Who we are
[FLUME LEGAL ENTITY NAME], trading as FLUME, is responsible for the personal information described in this Privacy Policy.
Our registered address is:
[FLUME REGISTERED ADDRESS]
In this policy, FLUME, we, us and our refer to the company responsible for processing your personal information.
For privacy questions or requests, contact us at connect@flumeglobal.com and include Privacy Request in the email subject.
What this policy covers
This policy applies when you:
- Visit the FLUME website
- Request a call or send us an enquiry
- Download the 90 Day Middle East Playbook
- Complete the Regional Readiness Check
- Register for an event, webinar or resource
- Communicate with FLUME by email or through another business channel
- Become or consider becoming a FLUME client, supplier or business contact
This policy applies to information about identifiable individuals. It does not apply to information that has been anonymised so that an individual can no longer be identified.
Information we collect
The information we collect depends on how you interact with FLUME.
Contact and professional information
This may include your name, work email address, telephone number, company, job title, country or region and professional profile information.
Enquiry information
This may include the FLUME solution you are interested in, your current activity in the Middle East, your regional priorities and any message or information you choose to provide.
Resource information
When you request the Playbook or another resource, we may collect your contact details, company information, source page and information about the resource requested.
Assessment information
When you complete the Regional Readiness Check, we may collect your answers, category scores, overall score, recommendations and any contact details you submit.
Website and technical information
This may include your internet protocol address, browser type, device information, operating system, pages viewed, links selected, time spent on the website, referring page, approximate location and campaign information such as UTM values.
Communication information
We may keep records of emails, meeting requests, calls, feedback and other communications with FLUME.
We do not ask you to provide sensitive personal information through our website forms. Please do not include health information, identity documents, financial account details or other sensitive information in free text fields.
How we collect information
We collect personal information:
- Directly from you when you complete a form, download a resource, take an assessment or contact us
- Automatically through essential website technology, server logs, cookies and similar technologies
- From another person in your organisation when they introduce or refer you
- From publicly available professional and business sources where appropriate
- From service providers that help us operate the website and measure its performance
Where information is collected from public or business sources, we use it only for relevant professional and business purposes.
How we use information
We may use personal information to:
- Respond to enquiries
- Arrange and manage requested calls
- Provide requested resources
- Generate Regional Readiness Check results
- Understand your regional priorities
- Recommend a relevant FLUME product or next step
- Manage client, prospect and supplier relationships
- Operate and improve the website
- Understand website and resource performance
- Protect the website and prevent misuse
- Maintain accurate business records
- Send marketing communications where permitted
- Meet legal, regulatory and contractual obligations
- Establish, exercise or defend legal claims
We do not use personal information for purposes that are incompatible with the reason it was collected unless permitted or required by law.
Our reasons for processing
Depending on the interaction and the law that applies, FLUME processes personal information for one or more of the following reasons.
Your request
We process information when you ask us to provide a resource, respond to an enquiry or take steps towards a possible business relationship.
Legitimate business interests
We may process information to operate FLUME, respond to business enquiries, improve our services, understand website performance, protect our systems and develop relevant business relationships.
When relying on legitimate interests, we consider whether the processing is necessary and whether your rights and expectations outweigh our interests.
Consent
We rely on consent where required, including for certain cookies and electronic marketing communications. You can withdraw consent at any time.
Legal obligations
We may process information where required to comply with applicable laws, regulations, court orders or lawful requests.
Contractual requirements
Where you or your organisation becomes a FLUME client, supplier or partner, we may process information to enter into and perform the relevant agreement.
Email and marketing
When you request a resource or submit a call request, FLUME may send a transactional message confirming that request.
Submitting a business enquiry or downloading a resource does not automatically subscribe you to general marketing communications.
Where FLUME offers marketing updates, consent must be requested separately when required. Marketing consent must be optional and must not be selected in advance.
You can stop receiving marketing communications at any time by using the unsubscribe link in the message or contacting connect@flumeglobal.com.
We may retain a limited suppression record after an unsubscribe request so that we can respect your preference.
Service messages, responses to enquiries and communications required for an active business relationship are not marketing messages.
International transfers
FLUME is based in the United Arab Emirates and may use service providers that process information in other countries. This means personal information may be transferred outside the country where it was originally collected.
Where required by applicable law, FLUME uses appropriate safeguards for international transfers. These may include contractual protections, recognised transfer mechanisms and assessments of the protection available in the receiving country.
You may contact us for more information about the safeguards relevant to your personal information.
How long we keep information
FLUME keeps personal information only for as long as reasonably necessary for the purpose for which it was collected.
Call requests and general enquiries
Up to 24 months after the last meaningful interaction.
Playbook and resource requests
Up to 24 months after the last meaningful interaction, unless the information forms part of an active business relationship.
Regional Readiness Check information
Up to 24 months after completion, unless the visitor requests earlier deletion or the information forms part of an active business relationship.
Client and supplier records
For the duration of the relationship and for the period required for legal, contractual, accounting and dispute purposes.
Marketing records
Until consent is withdrawn, the communication is no longer relevant or FLUME decides to stop the marketing activity. A limited suppression record may be retained after unsubscribe.
Analytics information
For the retention period configured in the relevant analytics service and no longer than necessary for website reporting.
Security and technical logs
For a limited period based on security, troubleshooting and legal requirements.
FLUME may retain information for longer where required by law or where needed to establish, exercise or defend a legal claim. Information may be deleted earlier when it is no longer required.
Security
FLUME uses reasonable technical and organisational measures designed to protect personal information from accidental loss, misuse, unauthorised access, alteration and disclosure.
These measures may include:
- Restricted access
- Authentication controls
- Encryption where appropriate
- Secure hosting and storage
- System monitoring
- Backups
- Staff and supplier confidentiality requirements
No method of transmission or storage can be guaranteed to be completely secure. Visitors should avoid sending sensitive information through general website forms.
Your rights
Depending on your location and the law that applies, you may have the right to:
- Ask whether FLUME processes your personal information
- Request access to your personal information
- Request correction of inaccurate or incomplete information
- Request deletion of information
- Request restriction of processing
- Object to processing
- Object to direct marketing
- Withdraw consent
- Request transfer of information in a usable format
- Request that processing be stopped in certain circumstances
- Ask for human review of certain automated decisions
- Complain to the relevant data protection authority
Some rights are subject to legal conditions and exceptions.
To make a request, email connect@flumeglobal.com and include Privacy Request in the subject line. Please describe the information or activity your request relates to. FLUME may ask for reasonable information to confirm your identity before responding. We aim to respond within the period required by applicable law.
Regional Readiness Check
The Regional Readiness Check uses answers provided by the visitor to generate an overall score, category scores and practical recommendations.
The scoring is intended to provide general business guidance.
The result does not make a decision that produces a legal or similarly significant effect.
FLUME may use assessment information to:
- Generate and display the requested result
- Provide a downloadable result where available
- Understand common regional readiness challenges
- Improve the assessment and FLUME services
- Respond when the visitor asks to discuss the result
Where results are used for aggregated reporting, FLUME will seek to remove or reduce information that directly identifies an individual.
Visitors may contact FLUME to ask questions about the scoring or request access, correction or deletion where applicable.
Children
The FLUME website and services are intended for business professionals.
They are not directed towards children.
FLUME does not knowingly collect personal information from children through the website.
A parent or guardian who believes that a child has provided personal information should contact FLUME so that the information can be reviewed and removed where appropriate.
External links
The FLUME website may contain links to websites or services operated by other organisations.
FLUME is not responsible for the privacy practices, security or content of those external services.
Visitors should review the privacy information provided by the relevant organisation before submitting personal information.
Changes to this policy
FLUME may update this Privacy Policy to reflect changes in the website, our services, legal requirements or the way we process information.
The current version will always be published on this page.
When a material change is made, FLUME will update the date at the top of the policy and provide an additional notice where appropriate.
Contact us
For questions about this Privacy Policy or the way FLUME handles personal information, contact:
[FLUME LEGAL ENTITY NAME] [FLUME REGISTERED ADDRESS]
Email connect@flumeglobal.com
Use Privacy Request as the email subject.
You may also have the right to raise a complaint with the data protection authority responsible for your location. We encourage you to contact FLUME first so that we have an opportunity to review and address your concern.