on the processing of Information”.
Device permissions for Information access
Depending on the User’s specific device, the App may request certain permissions that allow it to access the User’s device Information as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact FloLogic for support at the contact details provided in the present document.
The exact procedure for controlling App permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of the App.
If User grants any of the permissions listed below, the respective Information may be processed (i.e. accessed to, modified or removed) by the App.
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, Wi-Fi network, or the status of any ongoing calls.
Precise location permission (non-continuous)
Used for accessing the User’s precise device location. The App may collect, use, and share User location Information in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for the App to derive the exact position of the User on a continuous basis.
Used for accessing features related to the User’s messaging including the sending, receiving and reading of SMS.
Phone Address Book
FloLogic allows users to add addition users to control your FloLogic system. For convenience, they can select these users from the Phone’s Contact Address Book. An invite email is requested to be sent to the additional user.
Detailed information on the processing of Information
Information is collected for the following purposes and using the following services:
Data is collected from the FloLogic system to determine potential water leak conditions. Along with local onsite analytics, Cloud services is employed to predict upcoming events using machine learning along with previously stored information.
Contacting the User
Push notifications, email, and SMS messaging is used to contact the user for desired events that the user has preselected. Some events may not be disabled if the User has agreed to specific third-party requirements. This can include SMS messages warning of a disabled system or leak alarm that the third party, i.e. insurance company, has designated as a requirement for subsidizing the FloLogic system.
Hosting and backend infrastructure
FloLogic employs third-party hosting, cloud, service desk, and backend infrastructures to provide its services to users. Privacy polices of these can be found at the following:
Microsoft Azure Services
Apple App Store
Google Play App Store
The rights of Users
Users may exercise certain rights regarding their Information processed by FloLogic.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Information.
- Object to processing of their Information. Users have the right to object to the processing of their Information if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Information. Users have the right to learn if Information is being processed by FloLogic, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Information undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Information and ask for it to be updated or corrected.
- Restrict the processing of their Information. Users have the right, under certain circumstances, to restrict the processing of their Information. In this case, FloLogic will not process their Information for any purpose other than storing it.
- Users have the right, under certain circumstances, to obtain the erasure of their Information from FloLogic.
- Receive their Information and have it transferred to another controller. Users have the right to receive their Information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Information is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent information protection authority.
Details about the right to object to processing
Where Information is processed for a public interest, in the exercise of an official authority vested in FloLogic or for the purposes of the legitimate interests pursued by FloLogic, 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 Information be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether FloLogic is processing Information for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to FloLogic through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by FloLogic as early as possible and always within one month.
Additional information about Information collection and processing
The User’s Information may be used for legal purposes by FloLogic in Court or in the stages leading to possible legal action arising from improper use of the App or the related Services.
The User declares to be aware that FloLogic may be required to reveal information upon request of public authorities.
Additional information about User’s Information
System logs and maintenance
For operation and maintenance purposes, the App and any third-party services may collect files that record interaction with the App (System logs) use other Information (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Information may be requested from FloLogic at any time. Please see the contact information at the beginning of this document.
Should the changes affect processing activities performed on the basis of the User’s consent, FloLogic shall collect new consent from the User, where required.
Contact FloLogic by telephone at 1-877-356-5644 or email [email protected] for more information.
Information for Californian consumers
This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).
Categories of personal information collected, disclosed or sold
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 Information” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, internet information and geolocation information.
We will not collect additional categories of personal information without notifying you.
How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use the App.
For example, you directly provide your personal information when you submit requests via any forms on the App. You also provide personal information indirectly when you navigate the App, 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 the App and features thereof.
How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
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.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of the App 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 Information” 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.
Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:
- the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
- in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
- for sales, the personal information categories purchased by each category of recipient; and
- for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
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.
How to exercise your rights
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:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
How and when we are expected to handle your request
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.
Definitions and legal references
Latest update: June 26, 2020