Privacy Policy

The FLO entity that operates the Site you use is the entity that acts as controller of any personal information collected through your use of the Site. This means it is the entity that is primarily responsible for how and why your personal information is used.

We may collect the following personal information about you when you visit our Sites or use the FLO Network, but we try to collect as little as we need to fulfil the purpose of our interaction:

• Your name.
• Your home address and, if you provide them, other addresses that you designate as your “Favorite” places to use the FLO Network.
• The location of your charging station, if it is connected to the FLO Network through Wi-Fi or cellular connection.
• The approximate location of your mobile device, if you enable its location services to allow us to locate charging stations near you and provide other location-dependent services.
• Your email address.
• Your phone number.
• Your date of birth, but only when you choose to participate in anonymous customer surveys that we run from time to time.
• Your electric vehicle model.
• Your power consumption when you use the FLO Network.
• The time, date, and location of your charging sessions on the FLO Network.
• Your device identifiers (IP address and mobile device ID) that recognize you over time and across interactions with our Sites.
• Any information you provide us voluntarily when you send us your feedback, request products or services, contact our customer support, or inquire about your personal information.

Our Sites are not intended for, and we do not knowingly collect personal information from, children under the age of 16. If you are under this age, please do not provide us personal information of any kind whatsoever. If a child under this age provides us with personal information, a parent or guardian of that child may contact us to have this information deleted from our records. If you believe that we may hold information about a child under the age of 16, please notify our Privacy Officer at privacy@flo.com.

You directly provide FLO with most of the personal information we collect about you, but we also collect your personal information indirectly through our products and through cookies.

Information we collect from you

You directly provide personal information to us when you create a FLO account on our Sites, use the FLO Network, place an order for any of our products or services, contact customer service, submit a query to us via our Sites, interact with us on social media, click an advertising link that we put on someone else’s website, provide a testimonial, register for our events (including webcast events), enter our sweepstakes, contests or similar promotions, or complete our surveys. If you communicate with one of our representatives by phone, the conversation may be recorded to assess the quality of the service, to train our employees, or to protect both parties in case of disagreement. You will be notified of such recording in advance and may refuse it.

Information we collect through our products or services

We collect your charging station’s location automatically through its Wi-Fi or cellular connectivity, as applicable. You may disable this feature by contacting us at service@flo.com. Please be advised that several features of your smart charging station, such as over-the-air updates that enable product and security enhancements, depend on Wi-Fi or cellular connectivity, so disconnecting your charging station from the FLO Network will restrict all such features.

Information we collect through cookies

We collect personal information about you automatically through cookies that record how you interact with our Sites. You can learn more about cookies and how we use them in later sections of our Privacy Policy.

We use the personal information we collect about you to:

• Create and maintain your FLO account.
• Process your online purchases and deliver our products and services to you.
• Give you access to charging services on the FLO Network and networks operated by our roaming partners.
• Bill you for your charging activities on the FLO Network and networks operated by our roaming partners.
• Send you technical notices, product and service upgrades, and security alerts (because this information is important to your interaction with the FLO Network, you may only opt out of receiving these communications by deleting your FLO account).
• Verify your identity if you contact us with requests related to your privacy rights or our products and services.
• Respond to your requests, complaints, comments, and questions.
• Communicate with you about your account information, the status of your charging session, our upcoming events, sweepstakes, contests, promotions, special offers, and other news about us (we will ask you for your consent before doing so and if you are on our mailing list and wish to unsubscribe, you may do so by clicking the link provided on every email).
• Serve you advertising (we provide more details about this in the “What are our marketing and advertising practices” section of our Privacy Policy).
• Detect and prevent fraud on, and security threats to, the FLO Network.
• Apply for and collect carbon credits in respect of your charging station, as long as you or another third party are not the default collector of such credits under applicable laws or regulations.
• Compile aggregate data about how our members use the FLO Network so we can improve our services.
• From time to time, for other purposes when we have valid reasons and the legal grounds to do so.

We do not store your password when you create an account or use our Sites, and we do not collect or store your credit card number or other credit card information.

This section describes how we use your personal information for online marketing and advertising. We use cookies and other similar technologies (including scripts, pixel tags, etags, web beacons) on our Sites to understand your habits when you browse the Sites or other websites that display our advertisements. These tools help us and our marketing partners tailor advertisements that we think are most helpful and relevant to you. We provide more detail on how we use cookies in the “How do we use cookies” section and the “What types of cookies do we use?” section of our Privacy Policy.

We also partner with third-party social media platforms, such as Facebook, to show you customized advertisements. To offer such ads, we may convert your email address, telephone number or other contact information you have provided us into a unique value which can be matched to your social media profile by our partners, such as Facebook or other social media platforms. While FLO does not provide any personal information to these platforms, these platforms may gain insights about you and help us provide you interest-based advertising. Please visit Facebook for information on Facebook’s advertising and privacy policies (https://www.facebook.com/about/privacy/) and visit any other social media platform you use for information on their policies.

You have the right to object to our use of your personal information for marketing and advertising purposes, or – where you have provided us your consent to use your personal information for marketing and advertising purposes – to withdraw your consent.  Please read the “What are your rights regarding your personal information?” section of this Privacy Policy for further details. If you are a California resident and wish to make an opt-out request under the California Consumer Privacy Act, please refer to the “Do Not Sell My Personal Information” section of this Privacy Policy.

You can disable certain cookies by using the “help” feature of your Internet browser. We provide more details on how to manage cookies in the “How can you manage cookies?” section of this Privacy Policy.

You can also opt-out of network advertising programs here:

• NAI opt-out page: http://www.networkadvertising.org/managing/opt_out.asp and
• Ad Choices opt-out page: http://www.aboutads.info/choices/

Finally, you can opt-out of customized social media ads by adjusting your social media settings (for example, you can manage your settings via your Facebook profile). You can also unsubscribe from mailing lists by using the unsubscribe links included in the advertisements.

We may share your personal information with the following parties on a need-to-know basis and otherwise as required law.

Affiliates

We may disclose personal information to our affiliate companies (under common ownership) for the purposes described in this Privacy Policy.

FLO employees

Within FLO, we limit access to your personal information to authorized personnel whose responsibilities justify their need to know the information.

Partners and Suppliers

We may share information that we collect about you through cookies with our advertising partners (including but not limited to Google, Bing, Yahoo!, AOL, LinkedIn, Facebook, Twitter, Instagram, TikTok, Pinterest, and Taboola) and content publishers in our industry. This means that when you are on their websites, you may be shown advertising based on your browsing patterns on our Sites. We provide more details on this in the “How do we use cookies?” section and in the “What types of cookies do we use?” section of our Privacy Policy.

We may also share information that we collect about you with service providers that perform services on our behalf, such as our distributors (who help bring our products to market and make them widely available to you) and our call centre partners (who help us respond to customer service inquiries). We only share personal information with service providers that is necessary to perform the service and we always use contractual safeguards to ensure that our service providers protect your personal information appropriately throughout its lifecycle and comply with all applicable laws and regulations.

While we will not store your personal information outside Canada or the United States, we may transfer your personal information to service providers in other jurisdictions, in which case the information may be processed and subject to laws or regulations in countries, states, or provinces other than where you are based.

Professional Advisors and Entities Involved in Corporate Transactions with FLO

We may also share your personal information confidentially and under non-disclosure obligation with our financial and legal advisors for audit purposes, as part of a sale or assignment of our business, or to facilitate corporate financing transactions. In the event we combine with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personal information may be transferred with the business, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to our privacy practices occur as a result of such a transaction, we will notify you in advance by email or by prominent notice on our Sites and inform you of the choices you may have regarding your personal information.

Aggregated Information

We may also share aggregated non-personal information in the form of insights, trends, or analytics that do not identify you with third parties like utilities, academic researchers, policy actors, service providers, and other third parties to use for their own benefit. These purposes include understanding and forecasting trends in electric vehicle charging, developing driver behavioural insights, conducting research and policy development on electric vehicles and electric vehicle charging, and developing load management, vehicle grid integration, and other similar programs. For example, we may share our number of customers located in a certain geographic area; or anonymous charging session information like the number of hours in a day customers use electric vehicle chargers, charging session start and stop times, and the energy output associated with charging sessions.

We store the personal information of our Canadian customers at data centres hosted by Microsoft Azure in the Province of Québec (with a backup to a data center in the Province of Ontario). We store the personal information of our American customers at data centres hosted by Microsoft Azure in the State of Washington (with a backup to a data centre in the State of Virginia).

We do not keep your personal information for longer than is necessary to fulfil the purpose for which it was collected or to fulfil other legitimate purposes, such as complying with our legal obligations and resolving legal claims. Because these needs can vary for different types of personal information and depending on your use of the Sites or the FLO Network, actual retention periods can vary. When your personal information is no longer necessary, we destroy it securely. We never keep it just in case we have a need for it in the future.

We are committed to protecting your personal information. Therefore, we use data protection measures that meet stringent security and data privacy requirements and we have implemented appropriate organizational controls to protect your personal information from loss, theft, or unauthorized access, use, or disclosure. We also comply with breach notification laws, which means we will let you know of any breach of security, confidentiality, or unauthorized release of your personal information whenever we are legally required to do so.

Unfortunately, however, sending any information, including personal information, via the internet is not completely secure. Although we will do our best to protect your personal information once with us, we cannot guarantee the security of any personal information sent to our Sites while still in transit and so you provide it at your own risk.

This section describes your rights regarding your personal information, and how to exercise them.

• Access your personal information. You can request a copy of the personal information we hold about you.
• Correct and update your personal information. You can direct us to correct or update your personal information if you discover that any of it is inaccurate or incomplete.
• Delete your personal information. You can require us to delete your personal information. Once we receive and confirm your verifiable request, we will delete your personal information from our records and direct service providers to whom we have disclosed your personal information, if any, to do the same. However, we may deny your request and retain a copy of your personal information if we have a valid reason and legal ground for doing so.
• Object to or restrict our use of your personal information. You can direct us to stop using all or some of your personal information or restrict how we use it. We will always comply with a verifiable objection to our use of your personal information for direct marketing purposes. However, we may deny other objections and continue to use your personal information if we have a valid reason and legal ground for doing so.
• Port your personal information. You can ask us to provide you a machine-readable copy of your personal information so you can transfer it to a third party electronically.
• Withdraw your consent. Where you have provided us with consent to use your personal information, you can withdraw this at any time and thus prevent further use unless FLO has another valid reason and legal ground for continuing to use your personal information.
• Non-discrimination. We will not discriminate against you for exercising any of your rights, for example, by denying you access to our Sites, products or services, or by providing you a different level or quality of service.

You may have additional rights depending on your jurisdiction. If you are a California resident, you can find information about your opt-out right and how to exercise it in the “Do Not Sell My Personal Information” section of our Privacy Policy.

Please be advised that since we require basic information about you to process your transactions, and to create and maintain your FLO account and your access to the FLO Network, your ability to use our Sites and the FLO Network may be impacted if you decide not to provide us personal information that is necessary for us to perform such tasks.

If you would like to exercise any of your rights, please email our Privacy Officer at privacy@flo.com. You do not need a FLO account to make a request. However, only you or a person authorized to act on your behalf may submit a request related to your personal information, so we may attempt to verify your identity or authority to make the request.

We endeavor to respond to a verifiable request within 30 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to comply with your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee for the administrative costs of complying with it, we will tell you why and provide you with a cost estimate before completing the request. If we cannot comply with your request, the response we provide you will also explain why.

This section applies only to residents of California, U.S.A. and supplements the information contained elsewhere in our Privacy Policy. As a California resident, you have the right to opt-out of the sale of your personal information under the California Consumer Privacy Act (“CCPA”). This means that you can direct us at any time to stop selling your personal information. To exercise your opt-out right, please follow the instructions below.

We want you to know that we do not sell your personal information to third parties for money. However, we do share your personal information with third parties for the purposes described in the “Why do we share your personal information?” section of this Privacy Policy. While these data sharing activities are not what you might typically consider to be a sale of your personal information, they could qualify as a “sale” under the CCPA, which includes any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”. Therefore, these are the types of activities we would be required to stop if you opted-out of the sale of your personal information. Since some of our offers and services require us to share your personal information with our partners and suppliers, your ability to use our Sites and the FLO Network may be impacted if you decide to opt-out of the sale of your personal information.

If you would like to exercise your opt-out right, please email our Privacy Officer at privacy@flo.com with “Do Not Sell My Personal Information” in the subject line of your email, or click below and complete our web form: CCPA Op-Out Web Form

If you are a California resident and did not find the information you were looking for in this “Do Not Sell My Personal Information” section, please consult the other sections of our Privacy Policy. We address the following topics elsewhere in our Privacy Policy because they are relevant to residents and non-residents of California alike:

• The categories of personal information FLO collects.
• How FLO collects your personal information and why.
• How FLO stores and protects your personal information.
• How FLO shares your personal information with third parties and why.
• Your privacy rights (other than your CCPA opt-out right). These include your right of access, right of deletion, and right to non-discrimination, which all users of our Sites enjoy, whether they are California residents or not.

Cookies are small text files that get placed on your device when you visit our Sites. They collect standard web log information and visitor behaviour information that allow our Sites to recognize and remember you when you return to our Sites. Some cookies are necessary to help our Sites work properly and cannot be switched off, and some are optional but improve your experience on our Sites. We set out more details on this below.

We use cookies in a range of ways to improve your experience on our Sites, including:

• Ensuring the Sites function.
• Keeping you signed in until you sign out.
• Remembering your preferences so the Sites feel more personalized when you return.
• Understanding how you use the Sites so we can make them more intuitive.
• Delivering you relevant advertising in the form of personalized ads.

In the next sections, we explain in more detail how cookies on our Sites may be useful, and when and where you can manage them.

We use four types of cookies:

Necessary cookies

These cookies are essential for our Sites to function properly, which means they cannot be switched off. For example, these include the cookies that make it possible for you to stay logged into your FLO account. Without these cookies, you would not be able to navigate our Sites properly or operate their basic functions.

Performance cookies

These cookies measure how often you visit our Sites and how you use them. We use these cookies to get a better sense of how you engage with our Sites so we can make them more intuitive and improve your experience in other ways. For example, these cookies record which browser and operating system you used, which parts of our Sites you viewed most frequently, and how long you spent on our Sites. These cookies do not collect information that would allow us to identify you personally. They collect aggregated information, which is anonymous.

Functionality cookies

These cookies are used to recognize and remember your preferences or settings when you return to our Sites, so that we can provide you with a more personalized experience. For example, these include the cookies that collect information about your language settings and where you are based to ensure you receive the homepage for your country and in your language when you visit our Sites. These cookies collect anonymous information and cannot track your browsing behaviour on other websites.

Advertising cookies

These cookies collect information about your activity on our Sites, including the content you have viewed, the links you have followed, as well as information about your browser, device, and your IP address. We use these cookies to understand what you are interested in. We can then display advertising on your browser based on those interests. For example, if you have been reading up about our FLO Home^TM products, you may be shown more adverts for those products. These cookies uniquely identify your browser, device, and IP address (and therefore your general location), which, together with other information about you collected through cookies, could be used by third parties to identify you.

We also allow analytics services like Hotjar, Google Analytics, YouTube Analytics, Facebook Ads, Microsoft Advertising Universal Event Tracking, and Tik Tok Conversion Tracking to collect information on our Sites through cookies and similar technologies to help us analyze how our Sites are being used, measure the number of visitors our Sites receive, display advertising, and measure its effectiveness.

Our Sites may also include third-party advertising, links to other websites and social plugins.  Social plugins are buttons that let you share your experiences on our websites with other people on social media platforms. When you share your experiences through social plugins, social media platforms install their own cookies on your device.

You can stop your browser from accepting cookies by changing your browser’s cookie settings. Most browsers are initially set up to accept cookies; however, the “help” or “preferences” menu on most browsers will tell you how to manage cookies and/or how to disable them completely.

If you are a California resident, you may opt out of the sale of your personal information through cookies by following the instructions located in the “Do Not Sell My Personal Information” section of our Privacy Policy.

Please be advised that disabling cookies may affect user functionality on the Sites. For instance, visitors who have disabled cookies will no longer be able to enjoy all functionalities related to the management of their FLO account.

We review our Privacy Policy regularly to make sure it reflects changes in relevant laws and in how we handle your personal information. We may therefore change our Privacy Policy periodically. If we change our Privacy Policy, we will update this page and we will indicate at the top of the Privacy Policy when it was last updated. If we make any material changes, then we will also notify you in advance by email or by adding a pop-up notice to our Sites.

If you are not willing to accept the changes to our Privacy Policy, you must delete your FLO account and stop using the Sites and the FLO Network. By continuing to use the Sites or the FLO Network after we have posted changes to our Privacy Policy or notified you of any material changes, you are agreeing to the terms of the modified Privacy Policy.

We welcome your questions, comments, and concerns about our Privacy Policy and privacy practices.

If you have any questions, comments, or concerns, or wish to exercise any of your rights regarding your personal information, please contact our Privacy Officer by email at privacy@flo.com or by mail at:

FLO

Attn: Privacy Officer

2800 rue Louis-Lumière

Suite 100

Québec (Québec)

G1P 0A4 Canada

You can also contact our Privacy Officer if you are unhappy about how we use your personal information and would like to make a complaint.

If you wish to report a complaint, or if you are not satisfied with the way we handled your concern, you may contact your local data protection regulator. For example, in Canada this would be the Office of the Privacy Commissioner (https://www.priv.gc.ca/en/); in Québec this would be the Commission d’accès à l’information du Québec (https://www.cai.gouv.qc.ca/english); and, in California this would be the California Privacy Protection Agency (https://cppa.ca.gov). For a complete list of the data protection regulators within the European Union, please visit  https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.