Privacy Policy -

Flock, Inc. (“Flock”, “we,” “our,” or “us”) cares about the privacy rights of our users. This Privacy Policy (the “Privacy Policy”) describes the information we collect, how we use it, and when and with whom we share it. Our Privacy Policy applies to information that we collect about you when you access or use our mobile application or other online or mobile service offered by us (collectively, the “Services”). This Privacy Policy also applies to personal data we collect about you offline, such as when you contact us by phone, email or when you communicate with us in person.

By accessing or using the Services or otherwise providing us with your personal data, you acknowledge the applicability of this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services or provide us with your personal data.

This Privacy Policy covers our privacy practices with respect to the collection, use, and disclosure of information obtained through the Services including all information entered into and/or generated through the Services.

Please note that we may engage or partner with third party providers in connection with the provision of the Services. Those third party providers may have privacy policies which differ from the terms contained herein. Although we endeavor to partner only with responsible third party providers, we are not responsible for the privacy or data security practices of such third party providers.

Information That We May Collect

Flock may gather certain information through our Services. We may collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or services, sign-up for email updates, send us email messages, contact us by phone or through other applications, and/or when you interact with our various Services, including when you review and interact with the programs and reviews on our application or access related content through our Services. We may use the Personal Data that you provide to respond to your questions, provide you with specific content or functionality and/or send you updates about our offerings, events, and send you email messages about Service maintenance and updates to our Services.

Specific information that we may collect includes, without limitation, the following:

When you register for an account through our Services, you may be required to provide us with Personal Data such as your name, email address, personal address and phone number. You may also be requested to or required to provide Personal Data associated with your family members including your children.
In order for us to provide you with updates and otherwise communicate with you regarding our Services, you may be required to provide us with Personal Data such as your name and email address.
Information you voluntarily provide to us;
Information about specific aspects of our Services you are interested in.
Your credit card account details if you purchase a paid subscription to our Services.
Connectivity, technical and aggregated usage data, such as IP addresses and general locations, device data, date and time stamps of usage, and the recorded activity (sessions, clicks and other interactions) of customers in connection with the use of our services.
Data associated with your participation in surveys or submission of forms.
Your communications with us, such as through customer support;
Your transmission of user content to us, such as when you submit information or reviews about a camp program listed or to be listed on our Services.

You are not required to provide us with such information, but certain features or functions of the Services may not be accessible or available, absent the provision of the requested information.

We may also collect certain information about you automatically in connection with your interaction with our Services. This includes the following:

Device/Usage Information. We and our third-party service providers, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers; and (i) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our mobile application. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Services are used most frequently), to assist in determining relevant advertising (both on and off the Services), to evaluate the success of our advertising campaigns, and as otherwise described in this Privacy Policy.

Cookies and Other Electronic Technologies. We and our third-party service providers may use cookies, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services including our application. These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the portions of the application that you visit, help us manage content, and compile statistics about usage of our Services. We or our third-party service providers also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. You can choose to accept or decline cookies. If you disable cookies, you may be prevented from taking full advantage of our Services, because the Services or some portions thereof may not function properly.

Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address). We may also collect precise location information where you authorize such collection. For example, we may use precise location information to provide you with listings of camps and programs near you.

How we use the Information that we collect

We may use Personal Data and other information that we collect in some or all of the following ways and for some or all of the following purposes:

To provide you with the information you request.
To learn more about who is interested in our products and services.
To understand how visitors to our Services are using them, and which pages and features of our applications are most popular.
To help us improve the navigational experience on our application.
To track and prevent fraudulent activities and other inappropriate activities and monitor content integrity, manage security, and verify or authenticate information provided by you.
To provide you with marketing communications. You may choose to opt out of further marketing communications from us through an unsubscribe link.

To identify you as an account holder.
To communicate with you about your account.
To recognize you when you communicate with us.
To communicate verification codes to your phone number when you log into your account, if you choose to set up two-factor authentication.
To bill you for your use of our products and services.
To gain a better understanding on how our customers evaluate, use and interact with our Services, and how we can continue to improve our products, offerings and the overall performance of our Services.
To help us better understand our customer base.

To prevent fraud, conduct security investigations, run risk assessments, and enforce our legal terms.
To protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services.
To comply with our legal obligations or as permitted by law.
To verify your identity, conduct checks against third party databases, and other information sources.

We may combine information that we collect from you through the Services with information that we obtain from affiliated and nonaffiliated third parties, and information derived from any other products or services we provide.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

Your rights with respect to the Information

You have certain rights in relation to the Personal Data that we obtain. The exercise of these rights may vary depending on the data protection laws that apply in relation to the applicable Personal Data.

Except as set forth in this Privacy Policy or as specifically agreed to by you, Flock will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below.
We use various service providers, vendors, and contractors (collectively, “Contractors”) to assist us in providing our Services to you. These Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of our Services including our application. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
We do not sell, rent, exchange or allow your data to be used by third parties for their own marketing purposes.
We may be required to share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities and/or to protect and defend our rights or the rights of third parties.

Children’s Online Privacy Protection Act (“COPPA”)

Our Services are not designed for use by children under 13, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information.
Consumers under 16 years of age. We will not sell or share Personal Information of users if we have actual knowledge that the user is less than 16 years of age, unless the user, in the case of user at least 13 years of age and less than 16 years of age, or the user’s parent or guardian, in the case of users who are less than 13 years of age, has affirmatively authorized the sale or sharing of the user’s Personal Information. If you, as a parent or guardian of a child, provides information associated with that child in connection with our Services, we will consider that your affirmative authorization to share that child’s information subject to applicable law and the terms of this Privacy Policy.

Data Storage and Retention

We use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure. Because networks including the internet are not 100% secure and are subject to breaches, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information will be intercepted. It is your responsibility to protect the security of your login information. We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain your Personal Data depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

Changes to our Privacy Notice

We may change this Privacy Policy from time to time. If we make changes, we’ll revise the updated date at the top of this notice, and we may provide additional notice to areas such as on our application, on our website, via an account sign-in page, or via the email address we have on file for you. We will comply with applicable data protection laws with respect to any changes we make to this Privacy Policy and seek your consent to any material changes if this is required by applicable law.

International Users

Flock stores information about visitors to our website and users on servers located in the United States. By using our Services, you consent to the storage of your information inside the United States. If you are using the Services from outside the United States including from the European Union, you should know that your Personal Data will be transferred to and stored in servers located in the United States. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. By using the Services, you acknowledge the transfer, storing, and processing of your information in and to the United States.

If you reside in the European Union (“EU”) or the European Economic Area (“EEA”), the European Union General Data Protection Regulation (“GDPR”) will apply to how we collect and process your Personal Information. If you reside in the United Kingdom, the United Kingdom General Data Protection Regulation (“UK GDPR”) will apply to how we collect and process your Personal Information.

Personal Data may be processed outside of the United Kingdom, EU and the EEA by Flock or our service providers, including to process transactions, facilitate payments, and to provide support services. We may have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Flock and its processors.

Flock is considered the “data controller” of the Personal Information that we handle under this Privacy Policy. As such, Flock is responsible for deciding how to collect, use and disclose this data, subject to applicable law. The laws of some jurisdictions such as the laws of the EEA, EU and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing your information. To the extent those laws apply, our legal grounds are as follows:

Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you.
With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues.
Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

Third Party Links and Features

The Services may contain links to third-party websites such as social media sites, and also contain third-party integrations. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Flock is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy.