Privacy Policy

Introduction

Sleekflow Technologies Limited of Cyberport Road, Pok Fu Lam, Southern Hong Kong, with company register number 2654883, trading in the UK as SleekFlow Technologies Company Limited, registered at Room 5 2nd Floor, 39-41 High Street, New Malden, Surrey, United Kingdom, KT3 4BY, with registration number 13855447 (“SleekFlow”, ”we”, ”us”, ”our”) are committed to protecting and respecting your privacy.

We are committed to the protection of the personal data we process in line with the data protection principles set out in the UK General Data Protection Regulation (“UK GDPR”) and the EU General Data Protection Regulation (EU Regulation 2016/679) (“EU GDPR”) (together referred to herein as the “GDPR”); the Hong Kong Personal Data (Privacy) Ordinance (Cap.486) as amended (“PDPO”); the Personal Information Protection Law of the Peoples Republic of China (“PIPL”); the Data Security Law of the Peoples Republic of China (“DSL”); Lei Geral de Proteção de Dados Pessoais of Brazil (“LGPD”); Indonesia Law No.27 of 2022 on Personal Data Protection (“PDP Law”); Singapore Personal Data Protection Act (“PDPA”); Malaysia Personal Data Protection Act 2010 of Act 709 (“PDPA”); the Dubai Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (“PDPL”); the UK Data Protection Act 2018 (“DPA 2018”); the Privacy and Electronic Communications Regulations 2003 (“PECR”), as amended; the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). Consideration has also been given to the other State and Federal data protection laws of the United States which are applicable to us and which are not referenced here.

California residents should refer to Appendix A of this Privacy Notice.

We have aligned our company data protection compliance programme to the core requirements of the GDPR, as this is considered by SleekFlow as the global ‘gold standard’ of data protection regulation.

This Privacy Notice (“Notice”) explains how we treat personal information processed on our bespoke platform, SleekFlow, what we collect when you visit our website, contact us by email, phone or through one of our social channels, or through other communications. It also explains what information we collect automatically when you visit our website and the information we collect when you use our services.

Please be aware that we have separate privacy notices for employees and job applicants, available from SleekFlow Human Resources. Please also be aware that our clients’ have their own privacy notices on their respective websites.

Our work is predominantly as a Processor for our clients; however, SleekFlow is the Controller for our employee data and for the contact details of our clients. As such, in line with the requirements of UK data protection law, we are registered as a Controller in the UK with the Information Commission, registration number ZB360772.

As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity and availability of the data we hold and in meeting our data protection obligations when processing personal data. We are committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.

We update this Notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document. Please review this Notice periodically to check for updates.

What information do we process?

Information provided by our clients

The categories of personal data processed by us varies between clients, but may include:

Information provided to us via our website

We process all information you provide to us via our website (“our site”), by telephone, email or otherwise. This includes information you provide when you register for our services as a client, enquire about a product or service, use one of the social media functions linked to our website, or when you report a problem with our website.

The categories of personal data processed may include:

Cookies and Web Beacons

SleekFlow uses cookies on our website and web beacons in some emails. Cookies are small text files and web beacons are small graphic images. They are downloaded to your device when you visit a website or receive certain emails, unless you have set your browser to reject them.

We use cookies to remember your preferences and improve your overall experience of our site. We use web beacons to track the actions of individuals (such as email recipients) and measure the success and response rates of our marketing campaigns.

Below is a list of the cookies we use and the purpose of use:

To learn more about cookies, web beacons and what you can do to opt out of receiving them, please visit https://www.allaboutcookies.org/.

Purposes and bases for processing your personal data

We may use your data for the following purposes and on the following lawful bases:

Sharing your information

If sharing your personal data becomes necessary for the purposes of providing our services to you, we will only share it where appropriate safeguards are in place, such as the UK International Data Transfer Agreement (“IDTA”) or the EU Standard Contractual Clauses (“SCCs”) with supplementary measures, to ensure your personal data is protected to the same standard expected under the GDPR.

We may, on occasion, engage the services of a third-party sub-processor. Any such third party will act under our written instructions and will adhere to strict data protection obligations, including the implementation of appropriate technical and organisational measures which meet the processing requirements of the GDPR.

We also use a third party for hosting infrastructure, website performance and management, error monitoring, support and other functionality. The written contract in place between us and this third party provides for the maintenance of confidentiality, security, and integrity of the information we share with them.

Our website includes links to social media platforms and messaging services (WhatsApp, Facebook, Instagram, LinkedIn, ‘X’ (formerly Twitter)). Once you navigate away from our site via one of the links, the site may collect your IP address and may set a cookie on your device. When you use one of these links, you are sharing information to another website or service and this Notice will no longer apply. Please read the privacy notices provided by the particular service website you are directed to, before posting any personal information using these links.

Your rights

The GDPR provides you with certain rights in relation to the processing of your personal data, including to:

• Request access to personal data about you (a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.

• Request rectification, correction, or updating of any personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request personal data provided by you to be transferred in a structured, commonly used and machine-readable format.

• Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below).

• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g., if you want us to establish its accuracy or the reason for processing it).

• In the UK, you have the right to lodge a complaint with us as Controller of your personal data. This is in addition to your right to complain to the UK Information Commission.

• Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of SleekFlow.

Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation, laws, and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us at legal@sleekflow.io. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

In addition to the above, please note that you have the right to make a complaint at any time to the relevant supervisory authority within the UK and EEA if you are concerned about the way in which we are handling your personal data.

Data retention

We will retain your personal data for as long as is necessary to provide you with our products and ongoing services and for a reasonable period thereafter, to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

At the end of the retention period, your personal data will be securely deleted in accordance with our Personal Data Retention Policy.

Children's data

Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18.

If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us at legal@sleekflow.io.

If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to remove that information from our servers.

Data protection officer

Due to the nature of our personal data processing, we are required by law to appoint a Data Protection Officer (“DPO”). We have therefore appointed Evalian Limited as our DPO, details as follows:

Evalian Limited, West Lodge, Leylands Business Park, Colden Common, Hampshire, United Kingdom. SO21 1TH

Tel: 03330 500 111

Email: dpo@evalian.co.uk

Contact

You can contact us in relation to data protection and this Notice by emailing legal@sleekflow.io.

Appendix A

California Residents Additional Information

This Appendix A ("Appendix") applies to California residents and outlines your rights regarding the processing of the personal data we hold about you under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA").

1. Introduction

SleekFlow are responsible for determining the purposes and means of processing your data when:

• You visit our website or make general enquiries with us;

• We communicate with you regarding our services;

• We contact you for sales and marketing purposes; and

• During our standard business practices.

2. Personal data we collect, the purposes and legal basis

Please refer to the "What information do we process?" and the "Purposes and bases for processing your personal data" sections in our main Privacy Notice to learn more about the personal data we collect and use.

In summary, we collect the following categories of personal data as classified under the CCPA:

• Online identifiers, such as your email address and IP address;

• Personal information categories (Cal. Civ. Code § 1798.80(e)), such as your first name, last name, address and phone number(s);

• Internet or other similar network activity information, such as information regarding your interaction with our website; and

• Professional or employment-related information, such as your business contact information, job title and company name.

Personal data does not include publicly available information. 'Publicly available' means information that is lawfully made available from federal, state, or local government records. 'Publicly available' does not mean biometric information collected by a business about a consumer without the consumer's knowledge.

3. Sharing your personal data

SleekFlow shares your personal information with service providers such as technology service providers and other business partners as part of our business practices and to provide you with our Services.

Please see the 'Sharing your information' section in our Notice for additional details on how we disclose your personal information with selected recipients for specific purposes.

SleekFlow does not sell your personal data to advertisers or other third parties.

In summary, we share the following categories of information as classified under the CCPA:

• Online identifiers, such as your email address and IP address;

• Personal information categories (Cal. Civ. Code § 1798.80(e)), such as your first name, last name, home address and phone number(s);

• Internet or other similar network activity information, such as information regarding your interaction with our website; and

• Professional or employment-related information, such as your business contact information, job title and company name.

4. Your rights

In addition to the rights mentioned in our main Privacy Notice, the CCPA and CPRA provides California consumers with the following additional rights:

• Right to opt-out of the sale of Personal Data – You have the right to opt-out of the sale of the personal data we have collected about you. Although this right is available to you, SleekFlow does not sell your personal data to third parties.

• Right to non-discrimination – You have the right to not receive discriminatory treatment for exercising any of your CCPA rights. SleekFlow will not treat you differently for exercising any of the rights described in this Appendix or the main Privacy Notice.

• Right to limit the use of sensitive personal information – You have the right to inform businesses who fall under the CCPA and CPRA to limit the use of your sensitive personal data to only that which is necessary for providing their products or services.

You can exercise any of your rights by emailing legal@sleekflow.io. You may also authorise an individual to submit a verifiable consumer request relating to your personal information.

To help protect your privacy and maintain security, we take steps to verify your identity before responding to requests. To verify your identity and confirm the personal data relates to you, we may ask you to confirm your identity.

If you wish to use an authorised agent to submit a request on your behalf, you must provide the authorised agent written permission signed by you, the customer. We may deny a request from an authorised agent if the agent cannot provide your signed permission demonstrating that they have been authorised to act on your behalf.

Generally, we will respond to your rights request within one month of receipt, however the CCPA allows us to respond within 45 days. Your request and choices may be limited in certain cases, for example, if fulfilling your request is not permitted by law or if we have compelling legitimate interests to refuse your request.

5. Contact us

If you have any questions about this Appendix, this Privacy Notice, your rights, or data protection in general, please contact us at legal@sleekflow.io.