Privacy Policy: Revised October 2, 2020

Five to Flow (collectively, “Five to Flow, “us”, “we” or “our”) is committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with the business activities listed on our website. Please see our Terms of Use for more information about our online terms and policies in general.

Five to Flow collects personal data in the course of its business activities and may include, but is not limited to, when you sign up on our site, take the Wellness Wave, and click on the Site or its various reports, videos or articles. We will not sell, rent, share or otherwise disclose your personal data to anyone, except as necessary to provide our services or as otherwise described in this Policy, without first providing you with notice and the opportunity to consent.

1. Data Collection:The personal data collected varies and may include information you provide, such as your name, physical address, email address and telephone number. We may also automatically collect log data about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.

Five to Flow’s website is not intended for individuals under the age of 18, and it will not knowingly collect personal data from any person under the age of 18.

2. Data Use:We may use data for the purpose of our benchmarking and data analytics activities, fulfilling your requests for information, sharing across the Collective to improve our services, distributing newsletters, articles and videos, analyzing the Sites’ performance and functioning, publishing your testimonials, preventing fraud, enforcing our Terms of Use, complying with all applicable laws and with corporate reporting obligations, enforcing Five to Flow’s agreements, and accomplishing other purposes you may initiate or request.

Five to Flow and its service providers may use first and third-party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites, our services and collect analytics about how you use them.

a. Cookies

On the Five to Flow website, you have to opt-in to cookies. Cookies are small text files that can be used by websites to make a user's experience more efficient. ​ Applicable law states that we can store cookies on your device if they are strictly necessary for the operation of our site. For all other types of cookies, we need your permission.

Some cookies are placed by third-party services that appearing on our page. ​ Five to Flow uses cookies to understand how important our content is to you and to analyze traffic to our website. ​ We also share information about your use of our site with our marketing vendors who may combine it with other information that you have provided to them or that they have collected from your use of their services. ​ Five to Flow uses the following cookies:

  1. Necessary cookies help make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
  2. Statistic cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.
  3. Marketing cookies are used to track visitors across websites and for remarketing efforts. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

You can configure your web browser to refuse cookies or to notify you when a website attempts to send you a cookie. ​ You can also check your hard drive for cookie files and delete them from your computer. If you disable cookies, you may find a certain section of the Five to Flow website does not work properly. ​

3. Data Storage & Your Rights:We will collect and process your personal data only when we have 1) your consent to do so; 2) an agreement in place with you or your company; 3) a legal obligation to do so; 4) another legitimate business interest or 5) to protect your vital interest or that of another person.

Where we rely on your consent to process your personal data, you have the right to withdraw consent at any time. ​ Where Five to Flow relies on a legitimate interest to process your personal data, such as an agreement with Five to Flow, you have the right to object. ​ Your rights also include the right to access, correct, update, export or delete your personal data. ​ You may email gratitude@fivetoflow.com with any request, and we will respond within 14 days. ​ Subject to any exemptions provided by law, if you exercise your right to be forgotten, your personal data will be deleted from Five to Flow’s systems, and you will receive confirmation of such. Five to Flow will also notify its business partners and third-party data processors of your request and direct them to also delete your personal data.

Five to Flow may disclose your information to business partners or third-party data processors in accordance with a properly-executed court order or as otherwise required by law.

a. Your California Privacy Rights : If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information gratitude@fivetoflow.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested. As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of personal data collected, processed, and disclosed by Five to Flow, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed. In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about Five to Flow’s collection, use, disclosure, and sale of personal data about you including:

  1. The categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information,
  2. The categories of sources from which we have collected that information in the preceding 12 months,
  3. The commercial or business reason(s) we have collected, used, disclosed, or sold that information, and
  4. The categories of third parties to whom we have disclosed or sold that information in the preceding 12 months.

In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months. You may also have the right to request deletion of personal data about you that we have collected or maintained, which we will honor subject to certain limitations set forth in California law. If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us at gratitude@fivetoflow.com. When we process your request, we require you to provide certain personal data about you in order to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. Five to Flow will not discriminate against you based on your exercise of any of these rights.

4. Disclosure and Transfer of Data:Using the Internet to collect and process information about you may involve the transmission of data internationally. Therefore, by browsing Five to Flow’s site, you acknowledge and agree to the processing of your information in this way. ​ By agreeing to Five to Flow’s transfer of your information to third parties, you are deemed to have consented to any transfer of your information to a third party that Five to Flow works with outside the European Union.

Personal data collected in the course of Five to Flow’s business activities, may be transferred from time to time to its subsidiaries and affiliates and their personnel across our global organization, as well as to our third-party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Five to Flow and our third-party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Five to Flow subsidiaries, affiliates and third-party service providers, including the transfer of your personal data to countries other than the one in which you reside.

Five to Flow will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law. Five to Flow may provide access to your personal data to third -party service providers engaged by Five to Flow to provide services related to the Sites as well as related to Five to Flow’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

In addition, we may disclose information about you:

  1. If we are required to do so by law or legal process;
  2. To law enforcement authorities or other government officials;
  3. When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  4. If disclosure is necessary to protect the vital interests of a person;
  5. To enforce our Terms of Use;
  6. To protect our property, services and legal rights;
  7. To prevent fraud against Five to Flow, our subsidiaries, affiliates and/or business partners;
  8. To support auditing, compliance, and corporate governance functions; or
  9. To comply with any and all applicable laws.

5. Security:Five to Flow has commercially-appropriate measures in place to ensure your information is protected against unauthorized access or use, alteration, unlawful or accidental loss or destruction. ​ We also have systems in place to authenticate, monitor, audit and encrypt your information. Nevertheless, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee that information in our care will be absolutely safe from intrusion by others. It is important that you protect against unauthorized access to your account information and your computer.

6. Revision: By visiting the site, you are legally bound by the terms of this policy. ​ Five to Flow ​reserves the right to revise, update or change the terms of this Privacy Policy at any time without prior notice to you. ​ All modifications or changes shall be effective upon posting the updated policy on the Five to Flow website. ​ You should visit this page regularly to review the current terms. Your continued use of the site will be deemed as irrevocable acceptance of any revisions to this policy.

7. Exclusions:Five to Flow’s website links to third-party websites that are not the subject of this Privacy Policy. ​ We recommend you read the Privacy Policies of any third-party websites that you visit.

8. Contact Us: If you have any questions about Five to Flow’s GDPR compliance or data privacy, or would like to submit a request related to your data, please email gratitude@fivetoflow.com.

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