Flow Festival Oy (“Flow Festival”, “we”) process personal data of Flow Festival’s customers as well as users of our apps and services and the visitors of the website www.flowfestival.com (“Website”).
1. FLOW’S CONTACT DETAILS
Name: Flow Festival Oy
Company ID: 1601850-4
Correspondence address: Vilhonvuorenkatu 11 B 11, 00500 Helsinki, Finland
Customer service’s phone number: +358 9 7531 560
E-mail address: office AT flowfestival.com
Contact person: Susanna Hulkkonen, susanna AT flowfestival.com
2. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into two general data categories: Customer Data and Analytics Data.
Customer Data is personal data that is typically collected directly from you. We may collect Customer Data from our Customers in a variety of ways, including, when they register to MyFlow-service, subscribe to a newsletter or fill out a form. Such personal data include:
- name, home address, email address, phone number
- the artists and restaurants you have marked as your favourites in the MyFlow app
- marketing opt-ins and opt-outs
We may also process other information provided by you voluntarily such as:
- information you provide by phone or in email or chat correspondence with us
We may also receive some of the Customer Data from third parties, such as ticket sellers. This data includes your name, address, email and phone number. The ticket sellers collect such information in connection with your ticket purchase to the festival. Also, for example, if you connect or login to your MyFlow mobile app’s (“MyFlow”) account with Facebook, Facebook shares with us personal information about you such as your profile picture, a sample of your Facebook friends and your Facebook ID. If you connect or login to your MyFlow-account with Google, Google shares your personal information with us, including your name, e-mail address, and profile picture possibly attached to your account. When you login to your MyFlow-account with “Sign in with Apple”, Apple may share your name and email address with us.
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with Customer Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the Services:
Device Information. We collect the following information relating to the technical device you use when using the Services:
- device and device identification number, device IMEI
- country, city
- IP address
- browser type and version
- operating system
- Internet service providers
- advertising identifier of your device
- your location when using the MyFlow app. The location services are used to locate you on the map while at the festival site and to share your location with your friends.
Usage Information. We collect information on your use of the Services, such as:
- time spent on the Services
- interaction with the Services
- the URL of the website you visited before and after visiting the Services
- the time and date of your visits to the Services
- the sections of the Services you visited
- the keywords you use in the Services
We use various technologies to collect and store Analytics Data and other information when the Customers visit the Services, including for example cookies and web beacons.
Read more about the cookies and social media plug-ins we use from here.
3. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
There are several purposes of the processing of your personal data by Flow Festival:
To provide the Services (legal ground: performance of a contract and legitimate interest)
Flow Festival processes your personal data to be able to offer you the Services you use.
If you contact our customer service, we will use the information provided by you to answer your questions or solve your problems.
For our legal obligations (legal ground: compliance with a legal obligation)
We can process data to enable us to administer and fulfil our obligations under law. We may process data for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
Flow Festival may process personal data in relation to claims handling and legal processes. We may also process data for the prevention of fraud, misuse of our Services and for data, system and data network security.
For customer communication and marketing (legal ground: legitimate interest)
Flow Festival processes your personal data to contact you regarding the Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Services to you.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may also process information about your use of the Services to improve the quality of the Services e.g. by analyzing any trends in the use of the Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
Flow Festival processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with possibility to easily opt-out from our marketing communications.
In some parts of the Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
4. TRANSFER TO COUNTRIES OUTSIDE EUROPE
Flow Festival stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the Customer’s domicile.
We will take steps to ensure that the Customers’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
E.g. Flow Festival uses the MailChimp email service for sending its newsletters and press releases. The service causes personal information (email address) to be relayed outside of the European Union into the United States of America. Said information may also be relayed to Google’s servers inside the USA.
We do not share your personal data with third parties outside of Flow Festival’s organization unless one of the following circumstances applies:
To the extent that third parties need access to personal data in order for us to perform the Services, we provide such third parties with your data to be processed on behalf of us. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing services) to process it for us.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Services, the processing is based on their policies and standards.
For legal reasons and legal processes
We may share your personal data with third parties outside Flow Festival if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Flow Festival, the Customers or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
With your explicit consent
We may share your personal data with third parties outside Flow Festival when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
6. STORAGE PERIOD
Flow Festival does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
We store data related to your MyFlow account primarily as long as you have an account in the MyFlow app. The data is deleted within 12 months following the deletion of the account. We may store other Customer Data as long as such processing is required by law or is reasonably necessary for our legitimate interest such as claims handling, legal actions or internal reporting purposes. All such Customer Data will, however, be deleted within 10 years after you purchased your ticket with the exception of personal data required in certain rare situations such as legal proceedings.
However, information regarding direct marketing is stored until further notice if you have given us your consent for direct marketing. If you later opt-out from the direct marketing, we delete other information regarding the direct marketing, but will retain the information that you have opted out of the direct marketing to ensure compliance with the opt-out request.
We store Analytics Data relating to the visitors of our Website for 14 months.
7. YOUR RIGHTS
Right to access
You have the right to access and obtain a copy of your personal data processed by us. We may refuse to provide you with a copy of your data in case doing so would adversely affect the rights and freedoms of others.
Right to withdraw consent
In case the processing is based on a consent granted by the Customer, the Customer may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You may have the right to object on grounds relating to your particular situation to the processing of your personal data based on our legitimate interest. We will comply with such objection unless we have a legitimate ground not to. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Services.
Right to data portability
You have the right to receive all your personal data in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the Customer. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
8. DIRECT MARKETING
The Customer has the right to object to and prohibit us from using the Customer’s personal data for direct marketing purposes and profiling made for market research purposes or direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages. Where you object to processing of your personal data for direct marketing purposes, the personal data will no longer be processed for such purposes.
9. LODGING A COMPLAINT
In case the Customer considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (www.tietosuoja.fi).
10. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and systems protected with restricted access rights. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Customers, we will inform the relevant Customers as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.