1. Who we are
Flora ICT B.V. Is a Dutch company, based in Haarlem. Our services mainly consist of providing website traffic to our clients. Our contact information:
Flora ICT B.V.
2012 NE, Haarlem
+31 (0)23 5298683
- Personal data means any information relating to an identified or identifiable natural person;
- An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means.
The GDPR does not apply to anonymous information. Anonymous information is information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This includes processing anonymous data for statistical or research purposes.
We process your personal data in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
3. Basis for processing personal data
Processing of your personal data shall only take place on one of the following lawfull bases:
- You have given consent to the processing of your personal data for one or more specific purposes (see §4);
- Processing of your personal data is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation to which the we are subject;
- Processing is necessary in order to protect your or another person’s vital interests;
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (such as preventing fraud or direct marketing), except where such interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
4. Purpose(s) of processing your personal data
We cannot process your personal data without a purpose. We collect and process personal data for the following purposes:
- For the realization and performance of a contract between you and us;
- To offer you the requested services and information, tailored to your preference;
- To enable you to interact with our website features;
- To offer you general advertising, or based on your interests;
- To process your request, feedback or report;
- To analyze and optimize our site and services;
- To analyze the incoming and outgoing traffic (clicks) on our site;
- To conduct market research and gather information for product and service development;
- To comply with applicable laws and regulations;
- To prevent fraud or misuse of our services; and
- To cooperate with law enforcement and government agencies.
In principle, we only retain this personal data for as long as necessary for the purposes mentioned above, or to comply with statutory (storage) obligations.
5. Personal data we process
Passive personal data obtained through cookies and other technical information provided by you, your browser or your device.
Withdrawing cookie consent
- Safari - Go to preferences > privacy > Manage Website Data and select one or more websites, then click Remove or Remove All. You can also change which cookies and website data you want to accept.
- Chrome - Go to settings > click on Show advanced settings > in the 'Privacy' section click Content Settings > under 'Cookies' click All cookies and site data > click 'Remove All'. You can also clear your browsing history by doing this in the menu 'Clear Browsing History', by going to 'More' (the three dots at the top right menu) and selecting the 'Clear Browsing History' via 'More Tools' or clicking on 'History'.
- Firefox - Go to preferences > Privacy & Security and select the option Clear Data under 'Cookies and site Data' or Clear History under 'History'.
Please note that browser versions tend to change frequently, including their settings; so make sure to check out the help-pages for the fastest way to clear your cookies in your browser.
Types of cookies we use
- Persistent cookies – By using a persistent cookie we can recognize you when you visit our site. We use this for analytical purposes and tailoring the site to your preferences. Also, when you have given consent for the placement of cookies, we can remember this by means of a cookie. This way you do not have to set your preferences every time you visit our site, thus saving time and making your use of our site more pleasant. These cookies can be removed through the settings of your browser.
- Session based cookies – By using a session based cookie, we can see which parts of the site you have viewed during your visit. With that information, we can optimize and adapt the site as much as possible to the surfing behavior of our visitors. These cookies are automatically deleted when you close your browser.
Cookies we use
Analytical cookies - This website uses first party and third party analytical cookies to collect information about your visit to this site.
- First Party Analytics - We place our own analytical cookie. The information in this persistent cookie has a short retention period (max. 12 months). We consider the data we process through analytical cookies anonymous, since this information does not relate to an identified or identifiable natural person. We may disclose aggregated, anonymous information to third parties to operate our services properly.
- Third Party Analytics by Google Analytics - A third party analytical cookie is placed by Google as part of our use of the service Google Analytics. Google may transfer this information to third parties only when required by law or in cases where third parties process the information on Google's behalf. We have no influence on this. We have not allowed Google to use the information acquired through the analytical cookies for other Google services or advertisements. The information Google collects is anonymized as much as possible. We have asked them to anonymize any IP-addresses by changing the last octet of each IP. We have also made sure their analytical cookie is not persistent but session based. The information is transmitted to Google and stored on its servers in the United States. Google is part of the Privacy Shield Framework, to comply with the rules of the GDPR for companies that process personal data from residents of European Union member countries and Switzerland. We have also executed a Data Processing Agreement (or Data Processing Amendment) with Google regarding their Google Analytics service. Please note that Google offers a browser Add-on which enables you opt-out of Google Analytics' use of your (personal) data. You can find the add-on here: https://tools.google.com/dlpage/gaoptout.
- Favorites cookie - we store your favorite items in a persistent cookie after you click on that feature. This cookie only remembers the items you chose as your favorites, to show them to you whenever you visit us again. We do not collect this information for any other purpose. This cookie can be removed through the settings of your browser.
Forensiq cookie - In order to prevent fraud and abuse on our website, we use the services provided by Forensiq, which is part of Impact. Forensiq places a persistent cookie on your device and processes the following data, that might be perceived as personal data:
(i) IP Address; andThey use this personal data for fraud & abuse detection and security. We have concluded a Data Processing Agreement and Data Export Agreement with Forensiq, to ensure appropriate safeguards for processing of your personal data.
(ii) Mobile Device Identifier(s).
For an overview of cookies that are placed through our site see the table below:
|ta (referrer, trackerId, isReturningVisitor, clickCount, longTermTrackerId, longTermFirstVisit, utmSource, hasMultipleSessions)||Persistent cookie||First party analytics|
|variation||Persistent cookie||First part analytics|
|_gid||Session based cookie||Third party analytics by Google|
|_ga||Session based cookie||Third party analytics by Google|
|_gat||Session based cookie||Third party analytics by Google|
|_utma||Persistent cookie||Third party analytics by Google|
|fq-track||Persistent cookie||Third party fraud detection|
|cb-enabled||Persistent cookie||Stores cookie disclosure acceptance|
|session||Session based cookie||Stores user session|
|lp||Persistent cookie||Stores latest played items|
|fav||Persistent cookie||Stores favorized items|
B. Other technical information provided by you, your browser or your device.
When you visit and interact with our site, your browser or device automatically transmits certain technical information to our website. Such information enables us to know e.g. which browser type you use, what your browser settings are, where you originate from, what your referrer is, etc. With this information we can optimize your user experience by showing the site in your language, optimize rankings, customize the user interface etc. But mainly we use this information for analytical, statistical and research purposes, such as tracking referrals and incoming and outgoing traffic. We consider this data anonymous, since this information does not relate to an identified or identifiable natural person.
C. Active personal data obtained from your interactions with us, such as using specific website features or sending (e-mail) messages.
We may temporarily collect your personal data when you decide to provide this to us when using one of our website features. For example, you may voluntarily provide us with your e-mail address when reporting malware through our report tool or other data by sending us a (e-mail) message.
E-mails and other messages /mediums
The data processed by sending us an e-mail is limited to your e-mail-address and the contents of the message. We will process whatever personal data you included in the message. However, we will only process this data to handle your request or feedback. The period for which we store any personal data in your e-mail depends on the extent of your request and our legal obligation to retain such data to comply with laws and regulations, if any. The same goes for any other messages your send to us directly via other mediums, such as Skype or social media.
If there is an issue with content on our site, you can notify us by using our Report Tool. The information in a report is limited to technical info about your browser settings and the temporary storage of your IP-address. We will mask this IP-address as soon as possible and the browser info is limited to technical data, which we consider anonymous information, since this information does not relate to an identified or identifiable natural person. Any personal (contact) info you voluntarily provide will be temporarily processed by us, depending on the extent of your request and our legal obligation to retain such data to comply with laws and regulations, if any.
No memberships, subscriptions, accounts, profiles etc.
We do not provide memberships, subscriptions, accounts, profiles or any other means that lead to an agreement between you and us apart from your use of the website. We do not collect your personal data for such purposes. In the event that you come across a feature on this site that requests your personal data for such a purpose, for example a registration request, chat session, membership form or discussion board, you should be aware that this is a request originating from a third party, not from us. We cannot be held responsible for any use of your personal data by a third party that is not part of our services, so please be aware.
Below you will find an overview of the information that you might have chosen to actively provide to us.
|Name||Process your request||Deleted after your request is processed*|
|Contact info||Process your request||Deleted after your request is processed*|
|Other personal data you include in your message||Process your request||Deleted after your request is processed*|
|IP-address||Process your report||Masked as soon as possible|
|Browser info||Process your report||n/a, Anonymous data.|
|Country||Process your report||n/a, Anonymous data.|
|Language||Process your report||n/a, Anonymous data.|
|Date and time of report||Process your report||n/a, Anonymous data.|
|* Statutory storage obligations might require a longer storage period.|
6. What we do with your personal data
The passively collected, aggregated information collected through cookies is being used for market research, marketing purposes, to optimize our services and to optimize your experience on our Site. We also track clicks on items to improve our rankings and to analyze the traffic to and from our site. With cookies we can also personalize your experience by recognizing which language you chose as a filter or to show you the items you favorized. We consider this data anonymous, since this information does not relate to an identified or identifiable natural person.
Other personal data
Personal data you actively provided to us through your use of the site is handled to process your report, feedback or request. We do not provide third parties with your personal data, or information regarding your use of the services or site(s) accessible through our services, unless this is strictly necessary in our sole discretion, and we believe that it is reasonable to do so, including but not limited to:
- To satisfy any laws, regulations or legal requests for such information;
- To operate our services properly;
- To process your request;
- To protect our site’s visitors, the general public, and ourselves. We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed, is suspected, or if we are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process;
- To cooperate with law enforcement authorities, government agencies and/or private-party litigants seeking information about our users, to the extent required by applicable law and/or if we are legally advised to do so. Examples of such cooperation include but are not limited to, lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process.
7. What are your rights regarding our processing of your personal data?
Access, rectification, restriction and erasure
You can always send us a message to ask what personal data is stored of you or ask us to rectify, restrict or remove your personal data. Since our storage of personal data is minimal, and almost all our data is anonymized and aggregated, we cannot gaurantee that we have your data on file. As explained before, when data is anonymized, it is not considered personal data.
If you sent us an e-mail, we can retrieve that e-mail if we still have it on our mailservers. If so, we cannot rectifiy any data in that e-mail, since e-mails cannot be changed. We can delete any e-mail on request. The same goes for messages you send us through other mediums.
Please note that we might have legitimate rights to continue processing your personal data, which override your interest, rights and freedoms regarding our processing of such data. For example, we might be obligated to continue processing your personal data for the establishment, exercise or defence of legal claims or we need to retain such data for other legal purposes. We will always inform you of this decision when you contact us with a request to exercise one of your rights stated in this section.
The data we process is minimal, and mostly aggregated and anonymized. You have the right to receive the personal data concerning you in an interoperable format, so you can transmit that data to another service provider. We cannot guarantee that we have your personal data on file and/or in an interoparble format, but we will do our best to assist you in enforcing your right regarding data portability.
As explained in our paragraph on cookies, you can withdraw consent by deleting your cookies. You can contact us with your request to withdraw consent for any personal data you provided to us via certain interactions with our site, such as using a specific website feature or sending (e-mail) messages. Please note that we may have a legal obligation to retain your personal data to comply with laws and regulations.
You also have the right to lodge a complaint with a supervisory authority. We suggest that you contact the compentent supervisory authority in the country of your habitual residence, place of work or place of the alleged infringement.
8. Parental consent for children
We do not knowingly process personal data from children without prior parental consent. If your age requires prior parental consent for your behaviour on our site, according to your national law, we ask you to not engage with our site and do not submit any personal data through our services without parental consent. We encourage parents or guardians to monitor the online behaviour of their children and assist us in enforcing our policies by not allowing their children to access this site without their permission. If you learn that your child has provided us with personal data or if you have any questions regarding our data processing policies with respect to children, please contact us on: firstname.lastname@example.org.
9. Data Security
We take your privacy seriously and therefore we have taken appropriate technical and organizational measures to prevent and minimize the risk of unauthorized or unlawful processing, inappropriate use, inaccuracy, accidental loss, destruction and/or damage of (personal) data stored on our network and systems, insofar as this is reasonably possible and expected of us.
10. Third party websites
12. Any Questions