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: June 20, 2018

Flikli Inc. (“Flikli”, “we”, “us” or “our”, as appropriate) is committed to protecting the privacy and confidentiality of the personal information entrusted to it by the users of its websites, products and services.

This Privacy Policy governs the collection, use, storage and disclosure of the personal information of the users (“User(s)” or “you”) of our websites, products, and services, including http://platform.flikli.com (the “Platform”, and, together with Flikli website, the “Site”).

Note that this Privacy Policy constitutes an integral part of the terms and conditions of use of our Site, in addition to any terms and conditions specific to the Platform use, as applicable.

Collection of Personal Information

We may collect personal information that can identify you, when you (i) access our Site, (ii) subscribe to our Platform or services, or (iii) order or request information about our products or services.

The personal information we collect from you includes your name, mailing address, email address, phone number and your payment details. We will collect personal information from Users only if they voluntarily consent to submit such information to us. Users are under no obligation to supply their personal information, with the caveat that it may prevent them from engaging in certain Site or Platform related activities.

By providing their personal information or by using our Site, Users are consenting to Flikli’s collection, use, storage, and disclosure of your personal information in accordance with this Privacy Policy and all applicable laws.

For personal information of Users located in the European Union (“EU”) or using our Site tools which are offered to EU residents, the collection, use, storage, and disclosure of your personal information will be made in accordance with this Privacy Policy and in compliance with the applicable requirements of the General Data Protection Regulation (EU 2016/679) (“GDPR”). If you think GDPR may apply to you, please refer to the appropriate section of this Privacy Policy for more details about the processing of your personal information and your rights with respect to such processing.

In addition to personal information, we may collect other information about Users whenever they interact with our Site. This information may include the browser name, the type of computer and technical information about Users’ means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Purposes of collection

Flikli may collect personal information of Users for the following purposes:

  • To improve customer service

Personal information you provide helps us respond to your customer service requests and support needs more efficiently.

  • To personalize user experience

We may use your personal information in aggregate to understand how our Users as a group use the services and resources provided on our Site.

  • To process payments for our products or services

We may use the personal information Users provide about themselves when placing an order or accepting a production task, only to provide the product or service related to that order or production task. We do not share this personal information with third-parties except to the extent necessary to provide the service.

  • To send notification emails

We may use the email address provided by the User to send information and updates pertaining to its order or production task. It may also be used to respond to the User inquiries, questions, and/or other requests, as made from time to time.

Flikli will not use or disclose personal information of Users for purposes other than those for which it was initially collected, except with the User consent or as otherwise permitted or required by applicable laws.

How we protect your personal information

We have implemented and maintain appropriate data collection, storage and processing practices and security safeguards to protect against any unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Exchanges of payment details and other financial information between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

Disclosure of your personal information

We do not sell, trade, or otherwise transfer your personal information to third-parties. We may however disclose your personal information to our representatives, affiliates, suppliers or other third parties with whom we do business (our “Business Partners”) when it is deemed necessary for our business operations. Our Business Partners and any other third-party service providers will only have incidental access to personal information to the extent required to perform their services. They are prohibited from using your personal information for any purpose other than assisting with our business operations.

We may also share generic aggregated demographic information not linked to any personal information regarding our Users with our Business Partners and trusted advertisers for the purposes outlined above.

Changes to this Privacy Policy

Flikli reserves the right to update this Privacy Policy at any time. When we do, we will post a notification on the main page of our Site. We encourage Users to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Access to and Deletion of your personal information

If your Personal Information changes, or if you no longer desire to access our Platform, you may correct, update, amend, delete/remove it by contacting us through our Privacy Officer, whose contact details are provided below.

We may require that you provide us with acceptable verification of your identity before providing access to such information.

General and anonymous data related to the terminated account may be retained to ensure consistency of our databases and to allow retrieving historical data about services provided.

Data retention

Flikli will retain the personal information collected only for such period as is reasonably necessary for the fulfillment of the purposes for which it was collected and listed above or to comply with any legal requirements, including statutory retention periods.

Web browser cookies

Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

Third party websites

Our Site, including products or services available therein, may contain hyperlinks or other “computer” links to website from third parties (“Third Parties websites”) that can cause leaving the Site currently browsed. Flikli provides these links only for convenience, and the inclusion of any link does not imply endorsement by Flikli of the website linked to. Accordingly, any personal information that is transmitted by use of Third Party Websites is subject to the privacy policy of the relevant Third Party Websites. It is the responsibility of the Users to consult these policies in order to ensure that their Personal Information is being protected.

Contact

Flikli is responsible for personal information under its control and has designated a Privacy Officer who is accountable for this Privacy Policy and applicable Canadian governing laws. Should you have any questions, concerns or claims about your personal information or Flikli privacy practices, please contact our Privacy Officer at the information below.

Our Privacy Officer may be contacted by email at: support@flikli.com or by phone at: +1 226 929 3540.

European Economic Area (EEA) Notice

Transfers of Personal Information

Flikli is a data controller and is responsible for your personal information, which the Flikli processes and stores in Canada as well as well as in other jurisdictions where our servers, maintained by our third-party service providers, may be located. The European Commission has decided that Canada ensures an adequate level of protection of individuals’ personal information. We may use the following safeguards when transferring your personal information to a country, other than Canada, that is not within the EEA:

  • Only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal information;
  • Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in the EU.

Opt-in

If you are an EU resident, we may only collect your data using cookies and similar devices, and then track and use your personal information where you have first consented to that. We will not automatically collect personal information from you unless you have consented to us doing so. If you consent to our use of cookies and similar devices, you may at a later date disable them.

Your Legal Rights

Under certain circumstances, as an EU resident, you may have rights in relation to your personal information, including the right to:

  • Request access to your personal information.

This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of your personal information.

This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

  • Request erasure of your personal information.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal information.

You may exercise this right in the event that we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

  • Request restriction of processing your personal information.

This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

  • Request transfer of your personal information.

Upon your request, we will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Right to withdraw (revoke) consent.

You may exercise this right where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact our Privacy Officer. Please also note that the following will apply:

No Fee Usually Required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we my charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.