This Web site and all its contents, including but not limited to, text and graphics (collectively, "content"), are all copyrighted. The copyrights for this Web site are owned by FreeFlow. Users are permitted to view, print and/or distribute content in hard copy from this Web site provided that (1) they use such content for their own personal or internal business use and not for any purposes contrary to FreeFlow's business interests; and (2) they do not copy or use any content on any network or any other Web site for any public or business purpose; (3) they do not modify or alter any content and (4) they include FreeFlow's copyright notice on any such content, as follows:
Copyright 2001 FreeFlow. All Rights Reserved

The FreeFlow name and logo are trademarks of FreeFlow. Users may not use any trademarks belonging to FreeFlow or affiliated companies without the prior written permission of FreeFlow. Other trademarks or service marks included on FreeFlow's Web site belong to the indicated owners, who should be contacted with any questions about the use of those marks.

Except as expressly provided above, nothing contained on this Web site shall be construed to confer by implication, estoppel or otherwise, any license or right under any patent, trademark or copyright.

The information, recommendations and representations provided on FreeFlow's Web site and FreeFlow's server ("information") is presented free of charge to the user, subject to these conditions. While FreeFlow makes reasonable efforts to determine the accuracy of information, FreeFlow makes no warranties or representations, express or implied, as to the accuracy, completeness or any other aspect of the information contained on FreeFlow's Web site or FreeFlow's server. Information is supplied only upon the condition that the user will make their own determination as to the suitability of the information for their purposes prior to use. Nothing contained herein is to be construed as a recommendation to use any product or service. FreeFlow makes no commitment to update or correct any information that appears on FreeFlow's Web site, FreeFlow's server or any Web site linked hereunder. THE INFORMATION IS PRESENTED "AS IS" WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT. LIMITATION OF LIABILITY: IN NO EVENT SHALL FREEFLOW OR ANY PARTY INVOLVED IN CREATING, PRODUCING, UPDATING OR DELIVERING THIS WEB SITE, FREEFLOW'S SERVER, ANY LINKS CONTAINED THEREIN OR THE INFORMATION, BE LIABLE FOR DAMAGES OF ANY KIND OR NATURE WHATSOEVER (INCLUDING, BUT NOT LIMITED TO, DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE) RESULTING FROM THE USER'S ACCESS TO OR USE THEREOF (INCLUDING THE INABILITY TO ACCESS AND USE) OR THE DOWNLOADING OF ANY MATERIAL CONTAINED OR REFERENCED THEREIN, NOR SHALL SUCH PARTIES BE LIABLE FOR USER'S RELIANCE UPON INFORMATION OR THE PRODUCTS(S) OR SERVICE(S) TO WHICH THE INFORMATION REFERS. EVEN IF FREEFLOW OR ITS AFFILIATES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, FREEFLOW SHALL NOT BE LIABLE FOR ANY OTHER LOSSES, COSTS, OR EXPENSES OF ANY KIND WHICH MAY ARISE, DIRECTLY OR INDIRECTLY, FROM THE VIEWER'S USE OF, OR INABILITY TO USE, FREEFLOW'S WEB SITE, FREEFLOW'S SERVER OR ANY LINKS CONTAINED THEREIN, INCLUDING BUT NOT LIMITED TO, ANYTHING CAUSED BY: COMPUTER VIRUSES; SOFTWARE BUGS; HUMAN ACTION OR INACTION; ANY COMPUTER SYSTEM, PHONE LINE, HARDWARE, SOFTWARE OR PROGRAM MALFUNCTIONS OR ANY OTHER ERRORS, FAILURE OR DELAYS IN COMPUTER TRANSMISSION OR NETWORK CONNECTIONS.

Effective: 25th May 2018

This Privacy Policy describes how FreeFlow as a data controller collect, use and disclose information, and what choices you have with respect to this.

When we refer to "FreeFlow" we mean the business entity that acts as the controller or processor of your information. The data controller is Web Component Trading t/a FreeFlow.

How to contact us

Please feel free to contact us if you have any questions about this Privacy Policy or if you are seeking to exercise any of your statutory rights.

Email: privacy@freeflow.com

What and who does this Privacy Policy apply to?

This Privacy Policy applies to both individuals and companies who are our registered members, customers, purchasers and delegates of our online content, any other registered-user content we provide, along with any other interactions (e.g. customer enquiries) you may have with FreeFlow.

Why we process your data

We may process your data for a number of different purposes:

To keep you up to date with the latest, relevant content we have posted.
To administer any membership you have with us.
To administer any product you have bought from us.
To keep you up to date with and invite you to any of our latest, relevant auctions and/or events we are providing.
To collect your feedback and seek your insight through online survey invitations.
To give you access to content and auctions/ events provided by our approved third party partners.


Our lawful basis for processing your data

It's in FreeFlow's legitimate business interest to keep its customers, members and contacts informed of our latest content, products and services and to manage and administer their memberships and purchases.

We process customer and client data and use direct marketing as part of this legitimate interest. It's necessary for us to use a variety of direct marketing channels and messages to ensure our contacts are kept informed, and wherever possible we make sure the messages we send are targeted and relevant. Any direct marketing we undertake complies with e-privacy rules on consent so you can opt out at any time by following the unsubscribe instruction in our marketing communications (See "Right to Object" below).

We will keep your data safely and securely, typically for the period of your relationship with us plus a period of six years for any audit, legal or evidentiary purposes that may arise. If you'd like more information about how we store your data, please contact us directly.

Types of data we collect

When you register on our website we'll collect the kind of standard, non-sensitive information you would expect an online business to business supplier of product and services to request. For example, information we may collect directly from you may include:

At registration:

Your name;
Your company name;
Your email address;
Your Website domain;
Your postal address;
VAT / Tax ID Number;
Your phone number;
Your fax number;
A FreeFlow user ID;
A password (for FreeFlow website access);
Confirmation that you have agreed to the terms and conditions of the website;
Your preferences in relation to registering on our non-instant access marketplaces;
Your category preference requirements;
Your stock location preferences; and
Email contact preferences


During and after auction completion:

Bidding data associated with your Freeflow user ID


When purchasing from our platform:

If your bids placed on our action site are successful, you will need to provide us with billing and payment information which may include:
Full name;
Company name;
VAT / Tax ID number (corresponding certificates for verification purposes may be requested);
Billing/shipping address;
Shipping method / carrier details / carrier account number; and
Credit card details if paying by credit card


(If you do not provide us with the information requested and the corresponding payment, you may be unable to complete your order and access to our websites may be restricted and/or removed.)

After the completion of your order:

We will collect and store data on the transactions and purchases you make with us;
Proof of delivery documents and signed delivery statements; and
In the case where a credit note is issued we may require banking or credit card details in order to process a refund


Website Analytics / Cookies

FreeFlow uses third party tracking technologies in our websites that help us collect other information about our customers' and users' preferences.

Why does Freeflow use cookies and similar technologies?

Analytics and Research: To help us better understand how people use our Services, we work with a number of analytics partners, including Google Analytics; and to help us improve and understand how people use our services.

These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our websites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties. To find out more about how Google uses data when you visit a website that uses Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

Third party data

FreeFlow may receive data about organisations, industries, website visitors, marketing campaigns and other matters related to our business from our partners, affiliates or others, that we use to make our own information better or more useful. This data may be combined with other information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

Additional information provided to FreeFlow

We may receive and store other information when submitted to our websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with FreeFlow.



Recipients of the data we collect

In some cases we will share the data we collect from you with trusted third party content providers to support our business. Recipients of your data will be bound to use the data only for the contracted purposes which will be consistent with this Privacy Policy.

Our expectations of our content partners

Any personal data we share with our content partners is shared only on the basis that the data will be used by the partner under a lawful basis of legitimate interest and according to the requirements of the GDPR. We specify this in our contracts with all our content partners.

Data processing partners

FreeFlow may provide your personal information to any affiliated companies or other trusted businesses or persons, acting under a confidentiality agreement, for the purpose of processing personal information on behalf of FreeFlow. These parties are required to process such information based on instructions from FreeFlow and in accordance with this Policy. They do not have any independent right to share this information.

FreeFlow may transfer your data if FreeFlow is acquired by or merged with another company. FreeFlow will provide notice before this occurs and will email notification of the new Policy if necessary.

Credit and company background checking

FreeFlow may share your personal information with a credit and company background checking company. These third parties do not retain, share, or store any personally identifiable information except to provide these services and are bound by strict confidentiality agreements which limit their use of such information.

Your rights over the personal data we hold

You can reasonably request access to the personal data we hold on you, at any time, and we will respond to that request within one month of your request at the latest.

You can request inaccurate or incomplete personal data held on you to be rectified or completed or for your personal data to be suppressed or erased, and we will respond within one month of your request at the latest.

We will supply any data you request in an appropriate file format.

Your right to object

You have the right to opt out of our direct marketing at any point, and we will deal with your request right away. You can unsubscribe from our emails automatically by clicking on the unsubscribe link. Alternatively, you can amend your email preferences via our preference centre by logging into your account on our website.

To opt out of our direct mail or telephone marketing please call us on +353 (0)66 718 5400 or email info@FreeFlow.com

Data security

To secure your personal information, Freeflow utilise a secure high performance cloud environment to host our websites. Our hosting partner has adapted a multi-layer security methodology. Access to your data is password protected. It is your responsibility to keep your password confidential and not to share this information with anyone. Whilst FreeFlow will ensure all data is held securely, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.

Changes to this Privacy Policy

Freeflow may update this Privacy Policy to reflect changes to our privacy practices. If you are a Freeflow customer and we make any material changes that affect the way we treat information that we have previously collected from you, we will notify you by email (to your registered email address). We encourage you to periodically review this Policy for the latest information on our privacy practices.

Data Transfers outside the EEA

From time to time, Freeflow may transfer Personal Data outside the EEA. For example, our cloud environment is such that your data may be stored within or outside the EEA at any time. Such transfers will be subject to appropriate safeguards in accordance with applicable Data Protection Law (for example through the use of EU-approved Model Contract Clauses) and in accordance with this Privacy Policy.

Contact / Dispute Resolution

If you have any questions or concerns regarding the way in which your personal data is being processed or you want to exercise your rights above, please reach out to Freeflow using the contact information below:

Freeflow's data protection team can be contacted at:

Email: privacy@freeflow.com

Mailing Address:
Data Protection Team
Freeflow
Innovation Works 1
Kerry Technology Park
Tralee
County Kerry
Ireland

If you remain dissatisfied, you have the right to contact the data protection authority in your jurisdiction. We do ask that you please attempt to resolve any issues with us first, although you have a right to contact the data protection authority at any time. This policy was last modified on the 25/05/2018.

Although this Web site provides links to third party sites, FreeFlow is not responsible for the content of any such site. Links are provided as a convenience to viewers, and they shall not be interpreted as an endorsement, sponsorship or association of any kind.

A user may display on their Web site a hyperlink to FreeFlow's Web site for purposes of enabling other users of their site to link to FreeFlow's Web site. The hyperlink shall at all times be displayed in its entirety and not in association with any text, graphics, logos, trademarks or trade names (except those of FreeFlow or its affiliate companies) or any information which is misleading or otherwise misrepresents the nature of FreeFlow's Web site with which the hyperlink will connect or which is in any way derogatory, of negative connotation or otherwise negatively impacts on the good will of FreeFlow in the hyperlink or FreeFlow's Web site. Use of the hyperlink shall require the user to link directly to the home page of FreeFlow's Web site via either the same browser window in which their Web site operates or via a separate browser window. Under no circumstances shall the Web site, in whole or in part, be framed, modified in any manner or for any purpose or otherwise interfered with in its normal operation and appearance. The hyperlink shall only be displayed as set forth in this paragraph, and shall not be modified in any way, including but not limited to, enabling the hyperlink to grant access to other than the home page of FreeFlow's Web site. The only rights granted to the hyperlink are as set forth in this paragraph. In the event FreeFlow provides the user with written notice directing them to remove the hyperlink from their Web site, the user agrees to do so immediately upon receipt of such notice.

These terms and all claims related to Freeflow's Web site shall be interpreted and reviewed under the laws of the Republic of Ireland. (without regard to the conflicts of laws rules of that or any other jurisdiction). Any claim arising in connection with these terms or FreeFlow's Web site must be commenced within one (1) year after such claim arises.

FreeFlow reserves the right to modify these Terms of Use at any time, without prior notice. The users continued access to or use of FreeFlow's Web site shall be deemed to be their acceptance of these Terms of Use, as changed. For this reason, FreeFlow encourage the user to review these Terms of Use whenever they visit FreeFlow's Web site.