Flat Tummy Co Mobile App Privacy Policy

Last Updated: September 20th 2019.

Flat Tummy Co provides this privacy policy to describe how we collect, use, and share information on our websites, flattummyco.com and flattummyapp.com (“websites”) and our mobile app (the “app”) (collectively the “Properties”).  “Flat Tummy Co” (referred to as “we”, “us”, “our” or “Flat Tummy Co”) in this policy primarily refers to NomadChoice Pty Ltd (trading as Flat Tummy Co), and, where appropriate, to the parent company Synergy CHC. Flat Tummy Co is the “data controller” of all information that is collected and used about Flat Tummy Co customers for the purposes of privacy and data protection laws, principles and regulations which may apply in your country. 

What Information We Collect

We collect information from you (either directly or indirectly, through our third party partners or providers) in a number of ways.

Specifically, we collect the following categories of information:

  • Name, address, e-mail address, telephone number, credit/debit card or other payment details;
  • Information such as place and date of birth, age, and gender;
  • Dietary preferences;
  • Information you provide about yourself and any preferences in your account;
  • Information about your purchases of products and services from us or our partners;
  • Information about your use of our Properties;
  • Photographs uploaded by you;
  • Communications with us or directed to us via letters, emails, chat services, calls, and social media; and
  • Location, including real-time geographic location, if enabled on your device or computer.

Cookies and Site Tracking

We collect information from other sources, such as through the use of “cookies,” log files, gifs, and pixels.  We also gather information from both online and offline data providers. This information includes internet browsing behavior, demographic data or interest-based data.

A cookie is a small text file stored on your computer that contains information that helps the website to identify and track the visitor.

Two types of cookies are used: "Session Cookies", and cookies that are saved permanently on your computer. The first type of cookie commonly used is "Session Cookies". During the time you visit the website, our web server assigns your browser a unique identifier string so as not to confuse you with other visitors. A "Session Cookie" is never stored permanently on your computer and disappears when you close your browser. To use some of our websites without troubles you need to have cookies enabled.

The second type of cookie saves a file permanently on your computer. This type of cookie is used to track how visitors move around on the website. This is only used to offer visitors better services and support. The text files can be deleted. On this website we use this type of cookie to keep track of your shopping cart and to keep statistics of our visitors.

To opt out of cookies, you can alter the settings on your internet browser to accept or reject a website from using cookies. This can affect functionality of the website. Some third parties use cookies and other technologies. We recommend that you read their privacy policies or policies relating to the use of cookies and technology.

When you browse our store, we automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.

We also collect information: regarding device IDs or identifiers, connection information, device software and other device information, statistics of page views, ad data, referral URLs and IP data; to determine your general geographic location, so that we can provide location-specific content to you; Internet Service Provider information; to assist in responding to complaints and queries; to investigate any possible breach of our terms or conditions including fraud or illegal activities with the use of your information; and with your permission, we will send you emails about our store, new products, and other updates.

When we ask for your information for a secondary purpose such as marketing and you are an individual in the European Economic Area (EEA), we ask for your consent, when required by law. You can withdraw your consent for us to contact you for the continued collection, use or disclosure of your information, at any time, by contacting us or by using the unsubscribe link within any of our emails.

We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of websites.

What Do We Use Your Information For, Why, and For How Long

Your information, including information that has been merged from different sources, is used for the following purposes:

  • Provide products and services you request: we use the information you give us to perform the services for which you have signed up;
  • Credit or other payment card verification/screening; and payment information for accounting, billing and audit purposes and to detect or prevent any fraudulent activities;
  • Administrative or legal purposes: we use your information for statistical and marketing analysis, systems monitoring and testing, customer surveys, maintenance and development, to help improve our Properties, or in order to deal with a dispute or claim;
  • Security, health, administrative, crime prevention/detection: we pass your information to government authorities or enforcement bodies for compliance with legal requirements.  We also use your information to protect the security or integrity of the Properties;
  • Customer service communications: we use your information to manage our relationship with you as our customer, to improve our services and enhance your experience with us and to respond to your inquires;
  • Provide tailored services: we use your information to provide information we believe is of interest to you, prior to, during, and after your interactions with us, and to personalize the services we offer to you, such as special offers. Our trusted partners as well as other companies use your information to send you information including marketing offers and other promotional materials.

    We will process your information where we have a legal basis to do so, which will depend on the reasons for which we have collected and need to use your information. We process your information for one or more of the following:

    • To comply with a legal obligation, including to fulfill a contract (e.g., to provide goods and services you request);
    • Where you have consented to our using your information (e.g., for marketing related uses);
    • To protect your vital interests or those of another person (e.g., in case of a medical emergency);
    • If it is in our legitimate interests to do so (e.g., for administrative purposes).

      We will retain your information for the time necessary to fulfill the purpose for which it is being processed. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the information, the purposes for which we process it, and whether we can achieve those purposes through other means. We also consider the periods for which we might need to retain information in order to meet our legal obligations, or to deal with complaints and queries, and to protect our legal rights in the event of a claim being made.

      When we no longer need your information, we delete or destroy it. We will also consider if and how we can minimize over time the information that we use, and if we can anonymize your information so that it can no longer be associated with you or identify you, in which case we will use that information without further notice to you.

      Sharing Your Information

      We also share your information with our affiliates as well as the following third parties for the purpose described in this privacy policy:

      • Government authorities, law enforcement bodies and regulators to respond to legal process (such as a search warrant, subpoena, or court order) or for compliance with legal requirements;
      • Other companies, contractors or agents to provide services to you including delivery, marketing, support ticket providers, or marketing platform providers, communications, legal services, debt collection, administration services, customer services, information technology providers, credit card or other payment methods to conduct transactions;
      • The host of our online store, which provides us with the online e-commerce platform that allows us to sell our products and services to you;
      • Credit and debit card companies which facilitate your payments to us, and for anti-fraud screening, which requires formation about your method of payment to process payment or ensure the security of your payment transaction. These include third party payment gateway providers;
      • Legal and other professional advisers, law courts and law enforcement bodies in countries in which we operate, or as otherwise needed to enforce our legal rights or the rights of any third party;
      • Our marketing partners, advertisers, or other third parties to contact you with their own offers;
      • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding; and
      • With your express consent or as otherwise disclosed at the time of data collection or sharing.

      We share information that has been anonymized or aggregated without limitation.

      Additionally, we share information with our trusted third party ancillary partners (identified on our website), who offer products and services on or through our website. If you choose to purchase products or services offered on our websites by third parties, you will be a customer of both Flat Tummy Co and these third parties, and we and our partners will collect and share information about you, such as your contact details and your billing information. We are not responsible for third parties’ use of your information where such use is permitted for their own purposes. You should consult their privacy policies for further information.

      Digital Advertising & Analytics

      We may partner with third-party ad networks and other ad serving providers (“Advertising Providers”) that serve ads on our behalf and others’ on non-affiliated platforms.  Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Properties and other sites or apps over time, including information about relationships among different browsers and devices.  This type of advertising is known as interest-based advertising.

      Flat Tummy Co adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity.  You can visit www.aboutads.info or www.youradchoices.com/AppChoices to learn more about interest-based advertising and how to opt out of this advertising by companies participating in the DAA self-regulatory program.  If you delete your cookies, reset your device advertising identifier, or use a different browser or mobile device, you will need to renew your opt-out choice.  You may also be able to limit data collection for advertising purposes using tools available on your device. Note that electing to opt out will not stop advertising from appearing in your browser.  It may make the ads you see less relevant to your interests.  Even if you opt out, Advertising Providers may continue to collect data for other purposes, including analytics and other operational purposes.

      We may also work with third parties that collect data about your use of the Properties and other sites or apps over time for non-advertising purposes.  Flat Tummy Co uses Google Analytics and other third-party services to improve the performance of the Properties and for analytics and marketing purposes.  For more information about how Google Analytics collects and uses data when you use our Properties, visit https://policies.google.com/technologies/partner-sites, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout/.

      International Transfer

      Flat Tummy Co operates businesses in multiple jurisdictions, some of which are not located in the European Union or European Economic Area (EEA). Please be aware that countries outside the EEA do not always have data protection laws that are as protective as those in your location. If you are located outside of the United States, please be advised that we process and store your information in the United States. 

      Data Protection Officer

      We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy (see contact details in “Contact Us” section below). You have the right to lodge a complaint at any time to a supervisory authority. The data protection supervisory authority for you depends upon the country or geographical area in which you are located.

      Your Data Protection Rights

      Under certain circumstances, by law you have the right to:

      • Request information about whether we hold information about you, and, if so, what that information is and why we are holding/using it.
      • Request access to your information (commonly known as a "data subject access request"). This enables you to receive a copy of the information we hold about you and to check that we are lawfully processing it.
      • Request correction of the information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
      • Request erasure of your information. This enables you to ask us to delete or remove information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your information where you have exercised your right to object to processing.
      • Object to processing of your information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your information for direct marketing purposes.
      • Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your information or profiling of you.
      • Request the restriction of processing of your information. This enables you to ask us to suspend the processing of information about you, for example if you want us to establish its accuracy or the reason for processing it.
      • Request transfer of your information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your information from us in an electronically useable format and to be able to transfer your information to another party in an electronically useable format.
      • Withdraw consent. In the limited circumstances where you have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes to which you originally agreed, unless we have another proper and legitimate basis for doing so.

      If you want to exercise any of these rights, then please contact our DPO by email at hello@flattummyapp.com.

      You will not have to pay a fee to access your information (or to exercise any of the other rights). However, we will charge a reasonable fee if your request for access is clearly completely unfounded or excessive. Alternatively, we will refuse to comply with the request in such circumstances.

      Where necessary, we will request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that information is not disclosed to any person who has no right to receive it.

      Third-Party Links

      You are able to access third party social media services through our Properties or before coming to our Properties. When you are registered with your social media account, we will obtain the information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our Properties. We also use social media plugins on our Properties. As a result your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of those third-party social media providers to find out more about these practices.

      Your California Privacy Rights

      We may make your personal information available to third parties for their marketing purposes as described in this Privacy Policy.  We maintain the policy of only disclosing such personal information to third parties with your affirmative consent.  If, however, you no longer wish to share your personal information in this way, please send your request in writing to: 865 Spring Street, Westbrook, Maine, 04092, USA.

      Security of Your Information

      We follow security procedures in the storage and disclosure of your information, and to protect it against accidental loss, destruction or damage.

      Your Choices

      If you decide that you do not want to receive marketing communications from us or our third party marketing partners you may opt-out of receiving them at any time by emailing us at getflat@flattummyco.com to unsubscribe.

      For choices with respect to third-party interest-based advertising activities, please see the “Digital Advertising & Analytics” section above.

      Changes to Privacy Policy

      Our privacy policy may change from time to time. Any changes will be communicated to you by way of an e-mail or a notice on our Properties.

      Contact Us

      If you have questions, comments, or concerns about this privacy notice, please contact us, in our role as data controller, at:

      Attn: The Manager
      Flat Tummy Co
      865 Spring Street, Westbrook
      Maine, 04092
      United States of America
      management@flattummyco.com