Privacy Policy
Wellcosan Inc., operating under the Flowell brand name (“Flowell,” “we,” “our,” or “us”), manages the website https://www.flowell.com along with associated sites and mobile applications (hereinafter collectively referred to as the “Sites”) and provides a range of services to our users, including products that deliver cooling, heating, and compression to promote improved movement for every user (collectively referred to as the “Services”).
This Privacy Policy explains our approach to gathering, utilizing, and disclosing data – including your personal information – when you access our Services, as well as the choices available to you regarding that data.
Our Privacy Policy is intended to inform you about how we collect, handle, protect, and share the information that we obtain from you. It also clarifies your rights concerning privacy and provides guidance on managing your personal information preferences. Please note that this Privacy Policy does not apply to third parties, such as partners, business service providers, or advertisers, even if these entities’ services are branded or offered on Flowell’s behalf. Information gathered by these parties, such as from external websites accessed through links on our Sites, is governed by those entities’ respective privacy policies.
1. Definitions
- Personal Information (also “Personal Data”): This refers to information relating to an individual or household that identifies, describes, is reasonably linked to, or could be used to identify them (alone or in conjunction with other data we hold or are likely to acquire). This also includes associated data like Usage Data (defined below), location, preferences, or interests, insofar as it can be used to identify you or your household.
- Usage Data: Usage Data encompasses information collected automatically, whether it is generated through the use of our Sites or originates from our Sites’ infrastructure (e.g., your IP address or the duration of your page visit).
- Cookies: Cookies are small data files stored on your device (such as a computer or mobile device).
- Data Controller: The individual or legal entity that (alone or with others) determines the purposes and means of processing personal information. In this Privacy Policy, Flowell acts as the Data Controller of your Personal Information.
- Data Processors: Individuals or legal entities that handle data processing on behalf of the Data Controller. To enhance data processing, we may employ the services of various partners.
- User (or “Data Subject”): Any individual using our Services who is the subject of Personal Information that we collect or process.
- Services: Our Services encompass the website http://www.flowell.com, mobile applications operated by Flowell, and our products designed to enhance movement through cooling, heating, and compression functionalities.
2. Collection and Use of Information
We use your data to fulfill the Services you request and to enhance the quality of our offerings. By accessing our Services, you consent to the collection and use of information as outlined in this Privacy Policy and our Terms of Service.
- The Flowell Connect App allows users to control Flowell Mobile devices via Bluetooth, offering an enhanced, personalized experience. With the app, you can:
- Access preset massage sequences optimized for regeneration.
- Create, save, and revisit custom massage sequences anytime.
- Adjust massage pressure and duration according to your preferences.
- Log in and add optional personal information such as birth date, gender, country, city, sport, activity status, weight, height, and leg length.
- Log out or delete your account and associated data at any time.
To support these functions, Flowell collects certain data through the app:
- Account Information: If you register, we collect your name, email, and login details.
- Device Connection and Settings: Information about the Bluetooth connection, such as device ID, connection logs, and operational settings.
- Massage Preferences: Data on selected massage sequences, pressure, duration, and custom settings.
- Optional Personal Data: If you choose to provide it, we may collect details like age, gender, location, sport/activity level, height, weight, and leg length, which personalize app features. This information remains stored on your device and is only transmitted to our servers when needed for service.
Flowell uses this data solely to operate and improve app functionality, ensuring device performance and user satisfaction. Data remains confidential and is shared with third parties only as necessary for service or as required by law.
- Types of Information Collected
We gather various types of data for different purposes to deliver and improve our Services for you.
- Personal Information: When using our Services, we may request or obtain certain personally identifiable details that enable us to contact or recognize you (“Personal Information,” as defined above). This includes, but is not limited to, your name, address, email, phone number, payment details, transaction and service history, gender, age group, and employment or military service information.
- Usage Data: We may also collect details on how you access and interact with our Services (“Usage Data”). This can include information such as your device’s Internet Protocol address (e.g., IP address), browser type, browser version, specific pages of our Services you visit, the date and time of your visit, time spent on those pages, unique device identifiers, and other diagnostic data.
If you access our Services from a mobile device, this Usage Data may further include details like the type of device, unique device ID, device IP address, operating system, browser type, unique device identifiers, and other diagnostic information.
- Generic Information: Generic information is data that does not directly reveal the identity of a Flowell user or website visitor. This may include aggregated Usage Data and metrics such as total visitor counts, pages viewed, and general usage trends across the Sites. This may also encompass data regarding your device. At times, certain Generic Information or combinations of data types may meet the criteria for Personal Information and will then be treated accordingly.
- Tracking & Cookie Data: We use cookies and similar tracking technologies to monitor activity on our Sites. Cookies are small data files that may include a unique anonymous identifier. These cookies are sent to your browser from a website and saved on your device. Other tracking technologies, like beacons, tags, and scripts, also help us gather and analyze data to enhance our Services.
Some cookies we employ are “strictly necessary” for the functionality of our Sites, while others improve functionality but aren’t essential. Certain cookies enhance the performance of our Sites (e.g., for analytical data), while others support targeted services (e.g., ads that may be relevant to you).
Examples of Cookies and other technologies we may use include:
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Other Technologies
We also collect data using various technologies to enhance our Sites and Services. For instance, we may gather Usage Data and other information related to your device used to access our Site, such as the operating system, browser type, domain, system settings, language, country, and time zone where your device is located. We may also log the IP address of the device used to connect to the internet.
Managing Your Cookie Choices
You can set your browser to block or control the cookies your browser or device accepts via the browser or device settings. Additionally, you can choose to modify your settings and remove any cookies that have already been stored on your device at any time. Please refer to the instructions provided by your browser or device’s manufacturer for guidance on limiting or deleting cookies or other tracking technologies. Note that limiting or disabling the use of cookies and similar technologies may impact or restrict your ability to conduct certain transactions on, utilize particular features of, and access specific content on our Site.
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Personal Information Collected over the last 12 months
We have collected the types of Personal Information described above , including Usage Data, Generic information, and Cookie data when they qualify as Personal Information within the last 12 months.
3. How We Gather Your Information
Flowell collects information about you in several ways: information that you choose to provide directly, data gathered from your interactions with our Services – including our Sites – and information we acquire from third parties.
a. Information You Choose to Provide
We gather details that you decide to share with us. At times, we may request certain information – including Personal Information – to enable specific functionalities on our Sites, fulfill your requests, or provide particular Services. For example, you may need to supply your name, email address, or other contact details when reaching out with inquiries or comments. If you set up an account with us, we may also require a username and password to allow you access to our customer portal. Additionally, to purchase a product, take advantage of promotions, or utilize other parts of our Services, you may need to provide certain Personal Information.
b. Information Collected Through Your Use of Our Services
As noted, we also gather information through your interactions with our Services, including Usage Data. For example, as you use our Sites, we may record data about the device you use to access, log in to, and navigate our Sites. We also collect aggregated data on how frequently certain sections of our Sites or other Services are accessed.
In addition, we may collect information via cookies, pixel tags, and similar technologies as previously outlined.
c. Information Acquired from External Sources
We may also receive limited data about you from our business partners, who assist in providing our Services. For instance, if you make a purchase, our payment processor may share order-related information with us to complete your transaction. We may also work with business partners who help us monitor and analyze how our Sites are used. Examples include:
- Google Analytics: This web analytics tool provided by Google tracks and reports on site traffic. Google uses collected data to analyze and monitor usage patterns on our Sites, which may be shared with other Google services. As part of its operations, Google Analytics may collect information such as your IP address, which under certain conditions may qualify as Personal Information.
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Google may use the collected data to tailor ads within its advertising network. To prevent Google Analytics from using your activity on our Services, you can install the Google Analytics opt-out browser add-on. This tool stops the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sending information to Google Analytics about your visit.
For more information on Google’s privacy practices, please refer to their Privacy Policy: Google Privacy & Terms.
Meta Analytics: Meta Analytics is an analytics service provided by Meta, tracking engagement with our Facebook and Instagram content and pages. Meta may collect details you provide when creating a Facebook or Instagram account, generating or sharing content, communicating with others, or granting Meta access to your contacts. It also collects usage information, such as session frequency, timing, and duration, as well as information about the device you use to access these platforms. Meta Analytics may also collect your IP address, GPS data, and other information about you, which could qualify as Personal Information under certain situations.
Meta may use this data to refine and personalize ads across its advertising network. You can manage or delete data collected by Facebook and Instagram through the “Settings” menu in your account(s).
4. Purpose of Collecting, Processing, and Using Your Information
Business and Commercial Reasons for Collection
Flowell collects, processes (or delegates processing to our business partners), and uses your information to provide and enhance the Services we offer. We gather, process, and utilize your information for several purposes, which include:
- To fulfill a contract with you or deliver the Services you request from Flowell (e.g., collecting and processing your information is necessary when you make a purchase to ensure we can fulfill your order).
- Where you have provided your consent or authorization (for example, if you have signed up for our newsletter and shared your email address to receive updates).
- To keep you informed via newsletters, special promotions, marketing materials, and general updates on other products, services, and events we offer that are similar to those you have previously purchased or expressed interest in, or that we believe may interest you. You may choose to opt out of receiving any or all of these communications by contacting us using the details provided below.
- Elements of the Website, such as displayed content or emails sent to you regarding your Website usage, may include advertisements tailored to you based on demographic information, interests, preferences, and Website usage patterns.
- To support the functionality of our Websites and other Services we provide to you, which may involve:
- Operating, maintaining, and enhancing our Services, including our Websites;
- Identifying and responding to security issues;
- Detecting, preventing, and addressing technical problems;
- Guarding against malicious, deceptive, fraudulent, or unlawful activities; and
- Assisting law enforcement in prosecuting individuals responsible for malicious, deceptive, fraudulent, or illegal acts.
- Collection and/or processing may also serve another Flowell business or commercial purpose. For instance, we may use your information to enhance fraud prevention efforts, improve network security, support the physical security of our customers, and report suspected criminal activity to law enforcement. Additionally, we may use your information in connection with marketing events and promotions we think could be of interest to you.
Purpose of Data Collection in the Flowell Connect App
The data collected through the Flowell Connect App serves several key purposes, aimed at providing a seamless and tailored experience with Flowell Mobile devices:
- Device Functionality and Control: To establish a reliable Bluetooth connection with Flowell Mobile devices, enabling users to control device features directly through the app.
- Customization and Personalization: To allow users to create, save, and access custom massage sequences, as well as to adjust pressure and duration based on individual preferences, for an optimized and flexible experience.
- Enhanced User Experience and Future Improvements: Optional personal information, such as age, gender, and sport activity level, helps Flowell understand user preferences and optimize future product features and updates. This information remains on the device and is not processed beyond app functionality unless required for service improvement.
By using the Flowell Connect App, users consent to data collection solely for these specified purposes, ensuring an efficient, customized, and effective experience while keeping data processing strictly limited to these functions.
To comply with applicable laws or respond to legitimate requests by law enforcement, courts, or other public authorities, or in relation to an applicable legal requirement.
5. How We Disclose or Share Your Information
Flowell does not sell your information to any third party. However, Flowell may disclose your information in a number of ways in order to provide our Services to you. For instance, we may share your information with our business facilitation partners that help us provide our Website and other Services to you, such as our web hosting and cloud storage providers. We may also share or disclose your information to those business facilitation partners that assist us with completing your orders, such as providing your credit card number to a third party payment processor when you make a purchase with us.
We may also provide your Personal Information to business facilitation partners or contractors to perform functions on our behalf including companies or individuals hired to publish and operate the Website, communicate news, deliver our promotional materials via e-mail and direct mail, promote our social media presence and activities, develop, enhance, market, or provide any of our products, and assist us with sending communications and performing other marketing and support functions.
We may also disclose or share your information for the following purposes:
- To comply with a legal obligation.
- To protect and defend Flowell´s rights or property.
- To prevent or investigate possible wrongdoing in connection with the Services.
- To protect the personal safety of users of the Services or the public.
- To protect against legal liability.
- When there is a good faith belief that such action is necessary to investigate or protect against harmful activities to our customers, associates, or property (including the Websites), or to others (including Hyperice itself). This may include disclosures to law enforcement to investigate potential criminal activity or other civil violations.
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Categories of Third Parties that Receive Personal Information from Flowell
We share or otherwise disclose individuals’ Personal Information to the following categories of third parties:
- Fulfillment Service Providers and Business Facilitation Partners: we employ fulfillment service providers and business facilitation partners, companies, individuals, and agents to facilitate and help us provide our Services to you. Such partners perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For more information on the analytic partners we use to better understand how you and other visitors use our site, please go to the “Information we obtain from Other Sources” above.
- Data Sharing: The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
- We may share your Personal Information with third-party service providers categorized by function to better serve your needs. These providers include, but are not limited to, marketing partners, analytics providers (such as Google Analytics and Meta), payment processors, web hosting services, and customer support vendors. Each third-party entity is restricted from using your data for purposes other than performing services on our behalf and is required to maintain confidentiality as outlined in our agreements with them.
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Categories of Personal Information Disclosed
Flowell has disclosed the following categories of Personal Information in the last 12 months for a business or commercial purpose:
- Customer names. This information may be shared with our Fulfillment Service Providers, Business Facilitation Partners, and other Flowell Entities.
- Customer addresses. This information may be shared with our Fulfillment Service Providers, Business Facilitation Partners, and other Flowell Entities.
- Payment card or other billing information. This information may be shared with our Fulfillment Service Providers, Business Facilitation Partners, and other Flowell Entities.
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Categories of Personal Information Disclosed in the last 12 months
Flowell has disclosed the Personal Information as described above within the last 12 months.
d. Categories of Personal Information Sold
Flowell does not sell individuals’ information without their permission. Flowell has not sold Personal Information to third parties in the past 12 months.
Please note that a “sale” of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction. If such transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation.
6. Data Storage and Retention
Flowell retains your Personal Information only for the period necessary to achieve the purposes outlined in this Privacy Policy. This includes keeping your information to deliver our Services, meet legal and regulatory obligations (such as data retention requirements under applicable law), resolve disputes, and enforce our policies and contractual agreements.
We aim to retain your Personal Information only for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. In general, account-related information is kept for as long as your account remains active, while transaction data is stored for tax and legal compliance. Generic Usage Data for internal analytics is typically retained for a shorter duration unless needed for security or service improvement. These estimated retention periods may vary based on specific circumstances or legal obligations.
We also retain Usage Data for purposes of internal analysis. This type of data is usually kept for a shorter time unless it is required to enhance the security or improve the functionality of our Services, or when applicable laws mandate a longer retention period.
For residents of California, we will retain your data and, if you request, delete it, in compliance with applicable legal requirements.
7. Data Transfers
Your information, including Personal Information, may be transferred to and stored on servers located outside your state, province, country, or other legal jurisdiction where data protection standards may differ from those in your area.
If you reside outside the United States and decide to share information with us, please be aware that your data, including Personal Information, will be transferred to and processed in the United States.
8. Data Security
We prioritize the protection of your data; however, please be aware that no method of Internet transmission or electronic storage is completely secure. While we implement commercially reasonable measures to safeguard your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, and destruction, we cannot provide an absolute guarantee of its security. By using our Sites and Services, you acknowledge the limitations of Internet security and accept that the protection, integrity, and privacy of information exchanged between you and Flowell, or between you and related entities, cannot be fully assured. We cannot guarantee or warrant the security of any information you transmit to us or that we store, and you proceed at your own risk.
Data Security and Bluetooth Connection in the Flowell Connect App
The Flowell Connect App prioritizes data security through:
- End-to-End Encryption: All data shared between the app and Flowell Mobile devices via Bluetooth is encrypted, safeguarding information during each session.
- Secure Data Storage: User-provided information is stored locally within the app, and data required for account management or personalized settings is only transmitted to Flowell’s servers as necessary and is subject to encryption.
Your Rights and Managing Your Data
Users of the Flowell Connect App have control over their personal data and can manage it as follows:
- Access, Update, and Delete Personal Information: Users can update personal information or delete their account directly through the app settings. Deleting an account will permanently erase all data stored within the app.
- Opt-Out of Optional Data Collection: Users may choose not to provide optional personal data (e.g., height, weight), which will not impact the basic functionality of the app.
For further assistance with these rights or other questions about data management, users can reach Flowell support via support@flowell.com. Flowell adheres to data protection laws to uphold user rights to access, correct, and delete data.
For non-U.S. users, please note that data stored on servers is processed in the United States, where data protection laws may vary. Flowell uses secure transfer mechanisms to maintain compliance with applicable data protection standards and regulatory requirements.
9. California Privacy Rights for Direct Marketing Information
If you reside in California, you have the right to request details about how we share certain types of personal information with third parties for their direct marketing purposes, in addition to the other rights listed above.
In accordance with California law, you may send us a request to obtain:
- The categories of information shared with third parties for their direct marketing purposes during the previous calendar year;
- The names and addresses of the third parties who received that information; and
- Descriptions or examples of the products or services promoted, where the third party’s business nature is unclear from its name.
To submit a request, please provide sufficient details to verify your California residency and confirm that this applies to you, along with a valid California mailing address for our response. Requests should be submitted in writing to the postal address provided below. Please include "California Privacy Rights Request" at the beginning of your request, along with your full name, street address, city, state, and ZIP code. Note that we are required to respond to only one such request per customer each year and will only respond to requests made through the designated postal address.
Please be aware that any response may be provided in a standardized format rather than individually tailored.
10. Links to External Sites
This Privacy Policy aims to inform you about how we collect, use, protect, and disclose information we gather about you. However, our Sites may include links to external websites not operated by Flowell. Please understand that this Privacy Policy does not apply to the practices of third parties, including our partners, service providers, or advertisers, even if their services are branded or offered on behalf of Flowell. Information collected by these third-party sites, such as those you access through links on our Sites, is managed under their respective privacy policies.
If you follow a link to an external site, you will be directed to that third party’s website. We recommend carefully reviewing the Privacy Policy of each site you visit.
Flowell does not control and is not responsible for the content, privacy practices, or policies of any third-party websites or services.
11. Children’s Privacy
Our Sites are designed for adult users and are not intended for individuals under 18 years of age (“Children”). Children under 18 are not permitted to use our Sites. If you are under 18, please do not attempt to register for or interact with our Sites, nor should you provide any Personal Information.
We do not knowingly collect Personal Information from individuals under 18. If you are a parent or guardian and discover that your child has provided us with Personal Information in violation of this Privacy Policy, please contact us. Should we become aware that we have unknowingly collected Personal Information from a minor without verified parental consent, we will promptly delete the information from our records.
12. Updates to This Privacy Policy
We may revise this Privacy Policy periodically. Although we reserve the right to modify our Privacy Policy at any time and at our sole discretion, we will inform you of any updates by posting the revised Privacy Policy on this page. We will update the "effective date" at the top of this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed of any updates. Changes to this Privacy Policy will be effective as of the date they are posted on this page.
13. Submitting a Verifiable Request to Flowell
California residents have specific rights to access, correct, delete, or otherwise control the collection, use, and disclosure of their information. Flowell will respond to a “verifiable request” to exercise these rights—meaning a request in which we can confirm the identity of the person making it. Verifying identity is essential to protect your information and to ensure it is not disclosed to anyone who is not you or is unauthorized to act on your behalf.
You may submit a verifiable request by contacting us using the options provided in the “Contact Us” section below, including our email, mailing address, or toll-free number as listed on our Site. Flowell may require certain information to confirm your identity, such as your name, address, or other details necessary to verify that you are the individual making the request. We will compare this information with the details in our records to confirm your identity.
To verify your identity and ensure that your Personal Information is not disclosed to unauthorized individuals, Flowell may ask for details specific to you, such as account-related information, an email address on record, or other identifying information associated with your use of our Services. This helps protect your data from unauthorized access. If we cannot sufficiently verify your identity or authority to make the request, we will not be able to proceed, and we will notify you accordingly.
If further details are needed, we may reach out to gather additional information. Requests that cannot be verified as coming from the correct individual will not be processed, in order to maintain the security of your data. If we cannot verify your identity, we will not be able to fulfill your request.
Under California law, you may appoint an “authorized agent” to make verifiable requests on your behalf, such as requests for access to or deletion of your information. To uphold the security and privacy of your data, Flowell requires that you provide written permission for the designated individual to act as your authorized agent. We may also contact you directly to confirm the agent’s identity and intent, verifying that no unauthorized party is attempting to exercise your rights.
In cases where an authorized agent submits the request, they must follow the outlined steps and provide proof of authorization. Flowell will also verify your identity as the individual granting permission to ensure security. Requests will not be honored if written consent is not provided, or if identity verification is not possible.
Please note that Flowell will only process verifiable rights requests applicable to California residents.
14. Contact Us
If you have any questions about this Privacy Policy, our practices, your Personal Information, or your rights and choices under applicable laws, please contact us:
By email: support@flowell.com
By phone: +1 (833) 785-1016
15. Difficulty Accessing Our Privacy Policy?
If you are unable to access this Privacy Policy due to a disability or require an alternative format, we offer additional accessibility options. You may request a screen reader-compatible version or another accessible format by contacting us at the information provided above. Flowell is committed to ensuring all individuals have equal access to information regarding our privacy practices.
16. Changes to This Policy for the Flowell Connect App
We may occasionally update this Privacy Policy to reflect changes in the Flowell Connect App’s data processing practices or new features that affect personal data usage. Significant changes that impact your data rights or our data collection methods will be communicated to you through the app or via your registered email. We encourage you to review this Policy periodically to stay informed about how your data is handled. Your continued use of the Flowell Connect App following updates constitutes acceptance of the revised terms.