Your privacy is important to fluxLoop.
Being a Norwegian company fluxLoop processes your data in compliance with applicable Norwegian laws on data protection, information security and consumer protection.
1. Collection of information
on our website
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2. Collection of information
using Pinch™ technology
fluxLoop has developed and owns the PinchTM technology. PinchTM enables advertisers and publishers to gain customer insight, target marketing and offer value added services based on sensors and mobile applications, enabling real-time registration of the physical location of the users of the application.
fluxLoop will only license the PinchTM technology to advertisers and publishers who commit to comply with applicable data protection laws and the terms and conditions accepted by the user.
As a user of applications utilising PinchTM technology you will be in control of your own data. All processing of personal data administered by PinchTM is based either on your informed consent or you are offered an opportunity to opt out.
2.1 Roles and responsibilities
fluxLoop operates as a data processor for our customers using PinchTM. That is for the processing of personal data for providing you with relevant information in the app or through other channels (see 2.3 below). Note that fluxLoop is not liable for the processing of your personal data carried out by the owner of an application using PinchTM.
fluxLoop operates as a data controller with respect to use of de-identified personal data collected through PinchTM for provision of marketing services to app owners and other customers (see 2.3 below).
2.2 Collection of data
When you install an application using PinchTM, the app owner will collect information that can be related to you as an individual (personal data). The following categories of information may be collected:
When you use an app using PinchTM, fluxLoop will register the mobile device's location. Registration of location will only take place when you have:
- Accepted location based services in the mobile device’s operating system (only iOS);
- Given your consent in the application to registration of localisation even when the application is not active.
Information collected from the mobile device
The application may request your consent to have access to information/functions on your mobile device, e.g. location and/or notifications. If you have consented to this, fluxLoop will on behalf of the app owner collect data about your device and internet connection, e.g. about your operative system, device manufacturer and network ID.
If you have several applications which uses PinchTM, fluxLoop may compile personal data collected from all those apps to make information, services and advertisement even more relevant to you. The PinchTM technology provides for an opt out opportunity with respect to such compilation. Note that fluxLoop will not share the compiled data sets with anyone.
fluxLoop extracts de-identified data sets from the personal data collected by an application using PinchTM. Such data sets are used for the offering of targeted advertisements to app owners and other customers (see 2.3 below). The PinchTM technology provides for an opt out opportunity with respect to use of de-identified data sets for marketing purposes.
2.3 Purpose for collecting the data
The purpose of the processing of personal data is partly decided by the owner of the application using PinchTM and partly by fluxLoop, depending on which party is acting in the role as data controller (see 2.1 above).
A. Provision of services
Generally the purpose decided by the application owner will be to provide you relevant information, services and advertisement.
Location based technologies provides several possibilities, e.g.:
- When you enter a shop the staff is notified and may offer you personalised service and offers tailored to your needs and preferences
- You may be provided information and offers tailored to the specific location, either through the mobile device or through digital screens.
fluxLoop may use de-identified personal data extracted from data sets collected from applications utilizing the PinchTM technology to target a specific audience on behalf of a customer.
Third parties are involved in the processing of de-identified data for this purpose as facilitators of the platforms on which advertisements are placed. Examples of such third parties are social media platforms. This is how it works: fluxLoop provides the third party service with a list of hashed (hashing is a common anonymization technique) mobile identifiers (each mobile phone has a unique identifier called IDFA/AAID). These identifiers belongs to a group of persons which assumingly have a common preference, based on for example the fact that they went to a specific store the last month (such knowledge can be derived from their use of an application using PinchTM).
The hashed identifiers enable the third party service to recognise identities without knowing the person behind. This is possible because the third party are in possession of the same identifiers. No information is added to the third party service through the information disclosed to them, but it enables the third party service to place an advertisement to a specific group of people.
Note that the PinchTM technology provides for an opt-out opportunity with respect to this processing purpose.
Anonymous data sets (statistics) may be used towards market players who want to gain insight on customer behaviour, for example the number of visitors to a specific sales outlet. These data sets are completely anonymous (exists only on an aggregated level).
2.4 Legal basis for collection of data
Processing of personal data administered by PinchTM for the purpose of providing you with relevant information in the app (ref. A above) is based on your informed and explicit consent. You may at any time withdraw your consent by disabling Bluetooth, disabling location based services in the operating system (iOS), disabling PinchTM in the application settings or by uninstalling the application.
Processing of de-identified personal data for marketing purposes (ref. B above), is based on a balancing of interests. Use of these data sets enables fluxLoop to provide valuable marketing services to market players who want to target their communications. fluxLoop has assessed that this legitimate interest is not overridden by the privacy interests of users, taken into account the establishment of several guarantees to make sure your privacy interests are well taken care of:
- You have the right to opt-out at any time for the use of personal data for this purpose.
- fluxLoop removes from these data sets all information which can directly identify you. This render the data sets anonymous for anyone not putting a considerable effort into re-identifying the person behind.
- The information is stored in a secure environment, which is only accessible to fluxLoop employees.
- Applicable data protection laws do not cover processing of anonymous data (ref. C above).Accordingly no legal basis is required for this purpose.
2.5 Access, rectification and deletion of data
You have the right to request access to your personal data held by publishers and advertisers using PinchTM technology as well as exercising other rights, such as the right to data portability. Access requests or other rights requests regarding personal data held by publishers and advertisers must be directed to the relevant application owner. What regards access to de-identified data held by fluxLoop, please note that fluxLoop is not able to identify you on the basis of such data. Accordingly access to de-identified data held by fluxLoop is not possible, unless you provide us with additional information enabling your identification.
Your personal data will be retained as long as necessary to fulfil the purpose of the processing of the personal data on behalf of the app owner. Normally this is 6 months. Unless there is a mandatory statutory requirement to store the data for a longer period the data will then be deleted. De-identified data extracted from the personal data may be kept by fluxLoop for a period of [18 months].
You have at any time the right to request that your personal data are deleted or rectified. Deletion of data can be carried out by choosing "delete all data related to my profile" in the application's settings. This functionality is provided by PinchTM.
3. Data protection by design
fluxLoop uses several security technologies to protect personal data against unauthorised access, inter alia, by storing personal data on servers with limited access in security-monitored locations and by use of a third-party service for the purpose of effective de-identification of data sets. Transfer of personal data over the Internet is always protected by use of encryption.
Our office address is:
We appreciate your feedback and will do our best to answer your questions and adapt the services to the expectations of users. If you disagree with the way fluxLoop treat your personal data you may file a complaint with the Norwegian Data Inspectorate.