Floe Oral Care Limited – Privacy Policy
Dated: August 2020
Dated: October 2024
PLEASE READ THIS POLICY CAREFULLY BEFORE USING FLOE ORAL CARE LIMITED’S WEBSITE
Protecting your data, privacy and personal information is very important to Floe Oral Care Limited (“Floe”, “us”, “our”, or “we”).
This policy (together with our Terms of Service and any other documents referred to in it), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Floe. Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.
When visiting Floe’s website at www.floe.com (our “Website”) or using any of the services offered via the Website, (as detailed in our terms of use) (the “Services”), you acknowledge, and where applicable consent to, the practices described in this policy.
Our Website contains links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
Information we may collect
We may collect and process the following data about you: Information that you provide to us. You will be asked to provide us with your information when you:
fill in forms on our Website, or correspond with us by phone, email or otherwise;
register to use our Services;
use the Services;
report a problem with our Website or Services; or
complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).
You must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
For the avoidance of any doubt, any reference in this privacy policy to your data shall include data about other individuals that you have provided us with.
The information you will be asked to provide to us for these purposes will include your name, address, age in years, email address, telephone number and card payment details. For customers purchasing the Floe Oral Health Test, you will be asked to complete a questionnaire on your oral health and medical history, and confirm consent to share this. Information we collect about you. With regard to each of your visits to our Website we may automatically collect the following information:
device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
details of your visits to our website, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).
Information we receive from other sources. When using our Services, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Services.
Information we may collect about others. We may collect and process data about others that you provide us with, including (but not limited to) information that you provide by filling in forms on our Website or that you provide to us by email. This information might include, but is not limited to their name, email address and delivery address (if you are purchasing a Floe Subscription Box as a gift).
How we use your information and justification of use.
Use of personal information under the General Data Protection Regulation (EU) 2016/679 (including as it applies in the UK under the European Union (Withdrawal) Act 2018, the UK GDPR), must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information: Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
Contract performance: where your information is necessary to enter into or perform our contract with you;
Legal obligation: where we need to use your information to comply with our legal obligations;
Vital interests: where we need to use your information to protect your vital interests;
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you or a third party.
We use information held about you (and information about others that you have provided us with) in the following ways:
| Types of Information Collected | Uses of that Information | Use Justification |
| Name and email address. | To provide you with access to our Website and any other information which you request from us. | Contract performance. |
| Name, email address, telephone number, postal address and age in years. | To provide you with the Services and specifically for the processing of any enquiries made via our Website. | Contract performance. |
| Email address, name, payment details and bank account information. | To administer our Services including payment processing services such as Stripe. | Contract performance (in respect of payment processing. |
| Name, email address and [age in years.] | For marketing products and services that we believe will be of interest to you. | Legitimate interest (for marketing our own similar products and services and any re-engagement campaigns). Consent (for marketing unrelated products or services or products or services of third parties). |
| Name, email address, telephone number, postal address and age in years. | To administer our Website and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services. | Legitimate interest (to administer and improve our Services). |
| Name and email address | To notify you about changes to our Services. | Contract performance and legitimate interests (to update our Services from time to time.) |
| Health Profile Data | This includes any general health information that you provide to us other than your Test Result Data (for example, information regarding age, weight, height, ethnicity and information regarding your lifestyle, your current health status and your goals). | Legitimate interest (to administer and improve our Services). |
| Test Result Data | This includes your test results, any escalations related to your test results, any doctor commentary on your test results, any consultation and/or prescription(s) relating to your result. Where relevant, Test Result Data also includes the analytics we run on your results to provide actionable insights related to your health, such as trend data and predicted future results. | Legitimate interest (to administer and improve our Services). |
We will not sell your personal data (or any other data you provide us with) to third-parties; however, we reserve the right to share any data which has been anonymised and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.
Marketing
We may use information for marketing products and services to you in the following ways:
| Type of marketing activity | Use Justification |
| Newsletters and marketing emails relating to our or own similar services and products. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. | Legitimate interests (to market our products and services – you have the right to unsubscribe at any time) |
| To send you details about our own or unrelated services or products or special offers and discounts which are being provided by our selected business partners. Where required by law, we will ask your consent at the time we collect your data to conduct any of these types of marketing. | Consent (which can be withdrawn at any time) |
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.]
Disclosure of your information
We may disclose your personal information to our service providers and business partners, including: Salesforce, Stripe, Klaviyo, Shopify, ReCharge, our shipping/delivery partners and fulfilment centres (to assist us in performing any contract we enter into with them or you, including providing the Website and the Services it enables), analytics providers, including Google and Shopify (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
In addition, we may also disclose your personal information to third parties in the following circumstances:
| Purpose of disclosure and third party(s) to which disclosure might be made | Use Justification |
| If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets | Legitimate interest (to sell our business or assets). |
| If Floe or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets | Legitimate interest (to sell our Company or assets). |
| If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Floe, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection | Legal obligation, vital interest. |
| Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies. | Legitimate interest (to assist with the prevention of fraud and to assess your risk profile). |
| We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. | Legal obligation (to cooperate with law enforcement and regulatory authorities). |
Security over the internet
No data transmission over the internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
Sensitive information between your browser and our Website is transferred in encrypted form using secure socket layer (“SSL”) or equivalent cryptographic protocols using certificates issued by a trusted third party authority.
All information you provide to us is stored on our or our subcontractors’ secure servers, and accessed and used subject to our security policies and standards.
We use hosted servers (such as Google and Shopify) in the course of our business, including for the permission of marketing and sales activity. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share your password with anyone.
Exports outside the EEA (including the UK for the purposes of this policy)
Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor, we will impose the same data protection safeguards that we deploy inside the EEA.
Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient, unless we are permitted under applicable data protection law to make such transfers without such formalities.
Please contact us if you would like further details of the specific safeguards applied to the export of your personal data.
How long we retain your personal data
We will hold the above information for as long as is necessary in order to conduct the processing detailed in the table above, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within twelve (12) months. We will keep it for this time in case you wish to return to us at a later date; however, if you would like your personal data deleted sooner than this please notify us in writing and we will do so. Please not that some personal data may need to be retained for longer than this to ensure Floe can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.
If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymizes (and the anonymised information may be retained) or securely destroyed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the personal risk or harm from unauthorised use or disclosure, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights
Under the General Data Protection Regulation (EU) 2016/679 (including as it applies in the UK under the European Union (Withdrawal) Act 2018, the UK GDPR), you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at hello@getfloe.com.
In certain circumstances, you have the following rights in relation to your personal data:
| Rights | Details |
| Right of Access | You have the right to obtain from us information as to whether your personal data is being processed, and, where that is the case, access to such personal data. |
| Right to Rectification | We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete. |
| Right to erasure / ‘Right to be forgotten’ | Asking us to delete all of your personal data will result in Floe deleting your personal data without undue delay (unless there is a legitimate and legal reason why Floe is unable to delete certain of your personal data, in which case we will inform you of this in writing). |
| Right to restriction of processing | You have the right to ask us to stop processing your personal data at any time. |
| Right to data portability | You have the right to request that Floe provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so and the processing is based on consent or contractual performance. |
| Right to complain | You have the right to lodge a complaint to the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints. |
We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Floe’s Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.
Where you request Floe to rectify or erase your personal data or restrict any processing of such personal data, Floe may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right.
Other regulatory requirements
Our at home saliva Oral Health Testing kits are CE-marked. This means that everything in our kits meets health and safety requirements within the European Economic Area. Our broader team of scientists, technologists, and clinicians use the power of technology to ensure that everything we do is safe and credible. Our Oral Health Testing kits are certified as a Class II Medical Device, and these are also regulated by the Medicines and Healthcare products Regulatory Agency (MHRA).
Consent
The principle of consent is an important part of medical ethics and we rely on your consent to provide and perform the Floe Oral Health tests, result analysis, dental reporting, healthcare services, including sharing your health records with our Partners (where relevant for indirect Customers).
Consent for these purposes is required for medical treatment and testing, and under the common law duty of confidence. This is separate and distinct from consent under data protection laws. Generally, we do not rely on data protection consent as the lawful basis for processing your data under data protection law except in certain circumstances, such as in relation to direct marketing.
Changes to this policy
Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.
Contact
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to hello@getfloe.com.
For the purpose of the relevant data protection legislation, the data controller is Floe Oral Care Limited (company no. 11769642) with registered address at 316a Beulah Hill, London, SE19 3HF
Cookies
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For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
