PRIVACY POLICY

At Friezo Loughrey Oil Well Partners, LLC (the “Company,” “we,” “>us,” or “our”), we respect and protect the privacy of our visitors and registered users of the Site (as defined below) (“you,” “subscriber,” or “your”). We created this “Privacy Policy” to demonstrate our commitment to your right of privacy and to describe our practices for how your personal information is collected and used. This Privacy Policy applies to information that we may receive, collect or maintain about you when you visit http://www.flowoilwell.com, https://www.impliedoil.com, https://www.flowoildata.com, and/or use our oil and gas well information management system (collectively, the “Services”). By accessing the Services, you expressly consent to the use and disclosure of your information as described below. If you do not agree with the terms set out in this Privacy Policy, please do not use the Services and delete any cookies placed by the website.

Except as specifically set forth herein, this Privacy Policy does not apply to information collected by third party websites or services that you may access through the Services or that you submit to us through email, text message or other electronic message, or offline. We are not responsible for the privacy practices or the content of any third party websites. Users and visitors who link to third party websites from the Services should check the privacy and security policy statements of such third party websites to understand the policies and practices of such third-party websites, as we are not responsible for those policies and practices. If you disclose your information to others on other sites on the internet, you do so at your own risk as different rules may apply to their use or disclosure of such information.

Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.

Terms of Use

Data that you provide to us will also be governed by the agreement(s) between you and the Company regarding use of the Services (the “Terms of Use”).

Information We Receive or Collect From You

You may give us data about you when you:

1. set up an account with the Services, for example, user name and password;
2. access or use the Services, for example, identifying information such as information about the organization you represent, contact information, postal address, email address, or phone number (“Subscriber Information”);
3. contact or correspond with us (for example via phone, email or otherwise); or (iv) complete a survey about the use of the Services.

We may collect information about you such as:

1. information about your use of the Services even if you are not a registered user; or
2. (ii) certain technical information if you visit the Services, for example the type of device (and its unique device identifier) you use to access the Services, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time-zone setting, browser plug-in types and versions, operating system, mobile network information and platform, full Uniform Resource Locator (URL), clickstream to, through and from the Services (including date and time), pages you viewed, page response time, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.

We may be given data about you, the organization you represent, or a third party such as information the organization you represent provides to us when it registers with the Services

We do not record the names or email addresses of visitors who do not register as Services users unless such users subscribe to receive information via electronic mail.

To protect children’s personal information, we do not knowingly collect any personal information from persons under the age of sixteen (16) that can be used to specifically identify them and the Company does not permit persons under the age of sixteen (16) to use the Services.

If you believe we might have any information from or about underage children, please contact us at info@flowoilwell.com.

Purpose and Legal Basis for Processing your Data and the Subscriber Information

The Company has lawful bases to collect, use and share your Subscriber Information and any personal data we receive from, collect or maintain about you. Lawful bases include your consent (as provided for in this Privacy Policy and the Terms of Use), contract (where processing is necessary for the performance of a contract with you), and other legitimate interests including, but not limited to, where processing is necessary to:

1. comply with laws that apply to us;
2. protect the vital interests of a natural person, such as in an emergency or to protect you or the Company from threats (such as security threats or fraud);
3. enable us to administer our business, such as for quality control and customer service;
4. manage corporate transactions; and/or understand and improve our business and customer relationships generally.

Where we have a legal basis to use your personal data without consent, this Privacy Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used. Where consent is required for our use of your personal data as described above, you have the right to withdraw or decline your consent and cease your use of the Services.

Your Subscriber Information will be kept confidential and will be used to support your relationship with us. Except as otherwise set forth in this Privacy Policy or the Terms of Use, we will not sell, rent or lease to others your Subscriber Information or any other personal information we receive from, collect or maintain about you.

As set forth above, if you email us, we may keep your message, email address, and contact information to respond to your message. In certain instances, our response may be provided to other Services users or third-parties as necessary to address certain problems, comments, and requests.

We employ Stripe as a payment intermediary service to receive payment from users, and do not request or store any of your financial information, such as your bank routing or account numbers, or your debit or credit card account numbers.

Following termination or deactivation of your account with the Services, we may retain information, including profile information and Subscriber Information, in order to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our rights under our agreements with you, for backup, audit or regulatory purposes, and for other actions permitted by law.

Otherwise we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we originally collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may share your Subscriber Information for marketing purposes but only with your prior consent. Those uses will be subject to such third party’s privacy policies. Also, the Company may share your Subscriber Information with third parties in aggregated and/or anonymized form.

Special Cases in which We Share Personal and Password Information

We may share your information, including Subscriber Information and personal information, with a third party in connection with a merger, sale, or acquisition, or a bankruptcy. Whenever your information is disclosed under this paragraph, we may also disclose such information on a non-aggregated, non-anonymous basis.

Under certain circumstances, Subscriber Information and personal information may be subject to disclosure pursuant to applicable law, judicial or other government subpoenas, warrants, or orders. In such circumstances, you acknowledge the Company may disclose such information to the extent necessary to comply with such legal requirement. Also, we may share your Subscriber Information or personal information in an emergency if necessary to protect the safety of Company employees, agents, customers or any person. Again, when your information is disclosed under this paragraph, we may also disclose such information on a non-aggregated, non-anonymous basis.

We may also share Subscriber Information and personal information with our service providers, business partners, suppliers, sub-contractors or agents who perform services for us, as well as our professional advisers (including our lawyers, bankers, auditors and insurers), and analytics and search engine providers that assist us in the improvement and optimization of the Services.

Control, Email and Opt-Out

You have control over your Subscriber Information and other personal information related to your use of the Services. Accordingly, you may access, review, add, modify, correct, delete or update your Subscriber Information or other personal information at any time.

If you receive one or more emails from us, it means one of two things: (i) your email address is on our list of customers or prospective customers; or (ii) you have provided us your email address so that we could contact you. If you believe you receive an email from us in error, please contact us immediately at info@flowoilwell.com

We provide you with the opportunity to opt-out of receiving marketing communications from us at any point in time. If you wish to cease receiving marketing emails and other communications from us, you can opt-out by contacting us at sales@flowoilwell.com.

In addition to the above rights of access, correction, amendment or deletion, if you live in the EEA, subject to applicable law, you may have some or all of the following rights with respect to your personal information:

1. to restrict processing of your personal data if the data is inaccurate, the processing is unlawful or we no longer need it for the purpose for which we hold it;
2. to transmit your data (as provided by you, directly or otherwise collected by us by virtue of your use of the Services) in machine-readable format to you or to a third party when we justify our processing on the basis of your consent or the performance of a contract with you;
3. to withdraw your consent to our processing of your personal data (where that processing is based on your consent);
4. to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization;
5. to object, at any time, to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law;
6. to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed); and
7. to file a complaint with your local supervisory authority for data protection.

You can exercise the above rights by email sent to info@flowoilwell.com. If you establish a membership account with the Services, you may make changes to the Subscriber Information related to your account by accessing your account settings.

Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of the Services you may not be able to use the Services as you did before, or at all. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least five (5) working days for your request to be addressed.

Please note that the rights mentioned above do not extend to non-personal data. Please also note that it may be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted to and/or held on the Services, and to manage the Services; your rights under applicable law may be limited accordingly.

Security of the Information Collected

We use technical, organizational, administrative, and physical security measures designed to protect against the loss, misuse and alteration of data used by, or transmitted to or from, our system. No data transmissions over the Internet, however, are guaranteed to be completely secure. While we strive to protect your data from unauthorized use or disclosure, the Company does not warrant or guarantee the security of the data that you provide to us; any transmission is at your own risk.

You are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of the Services without notice, pending an investigation, if any breach of security is suspected.

Information Choices and Changes

You may request to review, correct, delete or otherwise modify information you have previously provided to us through the Services.

You have the right to ask us not to collect, use, process or disclose your Subscriber Information in any of the manners described herein. This will affect your user experience. You can notify us of your intention to halt the collection, use, processing, or disclosure of your Subscriber Information at any time by contacting us at info@flowoilwell.com.

Some personal information is automatically collected via the use of data analytics tools. If you object to such collection, your only choice is not to access the Services.

Cookies

Cookies are text files that web browsers place on a computer’s hard drive to tell site owners whether an individual has interacted with the website previously. The Company uses cookies to recognize repeat visits by users of the Services and to collect information about our users’ interactions with and within the Services. The cookie may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g., the IP address) or the user. The use of cookies enables us to make your experience with the Services easier and more meaningful.

There are two types of cookies: session-based cookies and persistent-based cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. They include such information as a unique identifier for your browser. Standing alone, cookies do not contain personal data, and therefore do not identify you personally; they merely recognize your browser. Also, we may use other standard technologies including, but not limited to, pixel tags and web beacons, to track visitors to the Services. These technologies also help us to gather information including, but not limited to, the number of visitors to the Services and the pages those visitors accessed. This information also helps us to improve the appearance and content of the Services and enhances the functionality of Services resources. Unless you choose to identify yourself to the Company by using the Services, you will remain anonymous to the Company. You may delete cookies if you no longer wish to store them on your computer.

From time to time, we may engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to the Services to help us administer the Services and improve its quality. Such third parties may use cookies to help track visitor behavior, including visitor responsiveness to online advertisements. Such cookies will not be used to associate individual Services visitors with any personal data. All data collected by such third parties on our behalf is used only to provide us with information on Services usage and will not be shared with any other third parties.

The cookies we use do not transmit personally identifiable information to us or to our service providers. You have the choice to opt-out of receiving cookies from both the Company and third parties which will prevent the Company and third parties from tracking information about the online advertisements that you visit. Please note that you still will have the ability to use the Services even if you opt-out of receiving cookies, or if you choose to disable cookies; however, you may have limited access to some areas of the Services.

If you wish to opt out of receiving cookies from the Company, please contact info@flowoilwell.com. To opt-out of receiving cookies from our third parties, please contact info@flowoilwell.com

For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

Further Information

The Company is the sole owner and operator of the Services. If you have any questions about anything in this Privacy Policy or about how we collect your Subscriber Information, or information generally, please contact info@flowoilwell.com.

You may also use the above contact information if you think any information about you is inaccurate or incomplete.

Privacy Policy Changes

We reserve the right to modify, amend or cancel this Privacy Policy at any time. Any changes to this Privacy Policy will be posted here https://www.impliedoil.com/privacy-policy, so please check this page regularly and make sure to check the effective date of the policy as set forth above. If you have any questions or concerns about the changes, please contact us at info@flowoilwell.com

Notice to California Residents

Pursuant to California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Compliant Assistance Unit of the Division of Consumer Services for the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

International Transfers

From time to time, personal information we collect from data subjects in the European Economic Area (“EEA”) may be transferred to, stored, processed or accessed by, us and other entities who may be based outside of the EEA, for example, the United States. Also, we may allow our service providers or assistance providers, who may be located outside the EEA, to access your personal data. In addition, we may make other disclosures of your personal data outside the EEA, for example, in the event we receive a legal or regulatory request from a foreign law enforcement body.

We will always take steps to ensure any transfer of such information to entities based outside the EEA is carefully managed to protect your rights and interests by implementing appropriate safeguards to protect your personal information. Your personal data may be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where there is no adequacy decision by the European Commission in respect of a country (to the extent that they are outside the EEA), which means it is not deemed to provide an adequate level of protection to your personal data, we will ensure your personal data receives an adequate level of protection. For example, each such transfer to a third party will be protected by contractual commitments and further assurances (where appropriate) such as the European Commission's approved Standard Contractual Clauses.

If you would like to find out more about these safeguards in respect of processing your personal data, please contact us at info@flowoilwell.com

Notice to EU Data Subjects

Please be aware your Subscriber Information and personal information may be transferred to, processed, and stored in a country different from your country of residence. Data protection laws in such country may be different from those of your country of residence. You consent to the transfer of your information, including Subscriber Information, to such country as set forth in this Privacy Policy by visiting the Services.

How to Contact the Company

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@flowoilwell.com.

Please also contact us if you would like to know more about our data processing activities, to update or amend any of your personal data which you have sent us or if you believe our records relating to you are inaccurate.