July 16th 2018
ListFlow considers itself a steward of the information it collects, maintains and utilizes. Our responsibility is to ensure the security of the information in our care and to maintain the privacy of consumers through appropriate, responsible use.
We are committed to respecting everyone’s privacy and design our services with this goal in mind in accordance with European Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”) and applicable data protection laws.
This Privacy Statement is designed to tell you about our practices regarding collection, use, and disclosure of personal information that you may provide via this site.
By using this site, you agree to the terms of this Privacy Statement. Whenever you submit information via this site, you consent to the collection, use and disclosure of that information in accordance with this Privacy Statement.
This policy covers how the ListFlow Corporation (“ListFlow”) treats personal information that ListFlow collects and receives, including information related to customer past use of ListFlow products and services. Personal information is information about customers, potential customers, ListFlow website users, and others who may provide information that is personally identifiable, such as, name, address, email address, or phone number, and that is not otherwise publicly available. This policy does not apply to the practices of entities that ListFlow does not own or control or to people that ListFlow does not employ or manage.
Data Collection & Processing
This Privacy applies to all services offered by ListFlow including:
- Email Cleansing
- Email Enrichment
- Email Scoring
- Domain Search
Identity and contact details of the data controller
Personal data is collected on our site by the company HM Digital, a simplified joint-stock company registered with the RCS of Paris under number 801 813 841 and whose registered office is located at 5 bis rue Christiani, 75018 Paris.
Information collected during data processing
As part of the use of our services, namely to cleanse, enrich and score your contact lists, ListFlow has access to all the information contained in the email distribution lists that you create under your account that you send via our services.
The data is stored on secure servers and only a limited number of authorized people can access your distribution lists, including for support purposes. Information transmitted by users to the ListFlow servers as part of data processing functions of its products or services is therefore retained only to the limited extent necessary to complete the associated processing functions of the products or services.
When you register for our services, the following data is potentially collected and processed: email, civility, first name, name, country, VAT number if applicable, password, postal address, telephone number, address (es) IP and domain name. By using our services, the following data is collected and processed: login data and navigation data when you authorize it, order history, complaints, incidents, subscription information and correspondence on our site. If you become a paying customer, we will collect your payment card information.
Treatment goals and legal basis
The main purpose of collecting your personal data is to offer you a safe, optimal, efficient and personalized experience. To this end, you agree that we may use your personal data to:
- provide our services and facilitate their operation, including conducting audits of you;
- resolve potential issues to improve the use of our site and services;
- customize, evaluate, improve our services, content and documentation;
- analyze the volume and history of your use of our services;
- inform you about our services and those of our partner companies;
- prevent, detect and investigate any potentially illegal, illegal or contrary to good practice activities, and ensure compliance with our general terms and conditions and our shipping policy;
- comply with our legal and regulatory obligations.
Your IP address is used to help identify you and to gather advisable information. IP addresses are also used to provide an audit trail regarding use of our services, from which we may discern patterns and profiles about your usage.
We use servers to look at publicly available online pages and process business data on them. Only public pages are looked at and only publicly available online data that can be found by a search engine are indexed by our servers. If a website, via a robots.txt file, asks crawlers not to look at the content, we respect this indication. Our robots view systematically the robot.txt file before exploring and indexing the public data available on the website. We are not responsible for the privacy policies and practices of other websites. Please always review the privacy practices of a company before deciding whether to provide any information.
On those public pages, we look for business data such as names, professional emails, social networks URLs, etc. If we come across private consumer data (for example a Gmail or Hotmail address), we do not process it.
Services that help us manage your data
To provide our services, we rely on other companies that can partially manage your data. We carefully select our providers to ensure the privacy and security of your data. Our biggest providers are:
- To secure connections with our users and speed up our services: Cloudflare, Amazon Web Services (AWS)
- Hosting: AWS & OVH
- Customer support: Intercom, Sendinblue
- For internal collaboration and emails: G Suite (Google)
Sharing and disclosure of information
We may disclose your Personal Information for the purposes described in this Privacy Statement, including to third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
ListFlow may provide personal data to third parties that act as agents or subcontractors to perform tasks on behalf of and under specific instructions. Such third parties must agree to use personal data only for the purposes for which they have been engaged by ListFlow and must contractually agree, through European Commission model clauses and/or similar agreements, to comply with the Privacy Shield principles or another mechanism permitted by the applicable EU data protection law(s) for transfers and processing of personal data.
ListFlow also may disclose personal data for other purposes or to other third parties when an individual data subject has consented to or requested such disclosure.
The term “Personal Information”, as used in this Privacy Statement, refers to any information that can be used to identify or relates to an identifiable person. Personal information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. Personal Information we collect may include:
- Email addresses
- Telephone number
- Credit and debit card number
- ListFlow account ID and password
Personnaly identifiable Information Collection and General Use
ListFlow may gather information related to the use of its products and services, registration of a user account on the ListFlow website, or in the course of standard business practices. Personally identifiable information (“PII”) is collected from such parties only after obtaining consent, which is obtained when such parties are prompted for information when requesting product information, downloading a trial version of a product, registering a new user account, registering a product, purchasing a product or service, or contacting customer support. ListFlow may collect usage statistics to enable ListFlow to improve user experience and allocate internal resources.
Purchasing ListFlow products or services requires a customer to provide certain personal information and enter into a License Agreement. Nothing herein is intended to modify the terms in such a License Agreement.
ListFlow reserves the right to send certain communications relating to its products or services, such as service announcements, administrative messages, feedback requests that are considered part of routine technical support procedures.
Security and duration of the processing
As part of its services, ListFlow places the utmost importance on the security and integrity of its customers’ personal data.
Thus, and in accordance with the GDPR, ListFlow commits itself to take all necessary precautions to preserve the security of the data and in particular to protect them against any accidental or illicit destruction, accidental loss, alteration, diffusion or unauthorized access, as well as against any other form of unlawful processing or communication to unauthorized persons.
Although no data transmission can be guaranteed to be 100% secure, we take reasonable steps to protect Personal Information. ListFlow maintains reasonable administrative, technical, and physical procedures to protect information stored in our servers, which are located solely in the European Union (EU).
For users of our service, we process your data as long as your account stays active and after 2 years of inactivity. Once your account is deleted or after 2 years of inactivity, we remove almost everything within a few days and all remaining artifacts within 3 months. If you’ve paid for ListFlow, we might keep some information regarding your company for longer to comply with our legal obligations.
If your data was found online, we process it as long as it stays online. We make sure to regularly come back where we found it, if it isn’t there anymore or if we believe that your personal data that we hold is inaccurate, we remove it from our databases and stop all processing.
Your rights, controls and choices
We provide customer support via email or chat, to help you take full advantage of our service or fix any problem you might encounter.
Right to Access, Amend or Delete Personal Information
You have the following rights in relation to the personal data that we hold about you:
- To access your personal data, i.e. know if we have information concerning you and what that information is;
- To require any inaccurate personal data to be rectified, completed including by means of providing a supplementary statement;
- To require us to delete the personal data in certain circumstances;
- To require us to restrict or block the processing of your personal data in certain circumstances (when processing is restricted, we can still store your personal data, but may not use it further);
- To obtain from us your personal data, in a structured, commonly used and machine-readable format in certain circumstances. Further, you may have the right to require us to transmit your personal data directly to another person where it is technically feasible to do so;
- To object to our use of your personal data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal data (and require them to be deleted) in some other circumstances;
- Where we are processing your personal data based on your consent to such processing, to withdraw your consent at any time.
Individual data subjects in the European Union have the right to know what personal data about them is stored in ListFlow databases and to ensure that such personal data is accurate and relevant for the purposes for which ListFlow collected it. Individual Customers may review their own personal data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and ListFlow policies. Upon reasonable request, ListFlow allows individual Customers access to their personal data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting ListFlow Technical Support by email or phone at: firstname.lastname@example.org or +33 (0)1 85 08 37 48. In making modifications to their personal data, individual data subjects must provide only truthful, complete, and accurate information. To request complete erasure of personal data, individual data subjects are required to submit a written request.
ListFlow will endeavor to respond in a timely manner (thirty/30 days) to all reasonable written requests to view, correct, amend, or delete all personal data of data subjects.
You have the opportunity to opt-out of any disclosures by ListFlow of your personal information in accordance with this Policy. Our opt-out procedure is simple and straightforward. In order to opt-out, please contact us by sending an email to email@example.com and inform us that you are electing to opt out of any and all disclosures of your personal information by ListFlow. We will promptly honor and confirm your request by email or mail.