Privacy Statement

 Last Updated and Effective as of: May 21, 2019

PRIVACY STATEMENT FOR FLO PRODUCTS AND SERVICES

At Flo, we take your privacy seriously.

This Privacy Statement for Flo Products and Services (“Privacy Statement”) describes information that Flo Technologies, Inc., and its subsidiaries and affiliates (collectively, “Flo”), collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information). By accessing our sites or providing us your information when you contact us, you are consenting to the information collection and use practices described in this privacy statement.

This document focuses on information related to the operation of all Flo products and services, including the Flo by Moen™ iOS and Android App, Flo by Moen™ Device, Flo System™, and other products from Flo (collectively, “Flo Products”). In this Privacy Statement, the expression “Flo Products” also includes our Web Apps, Mobile Apps, and Subscription Services as defined in our Terms of Service.

We provide additional details about how we collect and use information from our public web sites in our Privacy Policy for Flo Websites.

We reserve the right to change this Privacy Statement at any time, so please review it periodically.  We may notify you in the event we make changes to this Privacy Statement. If you have any questions regarding this Privacy Statement, you can contact Flo by email at support@meetflo.com, or by telephone at 1(844) Meet-Flo.

Our Pledge:

1. We will be transparent about the different types of information we collect and how we use them.
2. We will use data responsibly.  When using or sharing data with third parties, we'll generally do so for purposes of providing or enhancing Flo Products, and when we think they will provide you with a welcome additional service.  In certain circumstances, a third party (such as your home insurer, home warranty provider, or plumber) may pay for the installation of the Flo by Moen Device, subsidize, discount or pay for part of the Flo System or Flo Service, and/or some or all of the Flo Products (a “Third-Party Payer”).  In that circumstance, you are deemed to have consented to permit Flo to share data collected from the Flo Products, including your personal information, with that Third-Party Payer.
3. We will use industry standard data security tools to keep your data safe and protect the Flo Products from unauthorized access. Flo is committed to protecting the security of your personal information and data. We use a variety of security technologies and procedures to help protect this information from unauthorized access, use or disclosure.

Your Consent:

Consent to data collection and processing. By using Flo Products, you agree to allow us to collect and process information as described in this Privacy Statement.  You acknowledge that monetizing data is part of Flo's business model, and helps allow Flo to provide the Flo Products and Services; as such, you consent to Flo using and monetizing your data. 

Consent to data export. Your personal information may be collected, processed and stored by Flo or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using Flo Products in the European Union or other regions with laws governing data collection and use that may differ from United States law, you consent to the transfer of your personal data to the United States and other countries where Flo operates.  

California residents should click here for CCPA information. 

What information does the Flo Device collect?

The Flo Device collects:

• Setup, account and on-boarding information you provide, or as provided by a third party, including but not limited to your name, email, password, home address, phone number, home profile info, Wi-Fi and other information
• Data from the Flo Device’s sensors and system, including but not limited to alarms, notifications, user preferences, settings, and user actions
• Other data collected by the Flo System via third party systems you’ve authorized the Flo System to communicate with
• Direct adjustments to the Flo by Moen Device and Flo by Moen App, including modifications or settings
• Technical information from the Flo by Moen Device

Setup information you provide: When you install the Flo by Moen Device, you’ll be asked several questions in order to help us create an initial program of water usage settings that may help keep your home safe. For example, we’ll ask for information like whether your Flo by Moen Device is in a single family home, the number of occupants and size of the home, or your home address or postal/ZIP code. This information helps us to customize your experience to set up an initial program and help protect your home.  We will also collect information as you use the Flo System – whether by opening the Flo by Moen App, clicking on the various functions, or contacting customer support.

Data from the Flo by Moen Device’s sensors: We collect data from several sensors built into the Flo by Moen Device. These sensors collect data such as current flow rate, temperature, and pressure rate of your water system. This helps your Flo by Moen Device protect your home and detect leaks.  Information about leaks, notifications or alarms delivered through the Flo by Moen App, and any actions you take in response to those notifications are also collected.  We may share this data with third parties, including third parties that you authorize to receive such data (such as your plumber). 

Direct adjustments to the device: When you use water in your home, the Flo by Moen Device records and feeds that information to algorithms developed by Flo to learn what’s normal water usage in your home in different situations and at different times of the day and week.  Also, in those situations in which you change a setting, like when you set the Home/Away/Sleep Assist feature on the Flo by Moen App. 

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with the Flo by Moen Device, we record your Flo by Moen Device model and serial number, software version, and other technical information.

What information is shared among multiple connected Flo Products?

If you have multiple Flo Products or sensors interfacing with one another, the products will share certain information with each other, such as data on the water temperature, water pressure, moisture, occupancy and leaks. This sharing may occur locally among connected devices (both Flo and third-party devices). Sharing can also occur between Flo Products and your mobile device or application, or among Flo's servers. Understanding occupancy can help the products do things like better assess if you are away from home so water data can be better analyzed. You may also set the Home/Away/Sleep feature to enable or disable other features.

How does my Flo System or account interact with third parties?

• If I connect third-party products and services to Flo, will information be shared? When you choose to connect third-party products and services to Flo, you are shown details about any proposed exchange(s) of data between Flo and the third party that is providing the product or service. In some cases, Flo or the third party will instead (or also) ask for permission to control the products that you have connected. Your explicit consent is required for requests for control and you will be able to revoke it at any time.

• Is information automatically shared with or received from third parties?

Flo may use third parties to provide some Services on its behalf. For example, Flo may use third parties to host its websites, send you notifications, conduct surveys, or process transactions, among other services. Also, Flo may share information with other devices and services installed in your home, such as a smart thermostat.  Flo may share information with third parties in order to deliver these services efficiently without any further notification to you.

To performing certain Services-related services, track issues in the case of an error, and assist in analyzing how our Service is used, Flo Mobile Apps do use third party services that may collect information used to identify you. Links to the privacy policies of third party service providers used by the Flo Mobile Apps:

• Google Play Services
• Firebase Analytics
• Fabric
• Mixpanel
• Zendesk

Additional information about the limited circumstances in which information from your Flo account may be shared with third parties is described below in the section titled “In what circumstances does Flo share my information?”

Any Flo data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession. Although Flo tries to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites or third parties.

Any data that Flo receives from third-parties will be processed and stored by Flo and will be treated in accordance with this Privacy Statement. This information may be processed in the same ways as any other data that is a part of your Flo account.

What additional information does Flo collect and store when a user connects a Flo Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your Flo Product to our Services, or to access your Flo Product over the Internet from a computer, a smartphone or a tablet, you will need to connect it to your Wi-Fi network. During setup, Flo will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device, along with your IP address, so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with Flo servers and download software updates.

Once connected to your Wi-Fi network, your Flo by Moen Device regularly sends the data described in this Privacy Statement (excluding your Wi-Fi password) to Flo to provide you with the Services.

Additional Authorized Users: Flo may provide you with the ability to enable additional authorized users to access your account. If you do so, the additional authorized users may control and view all of your devices, content, and third-party connections. Invited users may also add additional authorized users to your account, so be careful to add only those you trust. An invited user must have or create a Flo account, and information about invited users (like email address, name, or changes to product settings) will be stored with your account.

Email Addresses: When you create a Flo account, we collect and store your email address. From that point forward, your email address is used for communications from Flo. In addition, Flo may provide you with the ability to enable individuals to access your account as additional authorized users, or to invite other individuals such as friends or family to share access to your content. We will ask you for the email address of any such individuals and automatically send an email invitation on your behalf. Flo stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation services.

Basic Profile Information: Your account may allow you to provide certain basic profile information like your name and profile photo. Names and profile photos may be shown to others in connection with the Services. For example, if you invite someone as an additional authorized user, he or she may be able to see your name and photo. You should only use photos you are willing to make public.

Mobile location data: You may choose to enable features like Home/Away/Sleep Assist. If you do this, you’ll be asked to share location data from your mobile device or from additional authorized users. This data may be processed or combined with data from other products to enhance features like Home/Away/Sleep Assist.

ZigBee (or other local communication protocol) data: ZigBee (or other local communication protocol) - enabled Flo Products may broadcast an identifying signal wirelessly. This is used to connect with your ZigBee (or other local communication protocol) - enabled devices (such as a smartphone or tablet) in order to deliver features like easy setup or App Silence.

Remember that when you visit our web sites, we collect personal information as described in our separate Privacy Policy for Flo Websites. Like most Internet sites, we routinely record log entries (including information such as your IP address) and technical information (such as your browser type and version) when your browser, mobile device or Flo Product contacts our servers.

How does Flo use the information it collects?

We may use this information to provide, develop and improve Flo Products and services, including to make assessments and recommendations about products, safety, or water use. We may use your contact details to send you this information, or to ask you to participate in surveys about your Flo use, and to send you other communications from Flo.

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, Flo may process your personal information on servers that are not in your home country. Although the laws that protect personal information in those countries may differ from the laws where you live, we will take reasonable steps to ensure that your privacy is protected. By contacting us, using our Flo Products, or using our Services, you consent to the transfer of the data outside of your country.

In what circumstances does Flo share my information?

We do not share personal information for any commercial or marketing purpose unrelated to the activation, enhancement, research, services and delivery of Flo Products and Services without asking you first, except as otherwise stated in this Privacy Statement.

The following are the limited situations where we may share personal information:

• With your explicit consent: We may share personal information when we have your consent. One example of this would be if you invite another user to access the Flo Products on your account as an additional authorized user. Another example is if you sign up for programs offered by our partners (e.g., water or insurance companies); if you do this, we may share certain information with the partner. This could include things like your enrollment information, usage data and the activation status of your device. Similarly, when you connect third-party devices and services to your Flo Products, you are shown information about any proposed exchange of data. Your explicit consent is required to allow these exchanges on your behalf and you can change your mind at any time.  Also, as described above, in certain circumstances, a Third-Party Payer (such as your home insurer) may pay for the installation of the Flo Device and some or all of the Flo Products, in which case you are deemed to have consented to permit Flo to share data collected from the Flo Products, including your personal information, with that Third-Party Payer.
• For certain transactions: In connection with certain transactions, we may disclose some or all of your personal information to commercial partners, insurers, financial institutions, government entities and shipping companies or postal services involved in fulfillment of the transaction without further notice to you. Disclosures may occur on an ongoing basis pursuant to Flo's agreements with such commercial partners, insurers, financial institutions, government entities and shipping companies or postal services. 
• For external processing: We may use vendors, service providers, and technicians to help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers for technical problems.
• For installations: We may use professional plumbing servicers or handypersons to install your Flo Device on the water supply line to your home. 

These technicians (as well as Flo employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Flo purposes.

As part of business transitions: Circumstances may arise where, for strategic or other business reasons, Flo decides to sell, buy, merge or otherwise reorganize its businesses or commercial partnership. Such transactions may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of personal information from sellers. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of Flo’s assets. Upon the completion of such a transaction, your personal information may be among the items sold or transferred.  We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.

• For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, to respond to legal process, or comply with state and federal laws (or the applicable laws of foreign countries other than the United States).

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about water use in the home. This information may also be shared with other users to help them better understand their water usage compared to others in the Flo community, raise awareness about safety or conservation issues, or help us generally improve our system. We may also share non-personal information with our partners, for example, if they are interested in providing demand-response services or other incentive programs. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

If you select an outside party for the purchase, installation, or service of your Flo device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a Flo by Moen Device from a retailer, the retailer may collect personal information as part of the transaction. Or the party that installed the device may retain information that you provided to them to assist them in servicing the device if needed. Always check the privacy policies for any company that collects your personal information.

Additional EU Disclosures
Our role as data controller 

Flo generally acts as the data controller of your information submitted through our Flo Products.

If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us”. If you are situated in the EU and have a complaint, please contact our privacy manager at legal@meetflo.com.

Additional Information Regarding Insurance Pilots: If you have agreed to participate in a pilot project between us and a third party involving the sharing of data collected from the Flo device and the related Services. In this case, Flo and the insurance partner may have entered into an agreement in which Flo will be providing to the insurance carrier, with your consent hereunder, data generated from your use of Flo and the Service.

By accessing or using Flo and the Service, you acknowledge that you have read, understood, accepted, agreed to be bound by and to comply with this Privacy Statement and the Terms and Conditions. 

1) You agree to allow the insurer to access your information. Such information may include, but not be limited to, personally identifiable information about you, your property, the functioning of the plumbing equipment in your property, and other data that might provide the insurer with information about the risks of future water leaks in your property (collectively hereafter, “Data”). You agree and consent to allow us to license the Data to the insurer. Initially, the insurer will use the Data from the Services offered by Flo to the insurer. The use of the Data can be expanded into purposes, including underwriting/rating purposes, such as providing discounts to customers who enroll in an insurer's policy or discounting programs. Your consent to sharing the Data with the insurer is voluntary. Should you decide at any time to discontinue your participation in the sharing of Data with the insurer, you may do so by removing Flo from your property and notifying Flo of your intent to withdraw your consent and/or completing this webform if you are a California resident: meetflo.com/ccpa. In the unlikely event that damages to your property are caused by Flo or the Service, you agree that the insurer shall have no liability for such damages and that you will waive and not make any claim against the insurer for such damages.

2) Except as described in this Flo Privacy Policy, Flo will not share your Data without first explicitly asking your permission, usually in the form of a web page, email or app screen requiring you to indicate your acceptance of the terms.

3) Insurers may offer you services through the Flo app that uses the Flo APIs to access your Data. If such services are offered, you hereby consent to such access, which access is subject to this Supplement and the Terms and Conditions.

Does Flo save my personal information?

Flo stores your personal information on Flo’s servers in order to provide you with Flo Products.

As described above, some information is processed and stored directly on the Flo device. Personal information is encrypted as it is transmitted to Flo and cannot easily be accessed.

We may share, as described in this Privacy Statement, information with our affiliates and subsidiaries, and third parties. We may disclose information in response to legal process and lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.

Please note that this Privacy Statement may change from time to time.  

If you have any questions, please contact us at privacy@meetFlo.com.