Privacy Policy

This privacy policy applies between you, the User of this Website and the Product, and Weboo Online Limited (trading as and collectively referred to as “Fliplet“, “we“, “us” or “our“), the owner and provider of this Website and the Product. Fliplet takes the privacy of your information very seriously. This privacy policy will inform you how we look after your Personal Data when you use our Website and tells you about your privacy rights and how the law in our jurisdiction protects you.

This privacy policy should be read alongside, and in addition to, our Terms of Service

Definitions and interpretation

1. Capitalised terms used herein but not otherwise defined shall have the meanings given in our Terms and Conditions, which can be found on the Properties.

2. In this privacy policy, the following definitions are used:

“Anonymous Data”	means Personal Data that has been amended to the extent that it no longer contains any identifying information and thus, no longer constitutes Personal Data;
“Application”	means an application created by a customer using the Product
“Children”	any person under the age of 16;
“Cookies”	a small text file placed on your computer by this Website when you visit certain parts of the Properties and/or when you use certain features of the Properties. Details of the cookies used by this Website are set out below (“Cookies“);
“Data Controller”	means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed as outlined in the Data Protection Legislation;
“Data Processor”	means any natural or legal person who processes the data on behalf of the Data Controller;
“Data Protection Legislation”	all applicable data protection and privacy legislation in force from time to time in the UK including the Data Protection Act 2018, the UK implementation of the General Data Protection Regulation ((EU) 2016/679); the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended;
“UK and EU Cookie Law”	the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
“User” or “You”	any third party that accesses the Properties and is not either (i) employed by Fliplet and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Fliplet and accessing the Properties in connection with the provision of such services;
“Weboo Online Limited” trading as and collectively referred to as “Fliplet”, “we” or “us”	Weboo Online Limited, trading as “Fliplet”, a company incorporated in England and Wales with registered number 06974225 whose registered office is at 15 Bonhill Street, London, EC2A4DN;
“Website”	the website that you are currently using, https://fliplet.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions;
“Personal Data”	has the meaning given to it in the Data Protection Legislation;
“Product”	the Fliplet suite of products including but not limited to Fliplet Studio, Fliplet Viewer and applications created by Fliplet, but excluding any Applications; and
“Properties”	refers to the Website and the Product.

3. In this privacy policy, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

d. “including” is understood to mean “including without limitation”;

e. reference to any statutory provision includes any modification or amendment of it;

f. the headings and subheadings do not form part of this privacy policy.

Scope of this Privacy Policy

4. This privacy policy applies only to the actions of Fliplet and Users with respect to the Properties. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites, or any application published by Fliplet or by any of Fliplet’s clients each of which should have its own privacy policy.

5. This privacy policy aims to give you information on how Fliplet collects and processes your Personal Data through your use of the Properties, and any Personal Data you may provide through the Properties when you register with us or send us your details.

6. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them unless specifically stated.

How do we treat Personal Data in respect of Children?

7. The Properties are not intended for Children and we do not knowingly collect data relating to Children. Fliplet accepts no liability for the processing of any data relating to Children where Fliplet was not aware that the subjects were Children.

8. If Children or data about Children is entered into the Properties without our knowledge it is treated the same as any other Personal Data.

Who is the Data Controller?

9. Fliplet is a Data Controller in respect of Personal Data provided by Users via either of the Properties when they create an Account, sign up for newsletter updates, and by email.

10. Fliplet is a Data Processor in respect of any Personal Data processed by Fliplet on behalf of any User in the manner dictated by the User and by third parties including suppliers, provided through a variety of methods.

11. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if any aspect of your Personal Data changes during your relationship with us. Any previous data held on you will be deleted to the fullest extent possible.

Interacting with third party links

12. The Properties may include links to third-party websites, plug-ins and applications. Clicking on any of these links or enabling those connections may allow third parties not associated with Fliplet to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

13. We encourage you to read the privacy policy of every website and application you visit, but, for the avoidance of doubt, Fliplet accepts no liability for any data that has been unlawfully processed by third parties as a result of you accessing these links.

What Personal Data do we collect?

14. We may collect, use, store and transfer different kinds of Personal Data about you, which include but are not limited to, the following categories:

Identity Data: means data that includes your name any other information that may be used when setting up your Account.

Contact Data: means data that includes your contact information, such as: your email address, phone number, home address (if you are an individual) and office address (if you are a corporate client).

Financial Data: means data that includes your financial details, such as your bank account information and payment card details.

Transaction Data: means data that includes details about any payments to and from you relating to Fliplet and the details of Products and/or Services you have purchased from us.

Account Data: means data that includes your account type, product usage, account access data and other data related to your account.

Technical Data: may include internet protocol (IP) addresses you may have visited, your login data for Fliplet, the type and version of browser you are using, the time zone setting and location from which you are accessing the Properties, browser plug-in types and versions, which operating system and Website are being used and other technology on the devices you use to access the Properties.

Usage Data: includes information about how you use the Properties and our Services such as the full uniform resource locations (URL) clickstream to, through and from the Properties (including date and time), pages you viewed or searched for, page response times, download errors, length of visits of certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Marketing and Communications Data: includes your preferences in receiving marketing communications from us and/or our third parties and what are your communication preferences.

15. We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data (which has been collected and processed lawfully) but is not considered to constitute Personal Data under the Data Protection Legislation. This is because the data does not directly or indirectly reveal your identity.

16. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. This will help us to ensure that we are responding to the preferences of our users and delivering the best possible services. However, if we combine or connect Aggregated Data with your Personal Data in any way so that it can directly or indirectly identify you, the combined data will be considered Personal Data which will only be used in accordance with this privacy policy.

17. We do not collect any “Special Categories of Personal Data” about you. Special categories mean the kinds of data recognised by the Data Protection Legislation as being more sensitive in nature than Personal Data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data.

What happens if you don’t provide Personal Data?

18. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Products or the Services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time of contracting.

19. For the avoidance of doubt, Fliplet accepts no liability for any losses arising from our inability to fulfil any contractual requirement as a result of your failure to provide the data required.

How do we collect your Personal Data?

20. We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Account, Financial and Marketing and Communications Data by registering your Account or by corresponding with us by post, phone, email, via our Website or otherwise. This includes Personal Data you provide when you:

register or update your Account with us; or
use our Product, including when you purchase a Product through the Properties; or
when you sign up to our newsletter;
request for marketing material to be sent to you; or
request for more information related to our Services to be sent to you;
enter a competition, promotion or survey on the Properties; orgive us some feedback.

Automated technologies or interactions. As you interact with our Website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address, and Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We (or service providers on our behalf) may then send communications and marketing to this contact data. Note that this does not opt out from all Fliplet communications. Please contact support@fliplet.com to do this.

Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:

Technical Data from the following parties:
analytics providers;
advertising networks; and
search information providers.
Identity and Contact Data from publicly available sources such as Companies House.

How do we use your Personal Data?

21. We will only use your Personal Data when and to the extent permitted by the Data Protection Legislation. Most commonly, we will use your Personal Data in the following circumstances:

Where you leave a review or rating or any other information that you wish to post as part of using our Services and/or Products.
To facilitate your communicating with any other User with whom you have sought to share your personal information.
Where we need to notify you about changes to our Services and/or Products.
Where we need to contact you about your Account and our Services and/or Products.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

22. Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by opting out via our email marketing software or by updating your account within Fliplet or by contacting us if either of these methods fail.

For what purposes will we use your Personal Data?

23. We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

24. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data, where more than one ground has been set out in the table below.

25. For the avoidance of doubt, this table is not exhaustive of the ways in which Fliplet may use your Personal Data and there may be occasions where we require additional information.

Purpose/Activity	Type of data	Lawful Basis for Processing Including Basis of Legitimate Interest
To register you as a User	Identity Data Contact Data Marketing and Communications Data	Performance of a contract with you
To enable you to use the Properties and purchase a Product and/or Service	Identity Data Contact Data Account Data Financial Data Transaction Data	Performance of a contract with you
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey Asking you to pass a security check when you call us regarding your Account	Identity Data Contact Data Account Data Financial Data Marketing and Communications Data	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, so that we can develop our services to suit the demands and preferences of those using our Website, Products and/or Services)
To provide you with information on our Products or Services that you have indicated are of interest to you, such as our newsletter, or which we reasonably believe are of interest to you	Identity Data Contact Data Account Data Marketing and Communications Data	Performance of a contract with you Necessary for our legitimate interests (to provide services to customers)
To administer and protect our business and the Properties (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Data Contact Data Account data Technical Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To use data analytics to improve the Properties, Products/Services, marketing, customer relationships and experiences	Technical Data Usage Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make content suggestions and recommendations to you about Products or Services that may be of interest to you	Identity Data Contact Data Account Data Technical Data Usage Data Marketing and Communications Data	Necessary for our legitimate interests (to develop our products/services and grow our business in a way that is compatible with the preferences of those using them)

26. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

27. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

28. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing and Promotional offers from us

29. We may use your Personal Data to form a view on what we think that you may want or need, or what we may be able to provide that would be of interest to you. This is how we decide which products, offers, services and marketing information may be relevant for you.

30. We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. Once you have given consent for us to contact you with this information, you may withdraw any consent given to receive direct marketing communications from us by clicking the opt-out link in the Product and by unsubscribing from emails using a link within the email or by contacting us directly.

31. You may receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, consented to us using your Personal Data to contact you with this information and have not yet exercised your right to opt out of receiving that marketing and promotional information.

What cookies do we use

32. Cookies are small pieces of text and data sent to your web browser by a website you visit. A cookie file contains such information as how long was spent on that particular website, the site preferences and how frequently the website is visited. These cookies are stored in your web browser and analysed by us to ensure that your preferences are stored. We also use the data from the cookies to assess which of the content on our Website appears to be more engaging and attractive to you. The data is then applied by us to try and ensure that any subsequent use of our Website is both easier and more engaging for you and your preferences are recognised.

33. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

34. Our Website uses cookies to distinguish you from other users of the Properties. This helps us to provide you with a good experience when you browse the Properties and also allows us to improve the Properties.

35. We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of the Properties. If you block these cookies, the Properties will not operate properly.

Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors navigate around the Properties when they are using it. This helps us to improve the way the Properties works, for example, by allowing us to tailor the services to try and ensure that users are finding what they are looking for easily and their preferences are stored for future reference.

Functionality cookies. These cookies are used to recognise you when you return to the Properties. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

36. Please note that External Third Parties may also use cookies, over which we have no control. Fliplet accepts no liability in relation to any use of cookies by any third-party.

37. Before the Properties place Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Fliplet to provide a better experience and service to you. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Properties may become inaccessible or not function properly. Fliplet accepts no liability for any under-performance of the Properties as a result of your refusal or disabling of cookies.

38. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

39. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

40. Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know. We use the following cookies:

Google Analytics: This cookie is set by Google to distinguish and track website and app visitors for analytics and marketing purposes (name: _ga; duration: 2 years).
Google Tag Manager: This cookie is set by Google to distinguish and track website and app visitors for analytics and marketing purposes (name: _gid and _gcl_au; duration: 24 hours).
Fliplet Authorisation: This cookie is set by Fliplet to track the user’s website session and provide security access to Fliplet Studio (name: auth_token; duration: limited to the current web session).
Intercom: This cookie is set by Intercom to provide client support chat services as well as gather website visitor analytics (name: intercom*; duration: 1 year).
UserPilot: This cookie is used to trigger and monitor tutorials, guidance and checklists provided in the product (name: intercom*; duration: 1 year).
MixPanel: This cookie is used to record your usage for product optimisation purposes.
Segment: This cookie is used to record your usage and provide it to Segment for analysis and routing to other products we use, such as Mailchimp.
Delighted: This cookie is used to monitor your survey responses and ensure you are not shown them at the right frequency.

When will we disclose your Personal Data?

41. We may have to share your Personal Data with the third parties, including but not limited to those parties set out below, for the purposes set out in the table in paragraph 24 above.

External third parties which include processors in the following categories:

Payment providers
Analytics providers
Customer Service providers
Our hosting provider

How do we protect your Personal Data?

42. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

43. If you suspect any misuse or loss or unauthorised access to your Personal Data, please let us know immediately by contacting us via this e-mail address: support@fliplet.com.

44. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by the UK Government and businesses.

Data retention

45. Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once these have been satisfied, the Personal Data will either be deleted or amended to the extent that it would be considered Anonymous Data.

46. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

47. In some circumstances you can ask us to delete your Personal Data: see Erasure Request below for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

48. Under certain circumstances, you have rights under the Data Protection Legislation in relation to your Personal Data.

49. You have the following rights in relation to your Personal Data:

Right to access – the right to request copies of the information we hold about you at any time. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
Right to correct – the right to have your Personal Data rectified if it is inaccurate or incomplete. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to erase (“Erasure Request”) – 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 Data 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 Data to comply with the Data Protection Legislation. 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.
Right to restrict our use of your Personal Data – this enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability – the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data 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. In addition, this does not provide you with routine access to our systems and processes and only the extraction of your Personal Data.
Right to object – the right to object to our use of your Personal Data where 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 Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Withdraw consent – the right to withdraw consent at any time where we are relying on consent to process your Personal Data. 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.

50. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: support@fliplet.com.

51. If you are not satisfied with the way a complaint you make in relation to your Personal Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

52. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during the period for which we hold it.

Transfers outside the UK and European Economic Area

53. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK and EEA or one of our service providers is situated in a country outside the UK and EEA.

54. Whenever we transfer your Personal Data out of the UK and EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts approved by the European Commission and the Intellectual Property Office in the UK which give Personal Data the same protection it has in Europe.
Where we use providers based in the US, we will carry out a risk assessment in respect of the transfer of the personal data and will ensure that Standard Contractual Clauses are in place with the relevant sub-processor prior to transferring the personal data to them.

General

55. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

56. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

57. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

58. This privacy policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under this privacy policy will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

59. Fliplet reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Properties and you are deemed to have accepted the terms of the privacy policy on your first use of the Properties following the alterations. You may contact Fliplet by email at support@fliplet.com.

60. Our details are:
Full name of legal entity: Weboo Online Limited (company number 06974225)
Postal address: WeWork, 145 City Road, London, EC1V 1AZ
Email: support@fliplet.com