FLO Privacy Policy

In-Effect Date: June 26, 2018

Welcome and thank you for using our website, mobile application or transactional pages (collectively, the “Sites”), as well as our network of charging stations, owned and operated by FLO Services USA Inc. (collectively, “FLO”), FLO’s key office for privacy-related issues is located at 1209 Orange Street, Wilmington, New Castle County, Delaware 19801. FLO collects information about you when you visit our Sites or use our network of charging stations (the “FLO Network”). The purpose of this privacy policy, as it may be amended from time-to-time (the “Privacy Policy”) is to provide you with information about how and why FLO collects, uses and discloses information about you, the options you have in this respect and how you can access and rectify it, if necessary.

Note that we reserve the right to update this Privacy Policy from time to time and your use of the Sites and the FLO Network following an update constitutes your agreement to any modifications, subject to applicable law.

We reserve the right to update and change the terms of this Privacy Policy at any time.  If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Sites, and in the updated Privacy Policy. We may also notify you at the e-mail you provided us with. You should periodically check this Privacy Policy for updates.  By continuing to access or use the Sites or the FLO Network after we have posted an updated Privacy Policy or have provided you with written notice to you of any material modification to same via email or other method of notification you specify, you are agreeing to be bound by the modified Privacy Policy.

Consent

By using our Sites or the FLO Network, you consent to our collection, use and disclosure of that personal information as described in this Privacy Policy. We, therefore, invite you to read this Privacy Policy carefully. You may withdraw your consent to any further collection of personal information, in whole or in part, at any time by writing to our Privacy Officer at privacy@flo.com.  We, wish to advise you, however, that by doing so you may cease to enjoy certain privileges offered by the use of our Sites and the FLO Network.

Location

The Sites are intended for the use of our customers and users in the United States of America only. You may not use the Sites from another country. If you use the Sites from another country, you agree that only the laws of the United States of America will apply to your use and that we will under no circumstances be liable for, and you will hold us harmless against the application of the laws of any other country.

Types of Information Collected

Personal Information

For the purposes of this Privacy Policy, “personal information” refers to any information concerning an individual that allows for the individual to be identified (directly or indirectly).

You are not required to supply personal information to view the content of the Sites. However, we will require your personal information in certain instances, such as when you buy a charging station, when you create a user account to use the FLO Network, when you use the FLO Network to charge your electric vehicle or when you contact customer service.

Depending on the circumstances, we may collect different types of personal information about you, including the following:

  • your name;
  • your address;
  • your date of birth;
  • your email address;
  • your phone number;
  • your use of the FLO Network, such as your power consumption, the date of use, your geolocation and other similar information;
  • your electric vehicle model;
  • identifiers such as cookies, IP addresses, and mobile device IDs that recognize individuals over time and across different websites or online services, where those identifiers can be reasonably linked to an identifiable individual; and
  • details about problems using the FLO Network you may have experienced.

Client Experience

We may solicit your input on your experience using the FLO Network or navigating the Sites.

Telephone Communications

If you communicate with one of our representatives by phone, the conversation may be recorded in order to assess the quality of the service, to train our employees or to protect both parties in case of disagreement. You will be notified of such recording in advance and may refuse it.

Cookies

We use cookies and other similar surveillance technologies (including scripts, pixel tags, etags, web beacons) to help customize the Sites for visitors. Cookies are small text files that your browser installs on your computer or other device that enable the Sites to recognize you upon your visit. These cookies remain on your computer and are automatically retrieved when you visit the Sites. Some cookies are necessary for the Sites to function efficiently when you visit, and they allow us to know the pages you have visited. These cookies do not contain any personal information.

You may disable cookies on your computer. Most browsers are initially set up to accept cookies; however, the “help” feature of the menu bar on most browsers will tell you how to manage cookies and/or how to disable them completely.

Please be advised that disabling cookies may affect user functionality. For instance, visitors who have disabled cookie processing will no longer be able to enjoy all functionalities related to the management of their user account.

Web Logs

We keep standard web logs that record data about all visitors to the Sites. These logs do not contain personally-identifiable information and may consist of:

  • the Internet domain from which you access the Sites;
  • the location from which you access the Sites
  • the type of browser and operating system you use;
  • the date and time you visited the Sites;
  • the pages you viewed on the Sites; and
  • the address of the websites from which you linked to the Sites.

We also may have to record your IP address when you visit the Sites. When you surf the Internet, your computer is automatically assigned an IP address via an Internet protocol. Your IP address is either static or dynamic; a static IP address may allow for you to be identified; while a dynamic IP address does not usually allow for it.

Information Through Mobile Devices.

 

When you access the Sites or the FLO Network  through your mobile telephone or other mobile devices (“Mobile Device”), we may collect: (i) Mobile Device type and manufacturer; (ii) mobile carrier; (iii) Mobile Device identifiers (“Device ID”); (iv) telephone number; (v) Internet Protocol address; (vi) geographic location/country/zip code; (vii) platform version; (viii) installation, navigation, access, interaction, impression and engagement information; (ix) network connection type; (x) browser type; (xi) Mac address; (xii) iOS advertiser ID; and (xiii) such other information you voluntarily provide to us. In addition, we may collect information you provide when you sign up to have Short Message Service notifications sent directly to your Mobile Device.

 

Children

The Sites are not intended for children under the age required to drive an automobile in your jurisdiction or 13 years, whichever is higher. If you are under this age, please do not provide personal information to us of any kind whatsoever. If a child under this age provides us with personal information, a parent or guardian of that child may contact us to have this information deleted from our records. If you believe that we may hold information from a child under the age of 13, please notify us though our Privacy Officer by e-mail at privacy@flo.com.

 

Use of Information

We use the information we collect about you mainly for the following purposes:

  • Administering the Sites and making them available to you;
  • Allowing you to buy our products and services online;
  • Allowing you to access the FLO Network and networks with which we have roaming agreements and to use the charging services they offer;
  • Billing you for your charging activities on the FLO Network and networks with which we have roaming agreements;
  • Detecting and preventing threats to computer or FLO Network security;
  • Developing and marketing our brand image, products and charging services, promotions and advertising.
  • Communicating with you about technical notices, product and service upgrades, security alerts and support— because this information is important to your interaction with FLO, you may not opt out of receiving these communications while you still have an account with us;
  • Verifying your identity and the veracity of any requests if you contact us;
  • Responding to your requests, complaints, comments and questions, including helping you find alternative charging locations near you, if necessary;
  • If you enter into a sweepstake, contest, or similar promotion, we may use the information you provide to administer those programs; and
  • From time to time, any other purpose authorized or required by applicable law.

 

We also use the information we collect about you to generate statistics, gather information, and measure activity on the Sites and on the FLO Network. When we compile information for these statistical purposes, your personal information is not individually identifiable. Rather, it forms part of a whole made up of data from all the users of charging stations.

We may use your personal information to communicate with you about our services, upcoming events, promotions and special offers, and other news about us. We will ask you for your consent before doing so, subject to the applicable laws. Moreover, you will have the right to request information regarding our disclosure of your personal information to our affiliates or third parties for marketing purposes.  You may do so and/or withdraw your consent to this type of use by writing to our customer service at privacy@flo.com. More particularly, if you are on our mailing list and wish to unsubscribe, you may do so by clicking the link provided on every email.

We use cookies to help us analyze the Sites’ performance, remember your preferences, monitor your usage and tailor advertisements to you (see the section on Interest-Based Advertising below).

Sharing of Information

Your personal information will not be shared with third parties other than as described in this Privacy Policy, except as required or authorized by law, or as ordered by a competent court.

Partners and Suppliers

FLO may share information related to your use of the Sites and the FLO Network (i) with the owners and the hosts of our charging stations, and with our service providers and entities with which we run joint programs or offers, such as electricity suppliers, in order to improve or to continue to offer the charging services and to provide services related to programs you have chosen to participate in involving our service providers and entities with which we run joint programs or offers.

When you use your FLO user account to “roam” on another EV charging network with which we have a roaming arrangement, or if you are a member of another EV charging network “roaming” on the FLO Network, we are required to disclose various personal information with the operator of the other network to support your charging including, but not limited to, name, FLO Network user number, charging information, contact information, to provide any support necessary and conduct billing and reporting as required by agreement with our roaming partners.

When you are a member of another EV charging network, by using our FLO Network and Sites you agree to be bound by this Privacy Policy.

Within FLO, we limit access to your personal information to authorized personnel in compliance with applicable law.

Third parties

We may also share information with third parties, specifically financial and legal advisors, as part of a sale or assignment of our business, for audit purposes or for other financial transactions, including, but not limited to, credit transactions.

Affiliates

 

We may disclose personal information to our subsidiaries, parent companies, joint ventures and other corporate entities under common ownership located in the United States, Canada or anywhere else in the world for the purpose of transferring and processing such personal information based on our instructions and such purposes as described in this Privacy Policy.

 

Ownership Change 

 

In the event we combine with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personal information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction.  If material changes to our privacy practices will occur as a result of such transaction, you will be notified via prominent notice in our Sites of any change in ownership or uses of your personal information, as well as choices you may have regarding your personal information.

 

Aggregated Information

We may share with third parties some non-personally identifiable information and aggregated non-personally identifiable information, for example, the number of customers located in a certain geographic area or the number of hours in a day customers with an electric vehicle use electric vehicle chargers.

Safekeeping of Information

No method of transmission over the Internet, or method of electronic storage is ever completely secure. There is always a risk that the information you are sending us may be lost, intercepted, hacked or misused. Therefore, we encourage you to take special care in deciding what personal information you provide to us as we cannot guarantee its absolute security.

Storage of Information

All personal information will be safeguarded in a confidential manner in compliance with the privacy laws of the jurisdictions where we do business. We employ reasonable administrative, technical and physical safeguards to protect your personal information from loss, theft and unauthorized access, use, modification and destruction. We process personal information on our servers in the United States, Canada and in other countries.  In some cases, we may process your personal information outside of your country.  By using our Sites or the FLO Network, you consent to your personal information being transferred to, stored in, and processed outside of the United States.

Access to your personal Information

You have a right, under the law, to obtain access to your personal information and to request that it be corrected if the personal information is inaccurate, out of date, incomplete or ambiguous, or if the collection, release or keeping of the information is not authorized by law. If you notice any errors or inaccuracies, please let us know and we will make the necessary corrections. Subject to our retention rights described below, you may also request to have your personal information deleted.  Any request for access to, or correction or deletion of your personal information and any notice shall be directed by e-mail to FLO’s Privacy Officer: privacy@flo.com.

Retention Period

Your personal information is kept as long as required for the purposes for which it was collected or for the purposes of compliance with our legal and regulatory obligations. When the information is no longer necessary, it is destroyed. When destroying documents and data, we follow strict procedures and ensure that only authorized personnel have access to them.

In addition, we will provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.

Interest-Based Advertising

This section tells you about FLO’s online advertising practices.

As mentioned above, we use cookies and other similar surveillance technologies (including scripts, pixel tags, etags, web beacons) on the Sites to understand your habits when you browse the Sites or the websites that display our advertisements. These tools help us and our marketing partners tailor advertisements that we think are most helpful and relevant to you. We may also use the information we gather about you to customize our advertisements according to your interests.

Customized Social Media Ads

FLO partners with third-party social media platforms, such as Facebook, to show you customized advertisements. To offer such ads, we may convert your email address, telephone number or other contact information you have provided to us into a unique value which can be matched to your social media profile by our partners, such as Facebook or other social media platforms. While FLO does not provide any personal information to these platforms, these platforms may gain insights about individuals and help us in providing interest-based advertising. Please visit Facebook for information on Facebook’s advertising and privacy policies https://www.facebook.com/about/privacy/), and visit any other social media platform you use for information on their policies.

Your Choices with Respect to Interest-Based Advertising

You have a choice whether or not to accept the use of certain cookies by using the “help” feature of your Internet browser.

You can opt-out of network advertising programs here:

You can opt-out of customized social media ads by adjusting your social media settings (for instance, you can manage your settings via your Facebook profile). You can also unsubscribe from mailing lists by using the links included in the advertisements.

Do Not Track

We do not respond to DNT (Do Not Track) signals.

Please note that if you opt-out you may still receive online advertising from FLO or from other websites or applications. However, these advertisements will not be displayed to you based on your interests.

Final Provisions

This Privacy Policy is an integral part of the Terms of Use of the Sites and the FLO Network and all of their terms and conditions apply herein, including without limitation, the provisions regarding applicable laws and possible modifications.

 

© 2018. FLO Services USA Inc. All rights reserved.

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