Privacy Notice: The Flow Technologies BV

Version: April 2021

1.              Introduction

The Flow Technologies BV takes the management and the protection of data serious. This Privacy Notice describes how we use your Personal Data when you reside in or visit one of our building(s), when you interact with us, when you use our app or when you use any of the other services we offer (hereinafter jointly referred to as: “Services“).

2.              Scope of this Privacy Notice

This Privacy Notice applies to the use of Personal Data of the residents and visitors of our building(s), for which The Flow Technologies BV is the data controller.

This includes Personal Data of the following individuals:

  1. Residents (i.e. individuals working for a company renting office space at a The Flow Technologies Building (hereinafter jointly referred as: “The Flow”) : When you use our Services, we collect and use your Personal Data.
  2. Visitors: When you visit our building(s), we collect and use your Personal Data we receive either directly from you, or from your host.

3.              Personal Data we collect

Below an overview is given of the types of Personal Data we collect, the legal bases on which we do so and for which purposes. The exact types of Personal Data we collect from you will depend on your relationship with a The Flow (resident or visitor) and which Services you use.

Types of Personal Data Legal bases Purposes
Personal Data required to register at The Flow as a resident:

Your first name, surname, the company you work for, your license plate (if applicable), and any other contact details you provide to us, such as your telephone number and email address.

 

 ·      For the performance of our agreement with you or to enter into an agreement with you

·      Our legitimate (commercial) interests

·      Your consent

 

 ·      To carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information and Services that you request, including managing and handling your requests, inquiries or complaints;

·      To understand who is in our building(s) for safety purposes, therefore we register information regarding our visitors;

·      To send you updates about any new Services we provide, e.g. via the app or email (only after receiving your consent thereto).
Personal Data required to register at The Flow as a visitor:

Your first name and surname, the company you will be visiting, your license plate (if applicable), your time of arrival and any other contact details you provide to us, such as your telephone number and email address.

 ·      Our legitimate (commercial) interests

·      Your consent

 

 

 ·      to understand who is in our building(s) for safety and security purposes.
Personal Data required for the operation of our face recognition system:

Your photograph (more specifically: a unique collection of measurements of your face derived from your photograph).

 ·      Your consent

Please note that the use of our face recognition system is optional and requires your prior explicit consent. If you do not wish to provide your photograph for authorization purposes, let us know and we will arrange alternative means for authorization.

Also note that you may refuse or revoke your consent at any time, as set out below (see ‘Your Rights’).

 For authorization purposes, such as:

·      to facilitate and optimize access control to (parts of) our building(s); and

·      to facilitate and optimize  Services provided at The Flow, such as ordering lunch at our building(s) (pay-by-face).

 
Personal Data collected via (customer satisfaction) surveys ·      Our legitimate (commercial) interests ·      To improve our customer satisfaction and offer better Services.
Personal Data relating to the use of Services provided at The Flow:

We collect information relating to your use of Services (incl. the app), such as the Services you use, the frequency of such use, your preferences, your access  and purchases within the building(s), etc.

 ·      For the performance of our agreement with you or to enter into an agreement with you

·      Our legitimate (commercial) interests

 ·      To be able to provide our Services to you;

·      To operate and expand our business activities and to develop and improve our Services (e.g., we analyse the Services you use and like, how you use these products and Services, which recommendations we can give you when use our Services).

 
Your communication data:

Your requests, any complaints you may have and any other data that we receive if we communicate with you via email or online.

 

 ·      For the performance of our agreement with you or to enter into an agreement with you

·      Our legitimate (commercial) interests

 

 

 ·      To provide you with (technical) support and answer any questions you may have.
Recording of CCTV footage:

When you enter our building(s), you are recorded by our video surveillance systems (CCTV).

 

 ·      Our legitimate interests

 

 ·      To maintain the security of our building(s) and the safety of our residents, visitors and staff;

·      To assist in security and fraud prevention.

 
Any other Personal Data:

This includes any Personal Data that you disclose to us during the course of your contractual relationship with us, either voluntarily or upon request.

 

 ·      For the performance of our agreement with you

·      Your consent

 ·      Depending on the purpose for which you provide us your Personal Data, such as to provide additional specific services to you or to comply with your requests.

 

4.              How we share your Personal Data

We share your Personal Data with other parties who assist us in our delivery of (a part of) our Services or in order to operate our business activities. We will only do so on a strictly need-to-know basis and after entering into the necessary contractual arrangements with such parties.

For these purposes, we share your Personal Data with the following parties:

  • Service Providers. We engage third party service providers to assist us in providing (a part of) the Services, such as suppliers and sub-contractors (including IT service providers and smart building or proptech solution partners). In providing their services, they will act as a processor on behalf of The Flow.
  • Business partners. If the Services are offered by one of our partners, such e.g. security, access or F&B parties, your Personal Data will also be shared with such partner if required for the performance of the Services.
  • Your employer. It may be the case that your employer allows you to use certain Services we provide. The Personal Data in relation to your use of such Services will then be shared with your employer.
  • Third parties in case of legal requirement. We also disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process served on us, or to protect the rights or safety of the website, us or our affiliated companies.
  • Corporate transaction. In addition, information about our customers, including Personal Data, may be disclosed as part of any merger, sale, transfer of The Flow’s assets, acquisition, bankruptcy, or similar event.

 

5.              International transfers of your Personal Data

In most cases your Personal Data will be processed within the European Union. However, The Flow may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection to your Personal Data. The Flow or third parties we use will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer.

 

6.              Security

The Flow will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.

 

7.              Data Retention

We retain your Personal Data on the basis of applicable laws and regulations and as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to provide you our Services, answer queries or resolve technical problems), unless a longer period is necessary on the basis of applicable laws. For example our CCTV footage is stored for a period of 4 weeks and deleted afterwards, unless an incident occurred, in which case The Flow will retain the footage long enough for the incident to be investigated. If you would like to receive further information on how long we collect your Personal Data, please contact dataprotection@theflow.tech.

8.              Your Rights

Subject to the conditions set forth in the applicable law, you have the right to request, review, correct, update, suppress, restrict or delete Personal Data that you have provided to us or if you would like to request to receive an electronic copy of such Personal Data for purposes of transmitting it to another company, by sending an email to dataprotection@theflow.tech specifying your request.

Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

In the event your Personal Data is processed on the basis of your consent, you can withdraw consent at any time by sending an email to dataprotection@theflow.tech specifying your request.

You may lodge a complaint with the Autoriteit Persoonsgegevens, if you consider that the collection and use of your Personal Data infringes this Privacy Notice or applicable law.

9.              Changes to this Privacy Notice

This Privacy Notice may be revised from time to time. If a fundamental change to the nature of the use of your Personal Data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.

10.           Contact us

If you wish to exercise any of your rights or if you have questions with respect to this Privacy Notice, please contact dataprotection@theflow.tech