Privacy Policy

Your privacy is important to fluxLoop.

This Privacy Policy covers how we collect, use, disclose, and store your information when visiting our website fluxloop.com and when using applications based on our Pinch™ technology.

Being a Norwegian company fluxLoop processes your data in compliance with applicable Norwegian laws on data protection, information security and consumer protection.

This Privacy Policy does not apply to any links to third parties' websites and/or services that you may encounter when you use the website. Please be aware that fluxLoop is not responsible for the privacy practices of any third parties.

1. Collection of information

on our website

Use of cookies

Our website, fluxloop.com, uses cookies. A cookie is a small data file sent from our website and stored on your computer. We use cookies to improve your user experience by making the website work more efficiently as well as to provide us statistical information about the use of our website.

If you wish to manage or opt out of using cookies, you can do so by setting your browser to not accept certain or all cookies. Please see your browser’s help information or visitaboutcookies.orgon how to manage cookies. If you choose not to accept cookies we cannot guarantee that our website will work properly.

2. Collection of information

using Pinch™ technology

fluxLoop has developed and owns the Pinch™ technology. Pinch™ 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 Pinch™ 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 Pinch™ technology you will be in control of your own data. All processing of personal data administered by Pinch™ 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 Pinch™. 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 Pinch™.

fluxLoop operates as a data controller with respect to use of de-identified personal data collected through Pinch™ 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 Pinch™, 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:

Physical location

When you use an app using Pinch™, fluxLoop will register the mobile device's location. Registration of location will only take place when you have:

1. Accepted location based services in the mobile device’s operating system (only iOS);
2. 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.

Compilation

If you have several applications which uses Pinch™, fluxLoop may compile personal data collected from all those apps to make information, services and advertisement even more relevant to you. The Pinch™ technology provides for an opt out opportunity with respect to such compilation. Note that fluxLoop will not share the compiled data sets with anyone.

Extraction

fluxLoop extracts de-identified data sets from the personal data collected by an application using Pinch™. Such data sets are used for the offering of targeted advertisements to app owners and other customers (see 2.3 below). The Pinch™ 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 Pinch™ 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.:

1. When you enter a shop the staff is notified and may offer you personalised service and offers tailored to your needs and preferences

2. You may be provided information and offers tailored to the specific location, either through the mobile device or through digital screens.

B. Marketing

fluxLoop may use de-identified personal data extracted from data sets collected from applications utilizing the  Pinch™ 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  Pinch™).

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 Pinch™ technology provides for an opt-out opportunity with respect to this processing purpose.

C. Statistics

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 Pinch™ 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 Pinch™ 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:

1. You have the right to opt-out at any time for the use of personal data for this purpose.

2. luxLoop 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.

3. The information is stored in a secure environment, which is only accessible to fluxLoop employees.

4. 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 Pinch™ 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 Pinch™.    

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.

4. Changes to the Privacy Policy

We may update this Privacy Policy from time-to-time by posting a new version on our website.  You should check this page occasionally to ensure you are happy with any changes.

5. Contact

If you have questions to this Privacy Policy or other questions related to the Pinch™ technology, please send an email to:
privacy@fluxloop.com
Our office address is:
fluxLoop AS
Akersgata 41
0185 Oslo

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.

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