Privacy Policy

Last updated July 2026

This Privacy Policy (the “Policy”) describes the collection, use and disclosure (collectively: “Processing” or “Process”) of personal information by Flo Live Limited, a company organized and existing under the laws of United Kingdom and its affiliates (“Flolive”, “we” or “us”) in connection with your use of Flolive’s website and services. This Policy explains your privacy rights in connection with the said Processing.

By using Flolive’s services, you agree to the Processing of your information in accordance with this Policy.

Note that this Policy adheres to the EU-US Data Privacy Framework (DPF) Principles with regard to Personal Data transferred from the European Union, the United Kingdom and the Swiss-US DPF Principles with regard to personal data transferred from Switzerland.

1. Interpretation; Definitions.
   • Interpretation. The words of which the initial letter is capitalized have the meaning defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear singular or plural.
   • Definitions. For the purposes of this Policy:
     • “Business” means, for the purpose of the CCPA, Flolive as the legal entity that: (i) collects Consumers’ personal information; and (ii) determines the purposes and means of processing Consumers’ personal information; and/or (iii) conducts business in the State of California, whether acting alone or jointly with others in determining such purposes and means of processing.
     • “CCPA” means the California Consumer Privacy Act of 2018 California Civil Code § 1798.100 et seq., as supplemented or amended by the California Privacy Rights Act of 2020.
     • “Consumer” for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A California resident is a natural person (as opposed to a corporation or other business entity) who resides in California, even if the person is temporarily outside of the state.
     • “Cookies” means small files which are placed on your computer, mobile device or any other device when you visit a website. Cookies may contain information about your browsing preferences, device information, and other technical data used to enhance your experience on that website. This definition includes similar tracking technologies such as web beacons, pixels, and local storage.
     • “Data Controller” Flolive or, in cases of rendering services to Flolive’s customers, Flolive’s customers, which alone or jointly with others determines the purposes and means of the processing of Personal Data.
     • “GDPR” means the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 and any subsequent amendments, replacements, or supplements.
     • “Personal Data” means any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.  For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
     • “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website, to provide any Services on behalf of the Company, to perform services related to Our Services or to assist the Company in analyzing how the service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
     • “Usage Data” means data automatically collected or generated through the use of Flolive’s website and/or services or generated by the service infrastructure, including but not limited to technical data about service usage patterns, duration and frequency of access, system performance metrics, and infrastructure utilization statistics.
       
2. Collection of Personal Data.
   • Types of Data Collected. While Using the Flolive Services, we may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You, which may include, but is not limited to: (a) e-mail address; (b) first name and last name or company name; (c) phone number; (d) job title (if relevant); (e) Usage Data.
   • Usage Data. Usage Data is collected automatically when using the Company’s Services through the Website or any of the Company’s applications. Usage Data may include information such as Your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, any in-game interaction and other diagnostic data. When You access the Company’s Services by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.
   • Cookies. We use Cookies to track the activity on the Company’s Services and store certain information. For more information about the Cookies We use and your choice regarding Cookies, please visit our Cookies Policy.
   • Information we collect from other sources. In some cases, We may also receive information about You from Service Providers and third parties in connection with Your use of the Services or Your interaction with Us on other platforms.
     
3. Use of Your Personal Data. Flolive may use Personal Data for the following purposes:
   
   • 3.1. To create your user account and provide support and maintenance to our service, including monitoring the usage of our website;
   • 3.2. To communicate with you and respond to your requests;
   • 3.3. To provide you with news, special offers or personalized offers and general information
   • 3.4. We may anonymize Personal Data gathered through our website and use such anonymized data, among other things, to analyze, develop, improve and optimize the functionality, performance, and user experience of our websites and services;
   • 3.5. To comply with applicable laws and regulations and to operate our business;
   • 3.6. We collect information from SIM cards which are available to you through our services. Such information about the products or services you use will be anonymized. The anonymized data may be combined with information about the products and services used or purchased by others, but no Personal Data will be included in the resulting data.
   • 3.7. We do not share Your Personal Data with strangers. We may share your Personal Data in either the following situations:
     • 3.7.1. With Service Providers in order to perform business functions on behalf of Flolive, including to monitor and analyze the use of our services.
     • 3.7.2. For business transfer with third parties, in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company. Any successor entity shall be bound by the terms of this Privacy Policy with respect to your Personal Data;
     • 3.7.3. As required by law to comply with legal process, when we believe in good faith that disclosure is necessary to (i) comply with a legal obligation or in response to valid requests by public authorities (e.g., a court or a government agency); (ii) protect our rights; (iii) protect your safety or the safety of others; and (iv) prevent or investigate possible wrongdoing in connection with our services.
     • 3.7.4. With your consent. We may disclose your Personal Data for any other purpose with your consent.
   • When third parties are given access to Personal Data, we will take appropriate contractual, technical and organizational measures to ensure that such Personal Data is processed in accordance with applicable law. However, third-party Service Providers may collect, store, use, process and transfer information about your activity through our services in accordance with their privacy policies. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
     
4. Transfer of Your Personal Data. Your information, including Personal Data, is processed at Flolive’s facilities and in any other places where the parties involved in the processing are located. This means that your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable laws. If Personal Data is transferred to a country that does not provide an adequate level of protection for Personal Data, we will take adequate measures designed to protect the Personal Data, such as ensuring that such transfers are subject to the terms of the Standard Contractual Clauses stipulated in the GDPR or other adequate transfer mechanism as required under relevant data protection laws. Under certain circumstances, we may bear liability for onward transfers of personal information from the EEA where third party processes personal information inconsistently with the EU-US DPF, the UK Extension to the EU-US PDF and the Swiss-US DPF, unless we can demonstrate that we are not responsible for the event giving rise to any damage or loss.
   
5. Retention of Your Personal Data. Flolive will retain your Personal Data only for as long as necessary to meet the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen security or to improve the functionality of our services.
   
6. Security of Your Personal Data. The security of your Personal Data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks.
   
7. Marketing. We may use your Personal Data to provide you with newsletters, marketing or promotional materials and other information that may be of interest to you. We may also use HubSpot tracking pixels, in certain emails we send you in order to determine whether and when such emails are opened and clicked, collect certain technical information such as your IP address, device type and other engagement signals. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in our communications or by contacting us, as detailed in this Policy.
   
8. GDPR Privacy.
   
   
   • 8.1 Legal Basis for Processing Personal Data under GDPR. We may process Personal Data under the following conditions:
     
     Consent. You have given your consent to process Personal Data for one or more specific purposes.
     Performance of a contract. Provision of Personal Data is necessary for the performance of an agreement with You and/or any pre-contractual obligations thereof.
     Legal obligations. Processing Personal Data is necessary for compliance with a legal obligation to which Flolive is subject.
     Vital interests. Processing Personal Data is necessary in order to protect Your vital interests or those of another natural person.
     Public interest. Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in Flolive.
     Legitimate interests. Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Flolive.
     
   • 8.2 In any case, we 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.
     
   • 8.3 Your Rights under the GDPR. Flolive undertakes to respect the confidentiality of Your Personal Data and to guarantee the exercise Your rights. You have the right under this Policy, and by law, if You are within the EU, to:
     
     Right to access to Your Personal Data. You have a right to access, update or delete your information. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us at privacy@flolive.net and we will assist you. You may also receive a copy of the Personal Data we hold about you.
     Right to correct Personal Data. You have the right to have any incomplete or inaccurate information we hold about you corrected.
     Right to object to processing of your Personal Data. You can request that we stop using all or part of your Personal Data, if we are relying on legitimate interest as the legal basis for our processing, or limit our use. You also have the right to object if we are processing your Personal Data for direct marketing purposes.
     Right of erasure of Your Personal Data. You can ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
     Right of Portability of Your Personal Data. We will provide you, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided with consent for us to use or where we used the information to perform a contract with you.
     Withdraw Your consent. You have the right to withdraw your consent from using your Personal Data. If You withdraw Your consent, we may not be able to provide you with access to certain specific functionalities of our services.
     
   • 8.4 Exercising Your GDPR Data Protection Rights. You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
     
     
     
9. EU-U. Data Protection Framework (the “EU-US DPF”). We comply with the EU-US DPF, the UK Extension to the EU-US PDF, and the Swiss-U.S. Data Privacy Framework (the “Swiss-US PDF”) as set forth by the U.S. Department of Commerce. Flolive has certified to the U.S. Department of Commerce that it adheres to the EU-US DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US PDF. Flolive has certified to the U.S. Department of Commerce that it adheres to the Swiss-US PDF Principles with regard to the processing of personal data received from Switzerland in reliance to the EU-US PDF Principles and/or the Swiss-US PDF Principles, the Principles shall govern. To learn more about DPF program, and to view our certification, please visit Data Privacy Framework List.
   • Internal Compliance Mechanism. In compliance with the EU-US PDF, UK Extension to the EU-US PDF and the Swiss-US PDF, we commit to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-US DPF, the UK Extension to the EU-US PDF and the Swiss-US DPF should first contact us at: privacy@flolive.net
   • In compliance with the EU-US DPF, the UK Extension to the EU-US DPF and the Swiss-US DPF, we commit to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of Personal Data received in reliance on the EU-US PDF, the UK Extension to the EU-US PDF and the Swiss-US PDF.
   • The Federal Trade Commission has jurisdiction over Flolive’s compliance with the EU-US DPF, the UK Extension to the EU-US PDF and the Swiss-US DPF. Under certain conditions, individuals may invoke binding arbitration for complaints regarding DPF compliance that remain unresolved through other available DPF dispute resolution mechanisms.  Additional information is available at: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
   • Note that we may have potential liability for onward transfers to third parties.
     
     
10. CCPA Privacy. This privacy notice section for California residents supplements the information contained in our Policy and it applies solely to all visitors, users, and others who reside in the State of California. Capitalized terms used in Sections 10-20 have the meaning ascribed to them in the CCPA.
    
    Categories of Personal Information Collected. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.   This does not mean that all examples of that category of personal information were in fact collected by us but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.
    
    Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
    Personal information categories listed in the California Customer Records statute (Cal. Code § 1798.80(e)). A name and telephone number. Some personal information included in this category may overlap with other categories.
    Commercial information. Records and history of products or services purchased or considered.
    Internet or other similar network activity. Interaction with our Services or advertisement.
    Geolocation data. Approximate physical location.
    
11. Sources of Personal Information. We obtain the categories of personal information listed above from the following categories of sources:
    
    • Directly from You. For example, from the forms You complete on the Company’s Services, preferences You express or provide through our Services, or from previous direct communication with Us or Our employees at events, or via direct email exchange.
    • Indirectly from You. For example, from observing Your activity on our Services.
    • Automatically from You. For example, through Cookies We or our Service Providers set on Your device as You navigate through our Services.
    • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Services, third-party vendors for lead generation, or other third-party vendors that We use to provide the service to You.
      
12. Use of Personal Information for Business Purposes or Commercial Purposes. We may use or disclose personal information we collect for “business purposes” or “commercial purposes”, which may include the following examples: (i) To operate our services and provide you with our service; (ii) To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our services; (iii) To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our service, we will use that personal information to respond to your inquiry; (iv) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; (v) As described to you when collecting your personal information or as otherwise set forth in the CCPA. (vi) For internal administrative and auditing purposes; and (vii) To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.  Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.  If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.
    
13. Disclosure of Personal Information for Business Purposes or Commercial Purposes. We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes: (i) identifiers; (ii) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (iii) commercial information; (iv) internet or other similar network activity; and (v) Geolocation data.
    When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
    
14. Sale of Personal Information. Under the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.  Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
    
15. Share of Personal Information. We may share personal information identified in the above categories with the following categories of third parties: Service Providers, our affiliates, our business partners, third party vendors to whom you or your agents authorized us to disclose your Personal Information in connection with products or services we provide you.
    
16. Sale of Personal Information of Minors Under 16 Years of Age. We do not knowingly collect personal information from minors under the age of 16 through our services, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission. If you have reason to believe that a child under the age of 16 has provided us with personal information, please contact us with sufficient details to enable us to delete that information.
    
17. Your Rights under the CCPA. The CCPA provides California residents with specific rights regarding their Personal Information. If You are a resident of California, You have the following rights:
    
    • 17.1. The Right to Receive Notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
    • 17.2. The Right to Request Information. Under CCPA, you have the right to request that we disclose information to you about our collection use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm your request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information; (v) the specific pieces of personal information we collected about you; (vi) If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you the categories of personal information categories sold or disclosed.
    • 17.3. The Right to Refuse the Sale of Personal Data (opt-out). You have the right to direct us not to sell your personal information. To exercise this right, please submit an opt-out request to privacy@flolive.net. The Service Providers we partner with (for example, our analytics or advertising partners) may use technology that processes personal information in ways that constitute a “sale” under the CCPA. If you wish to opt out of the such processing of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA, you may do so by contacting us at privacy@flolive.net. Please note that any opt out choice is specific to the browser you use. You may need to opt out on every browser that you use.
    • 17.4. The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
      • 17.4.1. Complete the transaction for which we collect the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise fulfill our obligation under our contract with you.
      • 17.4.2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      • 17.4.3. Debug products to identify and repair errors that impair existing intended functionality.
      • 17.4.4. Exercise right provided for by law or comply with a legal obligation.
      • 17.4.5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
      • 17.4.6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      • 17.4.7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
    • 17.5. The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights as detailed above, including by: (i) Denying goods or services to you; (ii) Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (iii) Providing a different level or quality of goods or services to you; and (iv) Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
      
18. Exercising Your CCPA Data Protection Rights. To exercise Your CCPA rights as , and if You are a California resident, You can contact Us at privacy@flolive.net. Only You or an authorized person can make a verifiable request related to Your personal information. Your request must: (i) provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative; and (ii) describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it. We cannot respond to Your request or provide You with the request or provide You with the requested information if we cannot: (i) verify Your identity or authority to make the request; and (ii) confirm that the personal information relates to You. We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.
    

    For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

19. “Do Not Track” Policy – as required by California Online Privacy Protection Act (CalOPPA). Our website uses Google Analytics, HubSpot, LinkedIn Insight Tag, and Microsoft Clarity to track how visitors use our website and to support our marketing and analytics efforts. However, our website does not otherwise track visitors over time and across third-party websites. If you are visiting third-party websites, some of them do keep track of your browsing activities. You can set your preferences in your web browser to inform websites that you do not want to be tracked, including enabling or disabling any Do Not Track (DNT) signal by visiting the preferences or settings page of your web browser.
    
20. Your California Privacy Rights (California’s Shine the Light Law). Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
    
21. Push Notifications. We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.
    
22. Links to Other Websites. Our services and our website may contain links to other websites or applications that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s website or application. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
    
23. Changes to this Policy. We may update this Policy from time to time. The most up-to-date version will be posted on our website. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
    
24. Contact Us. If you have any question about this Policy, you can contact us at: privacy@flolive.net