Privacy Policy
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Privacy Policy
Table of contents
Effective as of 31 August 2026
- Policy scope, controller and effective date Legal Rights & Agreement Rules
If you want to see older versions of this policy, click here.
Your body, your data. At Flo, privacy is our top priority. We will never sell your data. We are based in the United Kingdom, and comply with the highest global standards of data protection laws, including the GDPR. This means that no matter where you are in the world, you can trust that Flo is committed to keeping your personal data safe.
- Flo promises never to sell your data Sharing & Disclosure
This policy explains how we handle your personal data. Here’s a quick summary. You should still read the full policy as well as our Terms of Use.
Safeguarding Your Data: Flo’s dedication to Privacy and Security
We are proud to hold two certifications for internationally recognised privacy and security standards. Flo has obtained independent certifications called:
- Flo reports privacy and security certifications Security & Safeguards
- ISO/IEC 27001 for Information Security; and
- Flo reports privacy and security certifications Security & Safeguards
- ISO/IEC 27701 in Privacy.
- Flo reports privacy and security certifications Security & Safeguards
Our certifications show our promise to keep your information secure and manage your privacy to a high standard. When you use Flo, you trust us with your personal data. We promise to always be clear about how your personal data is used, protect your rights and respect your data.
- Flo reports privacy and security certifications Security & Safeguards
Anonymous Mode
Flo is the first female health app to add further privacy to your personal data by creating and providing Anonymous Mode. This feature is available to all Flo users and lets you use the app without linking your name, email address or technical identifiers to your data. This means we can’t identify you if you switch to Anonymous Mode and neither can any third parties.
- Anonymous Mode reduces identity linkage without guaranteeing perfect security Linking & Identification
- Anonymous Mode unlinks identifying details from health data Linking & Identification
Data that helps to serve you
When you use Flo, we collect your personal data to make your experience better. This includes ensuring the safety of our Services, improving the accuracy of your predictions and giving you relevant content and offers.
- Data supports predictions, content and service safety Use & Processing
You can contribute to the growth of the Flo community
If you agree, we may use information about your device and other details (such as your device’s ID, your age group, subscription status, email and the fact you launch the app) to spread the word about Flo.
- Promotion using device and account details requires agreement Sharing & Disclosure
You’re in control and can reach out to us
You can reach out to us anytime. You can access, change, correct, delete and update your personal data by emailing us at support@flo.health. Or you can get in touch with our data protection officer at dpo@flo.health. If you gave us consent to process your personal data, you can take your consent back at any point. If you have any questions about this Privacy Policy, let us know.
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Use the chatbot or support contact, and withdraw health-data consent Account & Service Control
We limit children’s access to the app
You must be at least 13 years old to use the app. If you are in the European Economic Area, United Kingdom and Canada, you must be 16 years old.
- Minimum app age depends on location Account & Service Control
1. Introduction
This Privacy Policy explains how Flo Health UK Limited and our other companies (“Flo” or “we” or “us”) follow privacy laws such as the General Data Protection Regulation (“GDPR”), the UK GDPR, and any other laws that protect your personal data. It also describes how Flo collects, stores, uses, and shares personal data from you through the Flo mobile application, the Flo Period & Ovulation Tracker application (the “App”),* and the flo.health website (the “Website”), including all subdomains, products and services (together, the “Services”).
- Policy scope, controller and effective date Legal Rights & Agreement Rules
Flo Health UK Limited is a company registered in the U.K. and the registered data controller of the Services.
- Policy scope, controller and effective date Legal Rights & Agreement Rules
*The App might have different names depending on your location. A full list of names is available here.
- Policy scope, controller and effective date Legal Rights & Agreement Rules
We may update this Privacy Policy and any addendums from time to time. We review them at least once a year and make updates if needed to ensure they remain accurate. If there are material changes to this policy that we need to tell you about, we will let you know by email or through the App.
- Flo reviews the policy annually and notifies material changes Legal Rights & Agreement Rules
The latest updates to this policy are available on our Website and in the App.
- Flo reviews the policy annually and notifies material changes Legal Rights & Agreement Rules
2. Personal data we collect from you
We collect personal data about you when you use the Services. This can come directly from you or from other sources and third parties.
- Account details and inferred sex or gender Data Access & Collection
Personal data you provide to us directly:
- General information: When you sign up for our Services, we collect personal data like your name, email, birth month and year, password, location, time zone, and language. Based on how you use the Services, we may also infer your sex or gender.
- Account details and inferred sex or gender Data Access & Collection
You can also enter your first name or a preferred name. This is completely up to you and won’t impact your use of the Services if you choose not to provide it.
- Account details and inferred sex or gender Data Access & Collection
- Well-being: When using our Services, you may enter personal data (including ‘special category data’ as defined in the UK GDPR) about yourself, such as your weight, height, BMI, body temperature, and menstrual cycle details. If you enable pregnancy mode, you can also input and track pregnancy-related information. You may log symptoms linked to your menstrual cycle, pregnancy, perimenopause, or menopause, as well as general health and well-being. This can include details about your sex life, physical and mental health, water intake, and sleep duration.
- You may log sensitive health and well-being details Data Access & Collection
- Third-party services (including wearables): With your permission, we can connect to third-party services like Apple HealthKit and Google Health Connect. This allows us to automatically import your health and activity data into the app, so you don’t have to log it yourself. The imported data may include fitness activities, weight, height, BMI, calories burned, heart rate, steps taken, distance traveled, body temperature, sleep patterns, and other activity details.
- Optional health-service connections import activity and health data Linking & Identification
- Consent supports personalised app features and cycle predictions Inference & Profiling
This information helps provide insights into your activities and improves our ability to predict your cycle. We process this data to enhance the App’s features and functionality.
- Optional health-service connections import activity and health data Linking & Identification
Importing data is subject to the privacy policies and terms of Google Health Connect and Apple HealthKit. If you use a wearable device to connect to Flo, please review its terms and privacy policies as well. Your device provider may collect usage data for its own purposes, such as improving its services.
- Optional health-service connections import activity and health data Linking & Identification
- Consent supports personalised app features and cycle predictions Inference & Profiling
Personal data we collect automatically:
When you use the Services, we may automatically collect certain information:
- Flo may automatically collect device and accessibility information Data Access & Collection
- Device information: device model; information about the operating system and its version; unique device identifiers; enabled device accessibility features (e.g., display features, hearing features, and physical and motor features); mobile operator and network information; device storage information or version of your device system.
- Flo may automatically collect device and accessibility information Data Access & Collection
- Location information: IP address for an approximate location; country; time zone or information about your mobile service provider. We do not collect your exact location. We only use location details for the reasons listed below.
- Location collection is approximate Data Access & Collection
- Data about your use of the Services, including: frequency of use; areas and features of the Services that you access or use; payment transaction information (excluding full payment card details) or engagement with features.
- Usage and transaction data may be collected using cookies Data Access & Collection
To collect this and other information, we may use cookies and other similar technologies. See more in our Cookie Policy.
- Usage and transaction data may be collected using cookies Data Access & Collection
Data from external sources: We may receive your personal data from third parties. For example, they may provide additional information to enhance your existing data, personalise your experience, and support analytics and statistics.
- Third parties may supply additional personal data Data Access & Collection
3. How we use your personal data
Depending on the features you use, we will process your personal data based on the following reasons:
- Processing bases depend on the feature and purpose Legal Rights & Agreement Rules
Your consent: You can allow us to process your health data to provide the Services.
- Processing bases depend on the feature and purpose Legal Rights & Agreement Rules
Contractual obligations: We process certain personal data to meet our contractual commitments to you, such as managing your Flo account and handling administrative tasks.
- Processing bases depend on the feature and purpose Legal Rights & Agreement Rules
Legitimate interests: We may process your personal data based on our legitimate interests to improve our Services. For example, we might use your personal data to:
- Flo lists service improvement and safety as legitimate interests Use & Processing
- identify and fix issues;
- Flo lists service improvement and safety as legitimate interests Use & Processing
- fraud prevention, including ensuring interactions (e.g. app-installs) are from real members, not bots;
- Flo lists service improvement and safety as legitimate interests Use & Processing
- improve content in the App;
- Flo lists service improvement and safety as legitimate interests Use & Processing
- monitor and analyse App performance;
- Flo lists service improvement and safety as legitimate interests Use & Processing
- notify you about your subscriptions;
- Flo lists service improvement and safety as legitimate interests Use & Processing
- scan for vulnerabilities to ensure security; and
- Flo lists service improvement and safety as legitimate interests Use & Processing
- review overall App usage trends and forecast customer retention.
- Flo lists service improvement and safety as legitimate interests Use & Processing
We carefully balance our interests with your rights to ensure our activities don't negatively impact you or your rights. More examples of our legitimate interests are listed in the table below.
- Flo lists service improvement and safety as legitimate interests Use & Processing
Legal obligation: We may be legally required to process your personal data to comply with applicable laws and regulations.
- Processing bases depend on the feature and purpose Legal Rights & Agreement Rules
Below, we describe the purposes for Flo’s processing of your personal data, our lawful bases for doing so, with some basic examples:
Purpose of processing Legal basis for processing Example
To support the App’s features, including tailored content, insights and materials in the App, we use the personal data you provide within the App; machine learning models for cycle predictions; the Services you choose to use (e.g. your selected mode) and the App features you interact with; information from connected third-party services (like Apple HealthKit and Google Health Connect); and certain information provided in onboarding questionnaires. Consent We use your cycle data to predict future cycles or ovulation, analyse your personal data to offer new features and Services, and suggest articles or materials (e.g., stories, Health Assistant, and Secret Chats) for you to read.
- Optional health-service connections import activity and health data Linking & Identification
- Tecton processes cycle, goal and symptom data for machine learning Inference & Profiling
- Consent supports personalised app features and cycle predictions Inference & Profiling
We also customize product and service recommendations and cycle date notifications to you, such as through emails or push notifications. We may also contact you about third-party products and offers. Consent We may offer you a discount for Flo Premium.
- Marketing opt-out leaves essential service emails in place Use & Processing
- Personalised recommendations and cycle notifications use consent Use & Processing
We process transactions and send related information, including confirmations and reminders about your subscription, for account management reasons and other administrative purposes. Contract We use your device data to send reminders, like push notifications, if your subscription has expired or is about to expire. If applicable, we may also email you your invoice.
- Transactions and account notices use the contractual basis Charges & Financial Obligations
To respond to your comments, questions, requests and to provide you with customer service. Legitimate interest We use your name and email to respond to your support request or to contact you about a specific question or issue you’ve raised.
To review App content, feedback and complaints to ensure the App’s clinical safety and medical accuracy. Legitimate interest We use your name and email to review support requests that need our medical team’s attention.
To send you technical notices and updates; security alerts, ensure the safety of our App and investigate incidents; support and administrative messages; and customer satisfaction surveys. Legitimate interest To request that you update your App to ensure you have access to the latest features.
To enhance your user experience and connect data between the Website and App during the onboarding process.
- AppsFlyer connects website signup to the app Linking & Identification
Legitimate interest When you sign up for the Services on the Website, we use a third party deeplinking service, AppsFlyer, to help us identify you as an existing member when you download the App.
- AppsFlyer connects website signup to the app Linking & Identification
To monitor and analyse trends, usage and activities in connection with our App. Legitimate interest We review your usage activity in the App to make sure it works correctly, fix any issues, serve you relevant content, and improve your future experience. We may also use overall usage trends to deliver the right content, sales campaigns and offers to you.
- Usage analytics can shape content, campaigns and offers Use & Processing
Promotional communications regarding our Services. Consent If you give your consent and we use your personal data, we can post your review or comment on our Website.
- Consent covers testimonials, surveys and promotions Sharing & Disclosure
To enable you to participate in surveys and promotions.
- Consent covers testimonials, surveys and promotions Sharing & Disclosure
Consent If we ask you to participate in a survey or promotion, we use your name, survey responses and any other content (e.g. testimonial videos) that you provide for product improvement and marketing purposes. We may give you a gift for participating in the survey or promotion, so will process your contact details to provide you with this gift.
- Consent covers testimonials, surveys and promotions Sharing & Disclosure
Promote Flo by improving how our advertising and campaigns perform Consent We use some technical identifiers to help us understand which advertisements are effective and where our users are coming from. This allows us to improve how Flo is promoted. The personal data we use for this purpose does not include health data.
- Advertising measurement excludes health data and requires consent Sharing & Disclosure
Sign up to Flo through Flo’s commercial partner offerings Contract If you sign up to Flo through a Flo partner offer, we’ll use unique identifiers to verify that you are a subscriber to the partner’s service.
- Commercial partner signup uses identifiers to verify eligibility Account & Service Control
Principles of processing
Data minimisation and purpose limitation: we only process personal data for the specific purposes for which it was collected or authorised by you.
- Personal data is limited to collected or authorised purposes Use & Processing
No sale of personal data: we do not sell or rent your personal data for money. We will only share your personal data as outlined in this Privacy Policy. This includes sharing your personal data with our service providers who help us operate our Services. We will not use information from Apple HealthKit or Google Health Connect for advertising or sell it to advertising platforms, data brokers or resellers.
- Flo promises never to sell your data Sharing & Disclosure
- No paid sale or rental; specified service and marketing sharing remains Sharing & Disclosure
4. Your privacy rights
Regardless of where you live, we’re committed to providing you the same privacy rights afforded under the GDPR, which is generally regarded as the highest standard for data protection globally.
- Worldwide rights requests require identity and authority checks Account & Service Control
What are your rights?
You have rights in relation to your personal data. Only you or someone authorised to act on your behalf can make a request about your personal data. If you authorise someone to act on your behalf, we may need to verify their authorisation.
- Worldwide rights requests require identity and authority checks Account & Service Control
Correction of your personal data
If you think your personal data that we hold is incorrect, you can contact us to request a correction.
- Request correction or restricted processing Use & Processing
Restriction of processing
You can request that we limit the processing of your personal data in certain circumstances. For example, if you believe your personal data is inaccurate, you can ask us to restrict the processing while we verify it.
- Request correction or restricted processing Use & Processing
Access to your personal data
You have the right to know what personal data we process about you. You can request access to all your personal data and to receive a copy of it, including in a structured and portable form (we use .json files). For iOS Flo Premium members, the App also allows you to download a report with some of your personal data directly.
- Access and transfer your data Account & Service Control
Right to data portability
You can request your personal data in a format that lets you easily move, copy or transfer it to third parties for other services or purposes.
- Access and transfer your data Account & Service Control
Erasure of your personal data
You can ask us to delete your personal data at any time. Keep in mind that deleting some personal data might affect your experience with certain features that depend on historic information.
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
Objection to the processing of your personal data
You can object to the processing of your personal data, such as if we use it for direct marketing purposes.
- You may object to processing, including direct marketing Use & Processing
How to exercise your privacy rights
To exercise your privacy rights, you can use our interactive chatbot, available on our Website or by emailing us at support@flo.health.
- Use the chatbot or support contact, and withdraw health-data consent Account & Service Control
You can request to delete your account or make certain changes directly in the App's settings.
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
We will handle your request within one month of receiving it. In some cases, such as for complete deletion of your personal data stored in our backup systems, it may take 90 days. If we need more time to action your request, we will let you know and explain the reason for the delay. Please be aware that once the deletion process begins, it can’t be undone. This is because your personal identifiers are immediately unlinked from your App information, which means we can no longer identify you, even if some data temporarily remains in our backup systems.
- Account deletion is irreversible, with backup and legal-retention qualifications Retention & Deletion
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
Your consent is required for us to use your health data. You can withdraw this consent at any time by either contacting us or deleting your account through the App.
- Use the chatbot or support contact, and withdraw health-data consent Account & Service Control
What else should you know?
If your request is unclear, we might reach out to you for clarification. We may also refuse or charge a reasonable fee for requests that are clearly unfounded and/or excessive.
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Worldwide rights requests require identity and authority checks Account & Service Control
- Request correction or restricted processing Use & Processing
- Access and transfer your data Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
- You may object to processing, including direct marketing Use & Processing
To process your request, we’ll need to verify your identity. Usually, this involves confirming that the request is coming from the email you used to register. If you haven’t registered, we may ask you for additional verification to ensure we respond appropriately.
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Worldwide rights requests require identity and authority checks Account & Service Control
- Request correction or restricted processing Use & Processing
- Access and transfer your data Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
- You may object to processing, including direct marketing Use & Processing
Depending on local laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities. If you have any concerns about our privacy practices, please let us know by emailing our support team at support@flo.health or by emailing our data protection officer at dpo@flo.health.
- You may contact a local data protection authority Legal Rights & Agreement Rules
- Local law may permit a regulator complaint Legal Rights & Agreement Rules
5. Third party data processing
We will not share your personal data with third parties except as specified within this Privacy Policy.
- Third-party sharing is limited to this policy and excludes health data from marketing Sharing & Disclosure
Promoting our Services
We do not share your health data with third parties for marketing purposes. With your consent, Flo may collect and share information with AppsFlyer and its partners, Firebase and TikTok Ad Manager. These are mobile app marketing and analytics platforms (not social media platforms) who help us improve our advertising campaigns, understand the performance of our campaigns and spread the word about Flo. They may also use information collected to remind you to revisit the App if you haven’t used it in a while.
- Third-party sharing is limited to this policy and excludes health data from marketing Sharing & Disclosure
- Firebase’s processor role includes Android notifications and analytics Use & Processing
- Promotion using device and account details requires agreement Sharing & Disclosure
- Advertising measurement excludes health data and requires consent Sharing & Disclosure
- No paid sale or rental; specified service and marketing sharing remains Sharing & Disclosure
Your health data is not shared with AppsFlyer, Firebase or TikTok Ad Manager. AppsFlyer, Firebase and Tiktok Ad Manager handle your personal data only with your consent and according to our instructions as a data processor.
- Third-party sharing is limited to this policy and excludes health data from marketing Sharing & Disclosure
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- Firebase links promotional data to Google services Sharing & Disclosure
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
Here is how we work with AppsFlyer and its partners for marketing and promotional purposes:
- When you become a Flo member and give your consent, we share the following personal data with AppsFlyer and its partners to promote the Services:
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- technical identifiers: IP address (which may also reveal general location information), Android ID (in Android devices), Google advertising ID, and other similar unique technical identifiers;
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- your age group;
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- your subscription status;
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- the fact that you launched the App; and
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- your advertising identifier if you provide your consent on the iOS ‘allow tracking’ settings.
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- Flo sends this personal data to AppsFlyer, which analyses it and provides us with insights on how to improve our promotional campaigns.
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
AppsFlyer may also share your personal data with its partners (e.g., Pinterest, Google Ads, Apple Search Ads, Meta Audience and others) to find you or people like you on various platforms, including social media. These partners use the information shared to help us achieve the purposes described above. Read more about AppsFlyer and how its partners work here.
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- Withdrawing your consent: You can withdraw your consent to sharing your information with AppsFlyer anytime. You can do this by visiting your device settings or adjusting your consent preferences in the Flo App.
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
Please note, that we also use AppsFlyer for a separate functional purpose to help join up the onboarding process between the Website and App for some users. You cannot opt out of AppsFlyer’s processing of your personal data for this purpose.
- AppsFlyer advertising sharing is optional; onboarding processing is not Sharing & Disclosure
- AppsFlyer’s processor row includes onboarding, invitations and partner linking Linking & Identification
- AppsFlyer connects website signup to the app Linking & Identification
Here is how we work with Firebase for marketing and promotional purposes:
- When you become a Flo member and give your consent, we share the following personal data with Firebase and connected Google services partners to promote the Services:
- Firebase links promotional data to Google services Sharing & Disclosure
- technical identifiers: IP address (which may also reveal general location information), Android ID or Google advertising ID (in Android devices), IDFA (for iOS devices), and other similar unique technical identifiers;
- Firebase links promotional data to Google services Sharing & Disclosure
- your subscription status;
- Firebase links promotional data to Google services Sharing & Disclosure
- information about App usage, such as the fact that you launched the App; and
- Firebase links promotional data to Google services Sharing & Disclosure
- your advertising identifier if you provide your consent on the settings of your device.
- Firebase links promotional data to Google services Sharing & Disclosure
- Flo sends your personal data to Firebase, which analyses it and provides us reports and insights on how to optimise our promotional campaigns.
- Firebase links promotional data to Google services Sharing & Disclosure
- At the same time, your personal data is shared with linked services (e.g. Google Ads, Google Analytics, and Google Play). Linking this information helps us to enhance our app’s functionality, understand how well our marketing efforts are working, and allows us to create targeted campaigns to show you more relevant ads.
- Firebase links promotional data to Google services Sharing & Disclosure
Read more about how Firebase and linked services work here.
- Withdrawing your consent: You can withdraw your consent or opt out from the sharing of your personal data with Firebase in accordance with this subsection anytime by adjusting your device settings. You can opt out of receiving push notifications by adjusting your settings on your device at any time.
- Firebase links promotional data to Google services Sharing & Disclosure
- Firebase’s processor role includes Android notifications and analytics Use & Processing
Here is how we work with TikTok Ad Manager for marketing and promotional purposes:
- When you become a Flo member and give your consent, we share the following personal data with TikTok Ad Manager to promote the Services:
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- technical identifiers: IP address (which may also reveal general location information), Google advertising ID (in Android devices), IDFA (for iOS devices), and other similar unique technical identifiers;
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- Information about your subscription, such as purchased plan, price and currency;
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- information about App usage, such as the fact that you launched the App; and
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- your advertising identifier if you provide your consent on the settings of your device.
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- Flo sends your personal data to TikTok Ad Manager, which analyses it and provides us reports and insights on how to optimise our promotional campaigns. Read more about how TikTok Ad Manager and linked services work here.
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- Stop TikTok sharing through device settings and an app restart Sharing & Disclosure
- Withdrawing your consent: You can opt out of receiving push notifications by adjusting your settings on your device at any time. You can withdraw your consent or opt out from the sharing of your personal data with TikTok Ad Manager in accordance with this subsection anytime by adjusting your device settings. You will need to restart your app (close the app and reopen it) for the device settings to take effect and to stop Flo sharing your information with TikTok Ad Manager. Please note that if you want TikTok Ad Manager to delete your information, you can control this yourself on the TikTok platform (see more information here: https://www.tiktok.com/legal/page/us/privacy-policy/en)
- TikTok Ad Manager opt-out requires restarting the app Sharing & Disclosure
- Stop TikTok sharing through device settings and an app restart Sharing & Disclosure
Apple’s AppTrackingTransparency (ATT)
In addition to AppsFlyer, for iOS devices, we may use Apple’s ATT tool to help us improve our advertising and help more people discover Flo’s Services. If you choose to allow tracking, Apple will ask whether you would like to share your device’s advertising ID (sometimes referred to as a IDFA), and details like your age group, subscription status and the fact you launched the Flo App. Please be aware, we do not share your health data with third parties for advertising purposes, and you can change your consent for ATT any time in your phone settings or Flo’s consent settings in the App.
- iOS ATT tracking is optional and excludes health data Sharing & Disclosure
- Advertising measurement excludes health data and requires consent Sharing & Disclosure
Processing to make the App run
Sometimes, we work with other companies to process your personal data on our behalf. We call these companies or service providers “processors.”
- Flo uses processors and remains responsible for their actions Sharing & Disclosure
Processors are companies that help us operate our Services. We are responsible for any actions of these processors ensuring they follow the law and our instructions by entering into data processing agreements with them.
- Flo uses processors and remains responsible for their actions Sharing & Disclosure
Flo’s team is spread across several countries. The following group companies within the Flo group act as processors:
- Flo uses processors and remains responsible for their actions Sharing & Disclosure
- Flo Health Cyprus Ltd (based in Cyprus);
- Flo uses processors and remains responsible for their actions Sharing & Disclosure
- Flo Health LTU UAB (based in Lithuania, our main EU establishment); and
- Flo uses processors and remains responsible for their actions Sharing & Disclosure
- Flo Health NL. BV (based in the Netherlands).
- Flo uses processors and remains responsible for their actions Sharing & Disclosure
Here are some of the main processors we rely on:
Processor Processor's privacy policy Data collected Purpose
Infrastructure and security Amazon Web Services, Inc. AWS Privacy Notice All personal data Storing all personal data when you use the App
- Infrastructure processors are listed for all personal data Sharing & Disclosure
Infrastructure and security Cloudflare, Inc. Cloudflare Privacy Policy All personal data Security of the App, content delivery
- Infrastructure processors are listed for all personal data Sharing & Disclosure
Infrastructure and security Auth0, Inc. (Okta, Inc.) Okta Privacy and Cookie Policy Email address, IP address, and Name Authentication and authorization services
- Authentication and website hosting use different data scopes Sharing & Disclosure
Infrastructure and security Kibana Inc. (Elastic N.V.) Elastic N.V. Privacy Statement All personal data To protect members’ data
- Infrastructure processors are listed for all personal data Sharing & Disclosure
Infrastructure and security Vercel Inc. Vercel’s Privacy Policy Personal data processed via the Website To improve the Website’s performance and ensure efficient service delivery
- Authentication and website hosting use different data scopes Sharing & Disclosure
Email communications SendGrid, Inc. (Twilio, Inc.) SendGrid Privacy Notice Email address To send you our newsletters, surveys and notifications
- Communication and review providers receive specified contact or survey data Sharing & Disclosure
Email communications Trustpilot A/S Trustpilot Privacy Policy Email address, and Name (or a nickname if you prefer) To send and invite you to take part in Service reviews.
- Communication and review providers receive specified contact or survey data Sharing & Disclosure
Email and in-App communications SurveyMonkey (Momentive Europe UC) SurveyMonkey Privacy Notice IP address, member ID, and Results of surveys To send and invite you to take part in Service reviews.
- Communication and review providers receive specified contact or survey data Sharing & Disclosure
Analytical tools Looker (Google Cloud EMEA, Ltd) Looker Privacy Policy App usage data To understand how you use the App, which features you engage and what you like or dislike the most, and To create statistical reports.
- Looker and Databricks support usage analytics Use & Processing
Analytical tools Databricks, Inc. Databricks Privacy Notice App usage data To understand how you use the Website, which features you interact with and what you like or dislike. This helps us improve your product experiences.
- Looker and Databricks support usage analytics Use & Processing
Analytical tools Google LLC (Google Tag Manager & Google Analytics 4)
- Google analytics tools process website usage data Use & Processing
Google Privacy Policy Google Analytics 4: Data privacy and security
Website usage data To monitor how well our Services are performing and to understand how you use them on our Website, all while ensuring suitable privacy protections.
- Google analytics tools process website usage data Use & Processing
Customer Support Zendesk Inc., USA Zendesk Privacy Policy Email address, Content of the emails,and Content of support query chatbot messaging To process communications received from you, and Our Website chatbot is powered by Zendesk. Once a chat is closed, its contents will be automatically deleted within two hours.
- Zendesk handles support messages; closed website chats expire within two hours Retention & Deletion
Customer Support Customer Thermometer Ltd Customer Thermometer Privacy Policy Email address, and Responses to surveys To obtain customer feedback. Machine learning to deliver cycle predictions; forecast customer retention; and display relevant content within the app
Machine Learning Development Platform Tecton, Inc. Tecton Privacy Policy Personal data relating to cycle dates, goals, symptoms Machine learning to deliver cycle predictions; forecast customer retention; and display relevant content within the app
- Tecton processes cycle, goal and symptom data for machine learning Inference & Profiling
Payments Apple, Inc. Apple: App Store & Privacy Notice Payment and banking information, and Personal identifiers To handle and process payments for your App subscription.
- Payment providers receive banking data for different payment tasks Charges & Financial Obligations
Payments Google LLC, USA Google Privacy Policy Payment and banking information, and Personal identifiers To handle and process payments for your App subscription.
- Payment providers receive banking data for different payment tasks Charges & Financial Obligations
Payments Stripe, Inc., USA Stripe Privacy Policy Payment and banking information, and Personal identifiers To collect and process payments for certain Website purchases.
- Payment providers receive banking data for different payment tasks Charges & Financial Obligations
Payments PayPal Inc. PayPal Privacy Statement Payment and banking information, and Personal identifiers To handle and process payments for your App subscription.
- Payment providers receive banking data for different payment tasks Charges & Financial Obligations
Payments Chargeback Gurus (International Risk Mitigation, LLC) Chargeback Gurus Privacy Policy Payment and banking information To handle disputes and process refunds
- Payment providers receive banking data for different payment tasks Charges & Financial Obligations
Promoting Flo and user experience functionality AppsFlyer UK Ltd AppsFlyer Privacy Policy Information about your device model, language and operating system. Enable linking for Website to App onboarding journey or invite a friend or partner to Flo, and To optimise marketing campaigns. To link accounts when using Flo for Partners and to simplify, track and improve influencers campaigns.
- AppsFlyer’s processor row includes onboarding, invitations and partner linking Linking & Identification
Promoting Flo and user experience functionality Firebase (Google Cloud EMEA Ltd) Firebase Privacy and Security Information about your app usage, subscription status, and technical identifiers To optimise marketing campaigns. To send push notifications on Android devices. To enhance our app’s functionality. To understand how you use our Services and improve your experience.
- Firebase links promotional data to Google services Sharing & Disclosure
- Firebase’s processor role includes Android notifications and analytics Use & Processing
Security and verification of web users Cloudflare Turnstile Cloudflare's Privacy Policy IP address for fraud detection and validation, time spent on the Website or interaction signals (such as clicks), and Browser and device information To help keep our Website safe and secure. Cloudflare Turnstile confirms our Website visitors are real and blocks unwanted bots without slowing down web experiences for real users. This does not use cookies or track users across websites.
- Turnstile verifies website visitors without cross-site tracking Security & Safeguards
For details about the processors we use in connection with cookies, please see our Cookie Policy.
Skin Analysis Feature
If you're in the US, you may have access to our skin analysis feature.
- US skin analysis processes facial images on the device Use & Processing
How it works: We'll ask for your consent to use your facial image to create your skin report, and your device will ask for permission to use your camera. If you agree to both, on supported devices, we use TrueDepth camera APIs to capture facial contours in addition to a standard image to provide skin scanner functionality. Your device’s camera captures your facial image and measures an area of focus from your image for analysis. This information is analyzed entirely on your device, by skin-analysis technology, and is deleted as soon as the analysis finishes.
- US skin analysis processes facial images on the device Use & Processing
What we receive and why: Your facial image from your camera never leaves your device. They are not sent over the network, and they are not saved to your device's storage. They are held only in your device's memory while you're using the app, and cleared when you close it. They are also never uploaded to Flo’s servers, sold to third parties or used for advertising or marketing purposes. Only the analysis results (for example, skin-type classification and skin appearance such as the presence of breakouts or pigmentation) are sent to Flo. We use this data to create your report, and provide you with relevant insights and information. This feature does not offer you a medical diagnosis or medical treatment.
- US skin analysis processes facial images on the device Use & Processing
Retention: We store the date of your skin analysis and your results in your Flo profile so you can see them again and track any changes over time. We store this information in accordance with our retention policy (see section 8 of this policy), or until you ask us to delete it.
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
You stay in control of your data and this feature operates with your consent. You can withdraw your consent, and/or request deletion of your data at any time by contacting us at support@flo.health.
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
Commercial partners
Flo offers the Services to customers of selected commercial partners. These partnership offers involve limited sharing of personal data with Flo so that we know you have joined us via our commercial partner (like, Wellhub). Flo may receive information from the commercial partner to validate your subscription, which may include a customer ID or email address. Flo may share limited event information with the commercial partner, but Flo will never share any health data (or any other sensitive data) about you. If you join Flo via a commercial partner, please check their privacy policy for more information, or contact us at dpo@flo.health if you have any questions.
- Commercial offers exchange subscription and activity information, not health data Sharing & Disclosure
Example: Flo has partnered with Wellhub, a health and wellbeing platform. Flo is available to Wellhub’s members as a health and wellbeing service. If you sign up for Flo using your Wellhub subscription, a Wellhub ID is shared with Flo. After you sign up to Flo, Flo will confirm to Wellhub if you have been active in the App.
- Commercial offers exchange subscription and activity information, not health data Sharing & Disclosure
Telehealth partners
Flo is not a medical provider and does not deliver medical care. If you are located in the United States, we provide options and facilitate access to services provided by our telehealth partners (“Telehealth Services”).
- US telehealth uses partner privacy notices rather than this policy’s processing rules Legal Rights & Agreement Rules
If you choose to use a Telehealth Services, Flo may act as a service provider to the applicable telehealth partner. In this role, we may collect certain personal information—such as your ZIP code and insurance provider—and share it with the partner to facilitate that service. In some cases, this information may be treated as Protected Health Information under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).
- US telehealth uses partner privacy notices rather than this policy’s processing rules Legal Rights & Agreement Rules
We will process this information on behalf of our telehealth partners in accordance with applicable law and our contractual obligations, including, where required, entering into a HIPAA business associate agreement.
- US telehealth uses partner privacy notices rather than this policy’s processing rules Legal Rights & Agreement Rules
The data processing activities described in this Privacy Policy do not apply to the use of your personal information in connection with Telehealth Services. For information about how your personal information is collected, used, and disclosed in that context, please refer to the privacy notice or notice of privacy practices of the relevant telehealth partner.
- US telehealth uses partner privacy notices rather than this policy’s processing rules Legal Rights & Agreement Rules
- Policy scope, controller and effective date Legal Rights & Agreement Rules
Aggregated information
We may aggregate, anonymise or de-identify your personal data so that it cannot be used to identify you. This personal data might be shared with third parties, like research institutions or used for statistical purposes. For example, we share general age and demographic information, along with aggregated statistics about activities or symptoms to identify patterns across and support scientific research. This helps us create articles, blog posts and scientific publications that advance research on female health.
- De-identified research sharing is separate from consent for specific studies Sharing & Disclosure
If we want to include you in specific research studies, we will ask for your consent. You can withdraw your consent at any time by emailing us at dpo@flo.health.
- De-identified research sharing is separate from consent for specific studies Sharing & Disclosure
Information posted by you
The App includes community areas like Secret Chats and guided groups where members with similar interests can share information and support each other.
- Community posts are visible to others and must not identify people Sharing & Disclosure
Posting personal data that can directly identify you or others in such groups is not allowed and violates our rules, including the Secret Chats Rules. Any information you share in these community areas is accessible to the Flo community. Please think carefully before posting anything that could identify you in any public forum. Remember, what you post can be seen, disclosed, or collected by others and may be used in ways beyond our control, including contacting you for unauthorised purposes. If you accidentally post personal data and want it removed, email us at support@flo.health.
- Community posts are visible to others and must not identify people Sharing & Disclosure
We may also preserve or share some of your personal data in the following limited circumstances:
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
- in response to subpoenas, court orders, or legal processes, as required by applicable law (including to meet national security or law enforcement needs);
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
- when necessary to maintain the security and integrity of the Services or to protect any member’s security, consistent with applicable laws. In such cases, we may also delete some of your personal data (e.g., by resetting your password to prevent unauthorised access);
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
- Breach notice depends on law; Flo may reset access to address incidents Security & Safeguards
- to assert legal rights or defend against legal claims;
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
- when disclosure is authorised or requested by the member who has provided the personal data;
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
- in the event of a business acquisition, transfer or reorganisation; and
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
- depending on the situation, we may rely on legitimate interest or legal obligations as the basis for these processing activities.
- Limited legal, security and business events can permit preservation or disclosure Sharing & Disclosure
6. Anonymous Mode
Anonymous Mode lets you use Flo without linking your email, name, or other personal identifiers to your account.
- Anonymous Mode reduces identity linkage without guaranteeing perfect security Linking & Identification
What happens with your old account: if you already have a Flo account, some non-identifiable data (like your cycle information) will be transferred to your new Anonymous Mode account. However, your old account with personal data will be deleted according to our retention policy and you will no longer have access to it.
- Switching to Anonymous Mode deletes access to the old account Retention & Deletion
- Anonymous Mode unlinks identifying details from health data Linking & Identification
Limitations of Anonymous Mode: in Anonymous Mode, some features of the App will not be available because they rely on personal data. These features may include:
- Anonymous Mode limits integrations, messages and support Account & Service Control
- Anonymous Mode unlinks identifying details from health data Linking & Identification
- integration with your wearable device; and
- Anonymous Mode limits integrations, messages and support Account & Service Control
- Anonymous Mode unlinks identifying details from health data Linking & Identification
- certain push notifications and emails.
- Anonymous Mode limits integrations, messages and support Account & Service Control
- Anonymous Mode unlinks identifying details from health data Linking & Identification
Customer Support: when using Anonymous Mode, we cannot identify you. This means our customer support may not be able to assist with specific or technical questions. However, we will do our best to help where possible.
- Anonymous Mode limits integrations, messages and support Account & Service Control
- Anonymous Mode unlinks identifying details from health data Linking & Identification
Security: while Anonymous Mode minimises risks by unlinking personal data from health data, it’s important to note that in rare cases, security measures might be bypassed. For more details on Anonymous Mode, please check our Anonymous Mode FAQs here.
- Anonymous Mode reduces identity linkage without guaranteeing perfect security Linking & Identification
- Anonymous Mode unlinks identifying details from health data Linking & Identification
7. Flo for Partners
If you are over 18, you can choose the Flo for Partners Service, allowing certain information from your Flo account to be shared with your partner. As the main member, you have complete control over this sharing and you can stop it at any time.
- Members over 18 control limited, read-only partner sharing Sharing & Disclosure
- Partner content follows cycle, pregnancy and mode changes Sharing & Disclosure
- Children’s privacy section includes India in the age-16 rule Account & Service Control
- Minimum app age depends on location Account & Service Control
What information will be shared with my partner?
Your partner will have read-only access to the information you choose to share. They cannot download or edit your information. Specifically they cannot see or edit:
- Members over 18 control limited, read-only partner sharing Sharing & Disclosure
- calendar information created before you decided to share;
- Members over 18 control limited, read-only partner sharing Sharing & Disclosure
- personal notes;
- Members over 18 control limited, read-only partner sharing Sharing & Disclosure
- any symptoms or feelings logged in the App; or
- Members over 18 control limited, read-only partner sharing Sharing & Disclosure
- Partner content follows cycle, pregnancy and mode changes Sharing & Disclosure
- interactions with other features (e.g. Secret Chats).
- Members over 18 control limited, read-only partner sharing Sharing & Disclosure
If you’re trying to conceive or tracking your menstrual cycle: your partner will see a view-only version of your current cycle day and cycle phase predictions. They will also receive tailored daily educational insights and notifications during key phases of your cycle.
- Partner content follows cycle, pregnancy and mode changes Sharing & Disclosure
If you’re pregnant: your partner will get regular updates about your pregnancy, including tailored daily educational insights. They will be notified about changes to your body, common symptoms and important milestones.
- Partner content follows cycle, pregnancy and mode changes Sharing & Disclosure
Your partner will also see updates in their App if you switch between modes (e.g. from ‘track pregnancy’ to ‘track cycle’) and their content will adjust accordingly.
- Partner content follows cycle, pregnancy and mode changes Sharing & Disclosure
What personal data is collected from you as a partner?
If you’re a partner receiving information, we will collect your name and email to set up your account with Flo. We’ll also ask for your month and year of birth to verify your age. While we don’t collect your gender directly, it may be inferred based on your App usage. No health data about you will be collected.
- Account details and inferred sex or gender Data Access & Collection
- Receiving partners provide account details but no health data Data Access & Collection
8. Retention of your personal data
We will keep your personal data for as long as necessary to provide you with the Services or fulfill the purposes for which it was collected (except as noted below).
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Uninstalling or inactivity leaves a three-year retention period Retention & Deletion
Impact of account deactivation/requests to erase personal data: You can deactivate your account at any time by following instructions in the ‘How to exercise your privacy rights’. We will process your request within one-month. In some cases, it will take up to 90 days to completely erase your personal data from our backup systems. If you choose to deactivate your account, Flo will delete your personal data, and it will not be recoverable should you later create another account.
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Switching to Anonymous Mode deletes access to the old account Retention & Deletion
- Account deletion is irreversible, with backup and legal-retention qualifications Retention & Deletion
Deleting the App or inactivity: If you delete the App from your device or your account becomes inactive, we will retain your personal data for three years in case you decide to reactivate the Services or reinstall the App. After three years of inactivity, your personal data will be deleted. Flo will apply this standard retention policy. However, you can still request earlier deletion by contacting us at any time.
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Uninstalling or inactivity leaves a three-year retention period Retention & Deletion
Limitations: Even after your account is deleted, we may need to retain certain personal data and other information. This is required or permitted by applicable law, like the GDPR, and may include situations like:
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Switching to Anonymous Mode deletes access to the old account Retention & Deletion
- Uninstalling or inactivity leaves a three-year retention period Retention & Deletion
- Account deletion is irreversible, with backup and legal-retention qualifications Retention & Deletion
- Anonymous Mode unlinks identifying details from health data Linking & Identification
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
- complying with legal obligations;
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Switching to Anonymous Mode deletes access to the old account Retention & Deletion
- Uninstalling or inactivity leaves a three-year retention period Retention & Deletion
- Account deletion is irreversible, with backup and legal-retention qualifications Retention & Deletion
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
- managing and handling legal claims; and
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Switching to Anonymous Mode deletes access to the old account Retention & Deletion
- Uninstalling or inactivity leaves a three-year retention period Retention & Deletion
- Account deletion is irreversible, with backup and legal-retention qualifications Retention & Deletion
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
- archiving for public interest, scientific or historical research, or statistical purposes.
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Switching to Anonymous Mode deletes access to the old account Retention & Deletion
- Uninstalling or inactivity leaves a three-year retention period Retention & Deletion
- Account deletion is irreversible, with backup and legal-retention qualifications Retention & Deletion
- Contact Flo to exercise data rights or withdraw consent Account & Service Control
- Deletion can affect history-based features and cannot be reversed once started Retention & Deletion
How do we delete your data?
We use industry-standard methods to securely and permanently delete your personal data from our systems, making it impossible to recover. This process may include sending automated notifications to our processors who process your personal data on our behalf.
- Skin results stay in the profile under the policy’s retention rules Retention & Deletion
- Flo describes permanent deletion and possible processor notices Retention & Deletion
9. Security of your personal data
General security measures
We take various technical and organisational steps to protect your personal data from loss, theft, misuse, and unauthorised access, disclosure, alteration, and destruction. These measures are designed based on the nature of the personal data we handle and the risks associated with special categories of personal data we collect. This includes:
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
- encryption: your personal data is encrypted both in transit and at rest;
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
- vulnerability scanning: we conduct regular scans and penetration testing;
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
- data integrity protection: we have measures in place to protect the integrity of your data;
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
- organisational and legal measures: for example, our employees have different levels of access to your personal data, limited to what is necessary for operating the Services. We hold our employees strictly accountable for any disclosure, unauthorised access, alteration, destruction or misuse of your personal data; and
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
- privacy assessments: we conduct regular data protection impact assessments to ensure that the Services comply with privacy principles. We also commit to a privacy audit in the event of Flo’s merger or takeover.
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
Please keep your password secure and don’t share it with others. Consider adding a passcode or enabling face ID for an extra layer of protection.
- Keep credentials private and consider an additional device lock Security & Safeguards
While we strive to protect your information, we cannot guarantee absolute security, nor can we ensure that your personal data won’t be intercepted during transmission to us.
- Flo lists security safeguards but does not guarantee absolute security Security & Safeguards
- Flo reports privacy and security certifications Security & Safeguards
Security breaches
If there is a security breach and where required by law, we will either post a notice or try to contact you by email. We will take reasonable steps to fix the issue according to applicable laws and this Privacy Policy. For potential personal data breaches, we may take additional actions, such as logging you out from all the devices, resetting your password and other necessary steps to address the situation.
- Breach notice depends on law; Flo may reset access to address incidents Security & Safeguards
If you want to report a security incident related to the Services, please email us at security@flo.health.
- Breach notice depends on law; Flo may reset access to address incidents Security & Safeguards
10. Children’s privacy
General age limitation: our Services are not for children, and we do not knowingly collect personal data from anyone under 13. If you know of someone under 13 using the Services, please email us at support@flo.health.
- Children’s privacy section includes India in the age-16 rule Account & Service Control
Age limitation for residents of the European Economic Area (EEA), United Kingdom (UK), Canada and India: For legal reasons, residents of the EEA, the UK, Canada or India must be at least 16. If you know of someone under 16 using the Services, please email us at support@flo.health.
- Children’s privacy section includes India in the age-16 rule Account & Service Control
- Minimum app age depends on location Account & Service Control
Some features of the App are only available to members who are 18 or older.
- Children’s privacy section includes India in the age-16 rule Account & Service Control
- Minimum app age depends on location Account & Service Control
11. Communication with you
We might contact you via email, pop-ups or push notifications to share updates with you about Services, offers, promotions, rewards and events. These messages will be based on the Services you have chosen from Flo, (e.g. your selected mode) and the features you interact with.
- Marketing opt-out leaves essential service emails in place Use & Processing
Opt-out options: You can unsubscribe from marketing emails by clicking the “Unsubscribe” link in the email. Opting out of these marketing emails or notifications will not stop essential Service-related emails. To stop receiving push notifications, adjust your settings on your device. In some cases, we might ask for additional consent for certain communications.
- Marketing opt-out leaves essential service emails in place Use & Processing
Please note we may contact you through third-party platforms (like social media) with information about our Services, offers, promotions, rewards and events.
- Marketing opt-out leaves essential service emails in place Use & Processing
Presence on social networks
We may use social media to promote Flo and interact with our customers. When you engage with us on these platforms, we process information about you, like your username, profile picture and any comments or posts related to Flo. This information is used solely for engagement purposes.
- Social-media engagement data is used solely for engagement Use & Processing
12. Storage and international personal data transfers
Flo is based in the UK. The personal data we collect is transferred to and processed in the US, where it is subject to US law and to other countries (where it follows the laws of those countries). These transfers are usually cloud-based and occur when you use our Services. Please note, the laws in these countries may not offer the same protections as those in your country.
- Data is processed internationally, with safeguards for EEA and UK transfers Sharing & Disclosure
Transfers of personal data outside of the EEA and the UK
Personal data in the EEA and the UK is protected by the GDPR and the UK GDPR. When we transfer personal data outside of these areas, we apply appropriate safeguards to ensure your personal data is protected. For example, we use data transfer agreements that include the European Commission’s Standard Contractual Clauses and conduct transfer risk assessments.
- Data is processed internationally, with safeguards for EEA and UK transfers Sharing & Disclosure
For further information, please email us at support@flo.health.
- Data is processed internationally, with safeguards for EEA and UK transfers Sharing & Disclosure
Data Privacy Framework (“DPF”) Participation
Flo Health, Inc., Flo’s U.S. subsidiary, (“Flo U.S.”) is self-certified and complies with the EU–US DPF, the UK Extension to the EU–US DPF and Swiss–US DPF (collectively, the “DPFs”). Flo U.S. has certified to the U.S. Department of Commerce that, on reliance of the DPFs, it adheres to the DPF Principles when processing personal data of individuals within the EU, UK and/or Switzerland. For onward transfers, Flo U.S. is responsible for processing personal data it receives under the DPFs, and then transfers to a third party acting on its behalf. Flo U.S. remains liable under the DPFs if those third parties process personal data in a way that is not in compliance with the DPFs, unless it can prove that we are not responsible for the cause of any damage.
- Flo U.S. states DPF commitments and conditional onward-transfer liability Legal Rights & Agreement Rules
If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles will govern, please visit https://www.dataprivacyframework.gov/.
- Flo U.S. states DPF commitments and conditional onward-transfer liability Legal Rights & Agreement Rules
You can find Flo US’s certification on the DPF list here.
Complaints and dispute resolution: Flo U.S. is committed to resolving complaints about its collection and use of your personal data. EU, UK and Swiss individuals with inquiries or complaints regarding the DPFs should first contact us by emailing us at dpo@flo.health or by mail using the address: Flo Health UK Limited, Fourth Floor, International House, 1 St Katharine’s Way, London, E1W 1UN, United Kingdom.
- Start DPF complaints with Flo; unresolved complaints can go to free JAMS services Legal Rights & Agreement Rules
Arbitration: You may also be able to invoke binding arbitration for unresolved complaints, but prior to initiating such arbitration, a resident of a European country (including the UK and Switzerland) participating in the DPFs must first (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the US Department of Commerce (either directly or through a European data protection authority, the UK’s Information Commissioner’s Office or the Swiss Federal Data Protection) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that pursuant to the DPFs, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the DPF with respect to the resident. The arbitration option may not be invoked if the individual’s same claimed violation of the principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which the individual was a party; or (3) was previously settled by the parties.
- DPF arbitration has prerequisites, limited remedies and exclusions Legal Rights & Agreement Rules
Flo U.S. is subject to the investigatory and enforcement powers of the US Federal Trade Commission concerning personal data transferred under the DPFs, the UK’s Information Commissioner’s Office, the relevant EU Data Protection Authority, and the Swiss Federal Data Protection and Information Commissioner for resolving disputes with Swiss individuals.
- The DPF section identifies oversight and dispute-resolution authorities Legal Rights & Agreement Rules
Flo U.S. has further committed to refer unresolved DPF complaints to JAMS, an alternative dispute resolution provider located in the U.S. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact JAMS or visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
- Start DPF complaints with Flo; unresolved complaints can go to free JAMS services Legal Rights & Agreement Rules
13. United States
If you live in the United States, please also see our U.S. State Privacy Law Notice.
- US state and consumer-health notices are separate documents Legal Rights & Agreement Rules
- Policy scope, controller and effective date Legal Rights & Agreement Rules
If you are a resident of Washington and Nevada, please see our Consumer Health Data Privacy Notice.
- US state and consumer-health notices are separate documents Legal Rights & Agreement Rules
- Policy scope, controller and effective date Legal Rights & Agreement Rules
14. Contact us
If you have any questions or concerns about your privacy, you may contact us or our data protection officer by writing to us at:
- Privacy contacts include UK and EU offices Account & Service Control
Flo Health UK Limited:
- Privacy contacts include UK and EU offices Account & Service Control
Fourth Floor South, International House,
- Privacy contacts include UK and EU offices Account & Service Control
1 St Katharine’s Way, London,
- Privacy contacts include UK and EU offices Account & Service Control
E1W 1UN,
- Privacy contacts include UK and EU offices Account & Service Control
United Kingdom
- Privacy contacts include UK and EU offices Account & Service Control
Flo Health LTU UAB (our main EU establishment):
- Privacy contacts include UK and EU offices Account & Service Control
Lvivo g. 21-101
- Privacy contacts include UK and EU offices Account & Service Control
Vilnius
- Privacy contacts include UK and EU offices Account & Service Control
09306
- Privacy contacts include UK and EU offices Account & Service Control
Lithuania
- Privacy contacts include UK and EU offices Account & Service Control
You can also reach us by email at support@flo.health or dpo@flo.health.
- Privacy contacts include UK and EU offices Account & Service Control
If needed, you may also contact your local data protection authority. A list of local data protection authorities is available here.
- You may contact a local data protection authority Legal Rights & Agreement Rules