Privacy & Cookies Policy

FLEX TECH DESIGN, a company registered in The Netherlands under company number 75421429 and with our registered office at Johan Huizingalaan 763A, 1066 VH Amsterdam, Netherlands ("We" or "Us") are committed to protecting and respecting your privacy in line with the EU General Data Protection Regulation (GDPR) and any other applicable legal framework.

This policy together with any other documents referred to on it sets out the basis of:

• What Personal Data do we collect and why?
• What do we do with your Personal Data?
• How do we secure your Personal Data?
• How can you change or delete your Personal Data?

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Definitions

• "Site" — means the public area of FLEX TECH DESIGN.
• "Service" — means the restricted area of FLEX TECH DESIGN accessible via registration.
• "User" — means a person who uses our Site or has registered to use our Service.
• "Personal Data" — means any information that can personally identify an individual.
• "Legal Framework" — any applicable, lawful act or regulation that outlines the protection of Personal Data.

Standard Contractual Clauses

The Standard Contractual Clauses are standard sets of contractual terms and conditions which the sender and the receiver of personal data both sign up to, aimed at protecting personal data leaving the European Economic Area (EEA) or being transferred to a country where there is no adequacy decision in place between the EU and the relevant country.

What Information Do We Collect?

The legal basis on which we process information we collect is in order for us to provide the Service outlined in our Terms and Conditions and is in our (FLEX TECH DESIGN's) legitimate interests which are further explained in the "How We Use The Information Collected" section of this Policy.

We may collect and process various forms of information when you use our Site or Service:

User-Provided Information

When you use our Site or Service, you may provide Personal Data and we may collect this as a result. Personal Data is any form of information that can identify an individual, for example: name, email address, mailing address, and credit card or other billing information. Examples of when this information may be provided include, but are not limited to, when you register to our site, subscribe to our services, complete surveys you have consented to, and when you have contacted us.

Automatically Collected Information

If you use our Site or Service we may automatically collect information about your computer, including, where available, your IP address, operating system and browser type. We achieve this by using cookies and other forms of technology. All of the information that is automatically collected is statistical data about our Users' browsing actions and patterns. Some of this information is stored for security purposes so we can alert you of any suspicious activity on your account.

User Collected Information

We may collect Personal Data to ensure full functionality of the features provided depending on how you, the User, use our Service. For example, we may store names, mailing addresses and contact numbers (amongst other information) of your customers so you can fulfil any orders that are placed through our Service. For this purpose, FLEX TECH DESIGN is the data processor. Each User is responsible for providing notice to their customers or users detailing what Personal Data may be stored and processed through our Service, and the reasons for doing so.

Third-Party Information

Integrations from third-party services available through our Service will give us access to certain Personal Data in order for us to provide full functionality of the respective integration. Certain integrations may also require us to receive and store data of your customers or users depending on the functionality of the service. By agreeing to this Policy, you authorise us to access and store any Personal Data, including that of your users or customers, that may be required.

Each User is responsible for providing notice to their customers or users detailing what Personal Data may be stored and processed through our Service, and the reasons for doing so. We will only have access and thus use any Personal Data that is essential and will not disclose any of the information shared via these integrations. Please be aware that each third-party service will have their own privacy policy so be sure to check with each service for exactly what information they make available to us.

Client Portal Data

When you use our Client Portal (Creative Command Centre), we collect and store data that you submit through the platform. This includes project briefs, feedback and comments, approval decisions, uploaded files and assets, team member information, and any other content you provide within the Portal. This data is processed to deliver the Services outlined in your Subscription and to maintain a record of project history and communications.

Communication Channel Data

We offer multiple communication channels as part of our Service, including WhatsApp, email, voice notes, and video calls. Messages, voice recordings, and other communications exchanged through these channels may be stored and processed for the purpose of creating project briefs, maintaining records, and delivering the Services. Voice notes may be transcribed using automated transcription tools to create written records and actionable briefs.

AI-Assisted Processing

We use artificial intelligence (AI) tools to assist our team in processing client communications and project information. This includes transcription of voice messages, summarisation of briefs, and assisting with content drafting. AI is used solely as a tool to support our team — all decisions regarding your projects, deliverables, and account are made by our staff. AI does not make any decisions on our behalf. Your data processed by AI tools is subject to the same security and confidentiality safeguards as all other Personal Data we handle.

File Storage & Asset Management

Files uploaded to our Portal or shared via communication channels (including images, documents, brand assets, source files, and project deliverables) are stored securely using cloud infrastructure providers. These files are retained for the duration of your Subscription and for 30 days following cancellation, after which they may be permanently deleted. You are responsible for downloading and maintaining your own backup copies of all files and deliverables.

How Do We Use the Information Collected?

We use the information that we collect in a variety of ways during the provision of our services and operation of our business, including the following:

Operations

• To ensure that all the features we provide are available, functional and maintained as per the specifications advertised
• To carry out our obligations arising from any contracts entered between you and us
• To carry out any business-essential administrative processes
• To allow you to participate in interactive features of our Service, when you choose to do so
• To enhance the Service we provide by developing new features and improving functionality of existing features
• To enable our team to provide support to Users when requested or required to do so
• Investigate any issues that arise from using our Service
• To notify you of any changes to our Service
• To provide any information you have requested or that we feel may be of genuine interest to you, including updates about the services we offer, promotions and general business information which may or may not be connected to third parties we work with. You have the right to opt-out of receiving any promotional information as detailed below under "Your Rights".

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our Site and to deliver a better and more personalised Service. By using our Site or Service, you agree to the use of cookies.

For full details on the cookies we use and how to manage your preferences, please see our Cookie Policy.

Types of Cookies We Use

• Strictly Necessary Cookies — Required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
• Analytical / Performance Cookies — They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works.
• Functionality Cookies — Used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences within the application.
• Targeting Cookies — These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and any advertising displayed on it more relevant to your interests. We may also share this information with third parties, such as through the Meta (Facebook) Pixel, for this purpose.

You can find out more information about cookies and how to disable them by visiting cookiesandyou.com.

Analytics

We use Google Analytics and Google Search Console to measure traffic to our Site and understand how Users move around and use our Service. We use this information to enhance the Site and Service we provide. All of the information we collect from Google Analytics and Google Search Console is aggregate and will not be disclosed to any other third parties.

By agreeing to this Privacy Policy, you agree to the use of Google Analytics and Google Search Console. Google may use the data collected to assess activity on our site. As Google is a separate entity to us, it has its own privacy policy which we recommend you review. If you wish to do so, you can opt out of Google Analytics.

How Do We Secure Your Information?

When your information is submitted to us, we use it to ensure that appropriate security measures are in place to protect your information. These safeguards are implemented to ensure that Personal Data in our possession is not subject to any unlawful forms of processing, including accidental loss, unauthorised access or disclosure.

Our Site and Service have Secure Socket Layer (SSL) encryption present amongst other general security measures such as firewalls and password protection to certain areas of our Service. Our employees are trained to ensure that all administrative processes are followed so your data is handled and processed accordingly. These measures are regularly reviewed.

The data we collect from you may be processed, transferred and stored using various services integral to our business operations. These services may be based in locations outside of the European Economic Area (EEA) and only the essential and necessary data will be provided to them. Data may also be processed by a member of staff operating outside of the EEA who works for us. By submitting your Personal Data to us, you agree to this transfer, storing or processing.

We have ensured that all services we use to transfer, store and/or process data, in or outside EEA, have been verified to ensure that they are compliant with the EU General Data Protection Regulation (GDPR) and any other relevant Legal Framework. Where data is transferred outside the EEA and no adequacy decision is in place, we confirm that the relevant Standard Contractual Clauses are in place to safeguard such transfers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Disclosure of Information

We will only disclose your information to third parties as detailed in this Policy and under the following circumstances:

• In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
• If FLEX TECH DESIGN or substantially all of its assets are acquired by a third party, Personal Data held by it will be one of the transferred assets.
• To our domain name registries, in order to register domains on your behalf.
• To facilitate payment processing.
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce our Terms and Conditions; or to protect the rights, property, or safety of FLEX TECH DESIGN, our customers, or others.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you can contact us at info@flextechdesign.com.

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. These websites have their own privacy policies and we do not accept any responsibility or liability for them. Please check these policies before you submit any Personal Data to these websites.

Children's Privacy

Protecting the privacy of children is particularly important. As stated in our Terms and Conditions, anyone under the age of 18 is not eligible to use our Service. We do not knowingly collect any Personal Data of anyone younger than 18 unless parental consent has been obtained prior to using our Service.

If we become aware of any Personal Data that has been gathered on a child under the age of 18 without parental consent, we will take the appropriate action to ensure it is removed from our system. If you, as a parent or guardian, discover that your child is using our Service without your consent, please notify us at info@flextechdesign.com.

Your Rights

We are committed to protecting and respecting your privacy. Under the EU General Data Protection Regulation (GDPR), as a User of our Service, you have several rights in relation to your Personal Data:

• The right of access — you have the right to know exactly what information we hold about you and how we process it.
• The right of rectification — you have the right to have your Personal Data rectified if it is incorrect or incomplete.
• The right to be forgotten — you have the right to have your Personal Data removed or deleted without a specific reason for doing so (also known as "the right to erasure").
• The right to restrict processing — you have the right to block or suppress processing of your Personal Data.
• The right to data portability — you have the right to request the Personal Data we hold about you for your own use.
• Rights relating to automated processing — we do not use AI or automated systems to make decisions about you. AI is used only as a tool to assist our team in processing information. All decisions are made by our staff.

If you wish to exercise any of your rights in accordance with the EU GDPR or any other relevant Legal Framework, please contact us using the details in the "Contact Us" section below.

If you have concerns about the way we handle your Personal Data, you can contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or raise a complaint by contacting info@flextechdesign.com and we will investigate accordingly.

Data Retention

We will continue to retain any information collected from a User of our Service as long as the User's account is deemed active. When a User's account is deemed inactive, we will remove information as set out below:

• Content of trial accounts that have been inactive (no log in) for 6 months will be automatically deleted.
• Content of closed accounts that were once subscribed to our Service, that have been inactive for 12 months, will be automatically deleted.

We may still hold personal information of inactive accounts under the following conditions:

• If required to do so in order for us to continue our duties as a domain registrar or other domain hosting services.
• If required for financial records in line with Netherlands accounting and taxation laws (for a period of at least 7 years).
• If deemed necessary due to any legal obligations or regulatory investigations that may arise.

In regards to prospective employment with FLEX TECH DESIGN, by applying for any vacancy through the various channels, you agree to the processing of your Personal Data required to complete the employment process. If you are unsuccessful in your application, we will retain your personal information for 6 months in accordance with Dutch employer law. After 6 months, we will remove your personal information unless explicitly agreed otherwise. If you wish to correct or request deletion of your information before the 6-month period has expired, please contact info@flextechdesign.com.

Contact Us

You can contact us at any time if you have any questions, comments or requests regarding this Privacy Policy:

Alternatively, you can use the Contact Us section on our site. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

Also see our Terms & Conditions and Cookie Policy.