Hi, thank you for taking the time to read Flouria's Privacy Policy. 🌸

We store and process personal information about you if you use our app visit our website, subscribe to our newsletter or directly get in touch with us. We, Flouria Health B.V., are the data controller for all processing of personal data through our platform, which means that we are responsible for all your personal details flowing through our website and app. In this document, we will explain what personal data we process with regard to users, website visitors and newsletter subscribers, why we do so and what your rights are.

A. Personal data we process

Users

We process various types of personal data about our users. We distinguish between general personal data, data about your personal situation and health, and sign-up data.

General personal data we process include:

• nickname
• first and last name (optional)
• email address
• age
• any other personal information that you share with us, with the obvious exception of data about your personal situation and health

Personal situation and health data, which we will only process after we have received your explicit consent, include:

• personal experiment results
• your chats with our advisors

Sign-up data, which we will only store briefly to check if you have the right sign-up credentials, include:

• business email address

The main purpose for processing your user data is to offer you our services, via the website and the app. According to the law, we must state the legal basis here, which is that this processing is necessary for the performance of a contract to which you are a party. We may also process your general personal data for the purposes of our legitimate interests, including enhancing your experience of our website, improving our services, responding to your enquiries, complying with the law, and resolving disputes.

We only process user data which we have obtained from you directly, for example when you sign up for our app, if you share data with us during a conversation via phone or chat, by using the website or app, or if you participate in a personal experiment.

All personal data, except your email address, will be accessible to authorised Flouria advisors, via the Flouria platform. Other Flouria employees will only have access to your name and email address.

We try to limit our data processing as much as possible, so generally speaking any information we request from you will be necessary to provide our services. If you are not willing to submit certain information we request, we may not be able to provide our services, or you may not be able to enjoy all the benefits thereof.

Newsletter subscribers

For newsletter subscribers, we may store and process the following categories of personal data:

• name
• email address

We use these personal data solely to send you our newsletter, which we do on the basis of your consent.

B. Sharing your data with other parties

Your personal data will only be shared with other parties if that is necessary for the purposes we just mentioned. This means that we may transfer your personal data to:

• Flouria advisors, who are in most cases independent healthcare professionals
• tax services and other government organisations;
• courts and other dispute resolvers.

Please note that personal situation and health data will never be transferred to anyone, with the exception of Flouria advisors.

In addition, we may engage service providers (“processors”) to process your personal data. They will work in accordance with Flouria's instructions and guidelines, as we have concluded processing agreements with them which comply with GDPR requirements. The processors include:

• Google: for hosting our platform data, email contact, and analysing our website performance;
• Mixpanel: for analytics data from our app, which helps us analyse our app performance
• SendPulse: for sending emails from our platform
• Firebase: for sending push notifications to our app and collecting and analysing error reports from our app

Parties we share your personal data with can be based in countries where the GDPR does not apply, meaning that less protective data protection laws may apply. We will ensure that if this is the case, the parties we share your data with will agree to contractual terms or other measures to protect your personal data. You are of course free to contact us in case of any questions about our data sharing and the safeguards provided.

C. Protection of your personal data

We store your data on servers located within the European Union. Furthermore, we have taken appropriate measures in order to protect your personal data against unlawful processing. In addition to the usual technical security measures, we require all our staff who have access to personal data to agree to confidentiality agreements. We do not use automated decision-making.

D. Retention period

We will store your personal data no longer than necessary for the purposes mentioned above.

E. Your rights

You always have the right to request access to the personal data we store about you, and to request rectification, erasure or restriction of processing. You may also object to any of our processing, and you have the right to data portability. If you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens, or your local data protection authority.

F. Any questions?

If you have any questions regarding our processing of your personal data, please do not hesitate to contact us by email via support@flouria.health.

Date: April 2024