the dtx company dba Flowcode
Effective Date March 27, 2024
This is the Privacy Policy for the dtx company dba Flowcode (“dtx”) and its business operations, including Flowcode and Flowpage. It covers how we use the personal information we obtain in connection with our websites (“Sites”), Flowpages, and other services, features, content, technology and applications (desktop and mobile), including, for example, our QR Codes known as Flowcodes, our Flowtags, our API, our Flowleads tool, our Flowcode Conversion Pixel, and our data services (all of which, including Flowpages and our Sites, we refer to as our “Services”). We help companies and other organizations (collectively “Brands”) and other account holders and customers of our Services (“Creators”) build connections. Sometimes we do this – and provide other aspects of our Services– by collecting information through Flowpages, Flowtags, Flowcodes or through the websites, applications or other online properties of Brands and Creators.
If you represent a Brand or are a Creator or an individual who uses our Services or whose personal information is handled through our Services, this Privacy Policy sets out how dtx looks after your personal information and contains information regarding your privacy rights when using our Services or otherwise interacting with dtx. This Privacy Policy also covers the personal data we collect in the context of our other business-to-business interactions and marketing efforts. Dtx respects your privacy and is committed to protecting your personal information.
For the purposes of the relevant privacy and data protection law in the United Kingdom, European Union, or locations with similar law, in most cases (except where we have agreed to act solely as a “processor” of your information on behalf of a Brand or Creator you are interacting with as discussed below), dtx is considered the “controller” of your personal information. This means that we are responsible for deciding how we store and use personal information about you and providing you with the information contained in this Privacy Policy. However, this Privacy Policy only applies to dtx’s handling of your personal information. Brands, Creators and other third parties collect and handle personal information pursuant to their own policies and procedures, which differ from this Privacy Policy and for which they are responsible. Clicking on third-party links or using connections to third parties through our Services (including by using or visiting their Flowcodes, Flowpages or Flowtags) may allow third parties to collect or disclose personal information about you. These third parties typically act as separate and independent controllers of your personal information, including with respect to information they collect on Flowpages and through Flowcodes and Flowtags. We do not control these third parties and are not responsible for their privacy policies and procedures.
By using a Site or other Services, such as by scanning a dtx-powered QR code (including one labeled Flowcode, Flowtag or Flowpage), creating a personalized Flowcode QR code (“Personal QR code”), creating a Flowpage (“Personal Flowpage”) or Flowtag, or visiting, scanning, tapping, entering information into or clicking on a Site, Flowpage, Flowcode or Flowtag, you authorize the collection and handling of your information as described in this Privacy Policy.
The types of information we collect are described in the Key Privacy Details section below. You disclose some of that information with us using the information collection technology described below. We also may use that technology to collect information about you automatically. We may also receive personal information from Brands, Creators, service providers and data partners (e.g., Google), trade associations and industry partners, event organizers, joint marketing partners, public agencies, as well as other publicly available sources such as websites. If you disclose your Personal QR code or you disclose any other dtx-powered QR code (including through your Personal Flowpage) to another person who then scans that QR code, we may collect from that person’s device the same categories of information as described in the Key Privacy Details section below and the rest of this Privacy Policy, and that collection of information will be subject to the terms of this Privacy Policy. In addition, if a Flowpage uses our contact collection form or other information collection widget, another person (for example, a Flowpage visitor) may enter additional information into that widget. In that case, our own collection and handling of such information will be subject to the terms of this Privacy Policy, but the handling of the information by the Brand or Creator that made the Flowpage will be subject to their own privacy policies and practices.
It is important that you read this Privacy Policy together with any other privacy policy or notice we provide on specific occasions so that you are aware of how and why we are using your personal information. This Privacy Policy is not a contract.
We will update this Privacy Policy from time to time and may also notify you in other ways from time to time about how we handle your personal information.
This section of our Privacy Policy sets out some key details about how the dtx company dba Flowcode (“dtx”) and its business operations, including Flowcode and Flowpage, collect and use your personal information. It does not apply to the handling of personal information by our customers (“Brands” and “Creators,” each as defined above). For full context and details, we recommend reading this entire Privacy Policy from the top.
To understand dtx’s handling of personal information, you need to know a few things about how our QR codes work:
QR CODES
When you point the camera on any modern phone or tablet at a QR code, you’ll either be given an option to take some action, or your device will automatically take that action. For example, when you point the camera at the QR code below, you’ll see the option to visit a webpage. Some QR codes can do other things, like download some content or install an app
When you use a dtx-powered QR code, we may collect some information about that interaction via cookies. For example, a Brand or Creator could display a dtx-powered QR code on a billboard, in a Flowtag, in an ad on TV, on their product, or anywhere else, along with an invitation to scan it to get a coupon, download an app, join a mailing list, find out more information about a product, or purchase a product. If you scan it, your phone may visit a dtx Site (including without limitation flowto.it, flwc.de or shop2.it) first for a split second. At the dtx Site, we may collect information, such as the IP address of your device, the time of the scan, information about the browser your device uses and about your device’s operating system. Dtx may also use cookies and the other information collection technology described below in the Cookie Notice to collect information on that dtx Site and at website or online property that the Brand or Creator has associated with the QR Code. If you scan our QR Codes using a dtx mobile application or a browser through which you have given dtx a geolocation consent, dtx may also collect your precise geolocation during your scans and disclose it to Brands or Creators whose geolocation-activated QR codes you scan. Regardless, we may infer your general geolocation from your IP address and disclose this to the Brand or Creator when you scan their QR Code.
Personal Information We Collect
Personal Information that could be collected or generated when you scan one of our QR Codes (including on a Flowtag):
Personal Information collected in other contexts, such as through other use of our Sites or interactions with our business contacts or other counterparties:
For more information about the information we collect through cookies and how it is used, please see the Cookie Notice section of our Privacy Policy below.
How We Use Personal Information
We use personal information for the following purposes:
The California Consumer Privacy Act (“CCPA”) defines the “sale” of California personal information to include selling user data to random third parties for money, like a data broker does. But it also defines “sale” and “sharing” in a broader sense that includes some common practices that we have engaged in during the last 12 months. For example, under the CCPA, these terms include the use of certain advertising services, like when we pay an ad tech company to place a cookie on the browser of a visitor to our website so that the user can see an ad for our services on other websites. The ad tech company can see the website visitor’s IP address and other browser/device/cookie data as part of that process. Under the CCPA, we also are “selling” personal information when we allow vendors that assist us with our Services (like certain analytics providers) to also use IP addresses and browser/device/cookie data to improve their services in certain ways. The terms “sale” and “sharing” also cover some of our other uses of other advertising services, like if we were to pay a third-party website to serve ads for us to individuals that we specify by giving that website a list of those individuals’ email addresses (or hashes of those email address). This would be considered a “sale” and “sharing," even though we’d be the ones who would pay for it. We don’t currently engage in other “sales” or “sharing” of California personal information (as those terms are defined under the CCPA), but we do engage in other disclosures of personal information about Californians, as described further below. We don’t “sell” or “share” California personal information (as those terms are defined under the CCPA) if we have actual knowledge that the consumer is less than 16 years of age. Californians can opt out of our CCPA “sales” and “sharing” by following the instructions on our Your Privacy Choices form
Through our Sites and other Services (including on Flowpages and in some Brands’ and Creators’ online properties and communications, such as via the Flowcode Conversion Pixel), we and third parties collect information from your device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code.
This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as the Apple IDFA or Android Advertising ID), geolocation, other device information, Internet connection information, as well as details about your usage and interactions with the relevant website, application, email or other online property (for example, the URL of the third-party website from which you came, the pages and content on our Site that you view, how frequently you access or use the Services, and how you engage with or navigate our Services (including the links you click on), error logs, and other similar information). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.
These technologies help:
For example, in some cases, we assist with the collection of information by advertising services provided by third parties. We and ad services may track your online activities over time by collecting information through automated means such as cookies, and we or they may use this information to show you ads that are tailored to your individual interests or characteristics, your prior visits to certain websites, or other information we or they know, infer, or have collected from people like you.
In addition, when you scan a dtx-powered QR code, dtx may use cookies and the other information collection technology described above to collect information about that interaction (as further described above in the QR Codes section of our Privacy Policy).
In general, we will retain your information in identifiable form only for the time necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Because we may collect and use the same category of personal information for different purposes and in different contexts, there is not typically a fixed retention period that always will apply to a particular category of personal information. Therefore, to determine the appropriate retention period for personal information, we may consider factors such as the potential risk of harm from unauthorized use or disclosure of your personal information, the amount, nature, and sensitivity of the personal information, the purposes for which we process your personal information, to determine if we can achieve those purposes through other means, and the applicable legal requirements. Examples of how long we normally intend to retain personal information that we collect about residents of California in certain situations are set forth below. Information may also persist in copies made for backup and business continuity purposes for longer than original copies.
We disclose your information to third parties as follows:
When applicable, we comply with legal requirements for transfers of personal information to third countries, such as by making transfers under the following conditions:
Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your personal information out of the United Kingdom or Europe.
We will only use your personal information when the law allows us to. If you are based in the United Kingdom or Europe, when we act as a data controller we will only use your personal information if we have one of the following legal bases:
We urge you to use a unique password for each of the Services, to keep them in a safe place and not to give them to anyone. Also remember to sign off your account and close your browser window when you have finished your visit to the Sites or your other use of the Services. We use various physical, technical, and organizational safeguards in an effort to protect personal information. However, no security method is perfect, and even if you take those steps, we cannot guarantee that any personal information will remain secure.
To opt out of the non-essential cookies on flowcode.com, please select ‘Cookie Settings’ from the link in that website’s footer to manage your preferences.
To learn more about interest-based advertising generally, or to opt out of targeted, interest-based ads by some of our current ad service partners, visit aboutads.info/choices from each browser you use.
For controls relating to the data collected from mobile applications, please read your operating system's instructions for complete instructions. Some of the options may be found here:
You can also opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page from each browser. Google also allows you to install a Google Analytics Opt-out Browser Add-on for each browser.
In addition, you may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject our cookies, local storage, JavaScript or other technologies, certain websites (including some of our own Sites) may not function as expected.
If you replace, change, upgrade or reset your browser or device, or delete your cookies, or use a browser that automatically deletes cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.
You can unsubscribe from dtx marketing emails at any time. If you have established an online account with our Services, you may also be able to login to that account to access or change your personal information, or to use certain privacy preference settings.
If you do not want us to see or access your device location, you can turn off location sharing on your device and browser, change your device privacy settings, and change your device’s location settings for our Sites and applications. Please note that disabling such features may result in you not being able to access or receive some of the present or future content available in the Services.
If you would like to opt out of receiving marketing or promotional emails from dtx, please contact [email protected] or follow the instructions in those messages. Please note that if you opt out, we may still send you non-promotional or non-marketing messages, such as communications regarding Services you have requested.
In addition to exercising your choices regarding cookies and direct marketing as described in the Privacy Policy sections above, depending on where you live, you may have the right to make certain other requests related to your personal information. For example, if you are located in the United Kingdom, European Union, or an area with similar laws (including, to some extent, certain states in the U.S.), you have the right to:
If you want to exercise any of these rights, please contact us.
In addition, residents of California, Virginia, Colorado, Connecticut, Nevada, and a growing number of other jurisdictions have a right to opt out of what the laws in those states call a “sale” of personal information. In most of those states, the law also provides for a right to opt out of certain uses and disclosures of personal information for certain targeted advertising purposes. To exercise those rights, residents of those states can visit our Your Privacy Choices page and follow the instructions there. California residents’ rights, and the specific methods of contact that they must use to exercise those rights, are described in the next section of this privacy policy.
All the rights described above (except the direct marketing opt-out) are subject to important exceptions.
You will not normally have to pay a fee to access your personal information (or to exercise any of the other rights). However, depending on which laws apply, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to reduce the risk that personal information is disclosed to unauthorized people.
All individuals also have a right to complain to their local data protection supervisory authority about any company’s handling of their personal information. If you have a concern about our data practices, we invite you to please contact us first so that we can do our best to address your concern.
To exercise a right to appeal a decision we have made regarding your personal information (such as under Colorado, Connecticut, or Virginia law), you can contact us at [email protected] with an explanation of why you believe we should reach a different decision. Your appeal under one of those laws will be reviewed by our privacy team, including in certain circumstances our General Counsel. We will respond with a decision and a written explanation of the reasons for the decision within 45 days of your appeal or the time period provided under applicable law.
This section applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (CCPA), and it supplements the information in the Key Privacy Details section above and the rest of this Privacy Policy. Personal information about individuals who are not residents of California may be handled differently and is not subject to the same California rights described below. This section also does not apply to personal information that we handle solely on behalf of certain Brands or Creators, even when such information is about a resident of California.
Collection and Disclosure of California Personal Information During Past 12 Months
We describe in the two charts below the categories of California personal information we have collected, and the categories of third parties to whom we have disclosed such information for a business purpose, during the 12 months leading up to the effective date of this Privacy Policy:
If you are a California resident, California law may permit you to request that we:
Certain information is exempt from such requests under applicable law. You also may have the right to receive information about the financial incentives that we offer to you (if any). You also have certain rights under the CCPA not to receive discriminatory treatment by dtx for the exercise of your CCPA rights. To request to exercise those CCPA rights, please email us at [email protected]. For security and legal reasons, dtx may not accept requests that require us to access third-party websites or services. We do not respond to browser-based do-not-track signals or similar mechanisms. We will take steps to verify your identity before responding to your request, which may include confirming that the browser in your possession matches the one associated with the relevant QR Codes, requesting that you respond to an email that we send to you, or otherwise verifying your name, email address or other information that will help us to confirm your identity.If you are an agent making a request on behalf of a consumer, you must verify that you are authorized to make that request, which may include requiring you to provide us with written proof that satisfies CCPA requirements, such as an appropriate letter signed by the consumer or a power of attorney. We also may require the consumer to verify their identity directly with us.CCPA “sale” and “sharing” of California personal informationAs mentioned earlier in this Privacy Policy, you can request opt out of what the CCPA calls “sales” and “sharing” by using our Your Privacy Choices form, which is the fastest and best option. You also can start the process by emailing us at [email protected] and then following the instructions we send you. Your browser may also offer a way to activate the Global Privacy Control signal (“GPC”). Flowcode.com treats qualifying browsers for which the user has activated the GPC signal as having opted out of what CCPA calls a “sale” and “sharing” of any California personal information that is collected on that site from that browser using cookies and similar technology. You can override that treatment for a GPC-enabled browser by using the cookie controls available from the website’s footer.We do not use or disclose “sensitive personal information” covered by this Privacy Policy and as defined in the CCPA in a manner that requires us to offer a special right to limit our use of this data under the CCPA due to its sensitive nature.California Shine the Light DisclosureThe California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we shared certain categories of “personal information” with third parties for their “direct marketing purposes” (as defined in the Shine the Light law) in the prior calendar year. To exercise that right, please contact us as described below.
Our Services are not directed at and should not be used by children under the age of 16. If we learn that we have collected the personal information of a child under the age of 16, we will delete it or take other steps if required under applicable law. Please inform us if you believe we have collected the personal information of a child under the age of 16 by emailing us at [email protected].
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via: