Privacy Policy

1. Introduction

FL Marketing, Inc. ("FL Marketing," "we," "us," or "our") operates an informational website at https://flmarket.ing (the "Site") describing the company and its marketing and customer-acquisition services for pioneering companies. The Site's only interactive feature is email contact capability.

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit the Site. It also describes your privacy rights under applicable law. Please read this policy carefully. By using the Site, you acknowledge that you have read and understood this Privacy Policy.

We update this policy periodically. The "Last Updated" date above reflects the most recent revision. Material changes will be communicated by posting the updated policy on the Site with a new effective date. Your continued use of the Site after such changes constitutes acceptance.

2. Information We Collect

We collect only the minimal personal information necessary to operate and maintain the Site and respond to inquiries.

2.1 Voluntary Submissions

When you contact us by email at contact@flmarket.ing, we receive:

• Your email address
• Your name, if you include it
• Any information contained in your message

2.2 Automatically Collected Technical Information

Our hosting provider (Vercel Inc.) automatically records standard server log information when you visit the Site, including:

• IP address
• Browser type and version
• Operating system
• Pages requested and viewed
• Referral source (the URL that directed you to our Site)
• Date and time of access

We do not employ cookies, web beacons, advertising trackers, or third-party analytics services on the Site. No persistent identifiers are set in your browser by FL Marketing or by any third party acting on our behalf.

2.3 CCPA Categories of Personal Information

The table below maps our data collection to the statutory categories used under the California Consumer Privacy Act (CCPA/CPRA):

Category	Status
Identifiers (e.g., IP address, email address)	Collected
Internet or other electronic network activity (e.g., pages visited, browser type, referral source)	Collected
Geolocation data (coarse, derived from IP address by hosting provider)	Collected by hosting provider
Commercial information (transactions, purchase history)	Not collected
Sensory or biometric data	Not collected
Professional or employment information	Not collected
Education information	Not collected
Sensitive personal information	Not collected
Inferences drawn from the above	Not drawn

3. How We Use Your Information

We use the personal information we collect for the following specific purposes:

• Responding to your inquiries and communications
• Operating, maintaining, and improving the Site
• Diagnosing and addressing technical issues and preventing fraud or security incidents
• Complying with legal obligations, court orders, and lawful government requests, and enforcing our Terms of Service
• Protecting the rights, property, and safety of FL Marketing, its personnel, and others

We do not use your personal information for advertising, marketing, or for sale to third parties.

We do not use your personal information for automated decision-making or profiling.

4. How We Share Your Information

We do not sell, rent, or share your personal information for cross-context behavioral advertising. We disclose personal information only in the following limited circumstances:

4.1 Service Providers

We share personal information with Vercel Inc. (our hosting provider) solely for the purpose of operating and maintaining the Site. Vercel processes server log data (including IP addresses) as a service provider acting on our behalf. Vercel is not authorized to use your personal information for its own purposes.

• Categories of PI shared with Vercel: Identifiers (IP address), Internet/network activity, coarse geolocation

4.2 Corporate Affiliates

FL Marketing, Inc. is a Flagship Pioneering company. When you contact us by email, your message and contact information may be shared with the appropriate personnel at Flagship Pioneering for the purpose of responding to your inquiry.

4.3 Legal Requirements

We may disclose personal information when required by law, legal process, subpoena, court order, or government request; when necessary to protect the rights, property, or safety of FL Marketing, its personnel, or others; or to detect, prevent, or address fraud, security incidents, or technical issues.

4.4 Business Transfers

If FL Marketing is involved in a merger, acquisition, asset sale, reorganization, or similar transaction, personal information may be transferred as part of that transaction. We will provide notice via an updated Privacy Policy if such a transfer results in a material change to how your information is used.

4.5 Aggregated or De-Identified Information

We may use and share aggregated or de-identified information that cannot reasonably be used to identify any individual, for any lawful purpose, without restriction.

5. Cookies and Tracking Technologies

FL Marketing does not set cookies, web beacons, tracking pixels, or similar tracking technologies on the Site. No third-party analytics, advertising, or social media tracking scripts are deployed.

Our hosting provider (Vercel) may log server-side request data as described in Section 2.2. This is server-log data only and does not involve client-side cookies or browser storage.

If you have questions about whether a specific tracking technology is present, you may audit the Site using your browser's developer tools (Network tab) or a third-party scanning tool such as The Markup's Blacklight (https://themarkup.org/blacklight).

We will update this section promptly if we ever deploy cookies or tracking technologies on the Site.

6. Do Not Sell or Share; Global Privacy Control (GPC)

FL Marketing does not sell or share your personal information as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA) and similar state privacy laws. We do not disclose personal information to third parties for cross-context behavioral advertising or for monetary or other valuable consideration.

Because we do not sell or share personal information, we have not implemented a "Do Not Sell or Share My Personal Information" opt-out mechanism. We do, however, recognize and acknowledge Global Privacy Control (GPC) signals from your browser. Because we do not engage in the sale or sharing of personal information, receipt of a GPC signal requires no additional action on our part, and your browsing experience will not change.

7. Data Retention

We retain personal information only as long as necessary for the purposes described in this policy, subject to applicable legal obligations:

• Email correspondence is retained as long as reasonably necessary to respond to your inquiry and maintain a record of the communication, after which it is deleted or archived in accordance with our internal retention schedule.
• Server log data collected by Vercel is retained for a limited period (typically 30 days) for security and operational purposes, then automatically discarded. Please review Vercel's privacy policy for specifics on their log retention practices.

We may retain personal information longer when required to comply with legal obligations, resolve disputes, enforce agreements, or exercise legal rights. Where retention beyond an initial period is necessary, we apply data minimization principles and limit access accordingly.

8. International Data Transfers

FL Marketing is headquartered in the United States. If you are visiting the Site from outside the United States, including from the European Union or United Kingdom, your personal information will be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction.

Our hosting provider, Vercel Inc., is a US-based company. To the extent Vercel processes personal data of visitors from the European Economic Area (EEA) or United Kingdom, Vercel relies on applicable transfer mechanisms, including participation in the EU-US Data Privacy Framework (DPF) and Standard Contractual Clauses (SCCs), as applicable. You may review Vercel's privacy practices at https://vercel.com/legal/privacy-policy.

By using the Site, you acknowledge and consent to the transfer of your personal information to the United States as described above.

9. Your Privacy Rights

9.1 Rights Available to You

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

• Right to Know / Access — to request disclosure of the categories and specific pieces of personal information we have collected about you in the preceding 12 months (and beyond, to the extent required by applicable law).
• Right to Delete — to request deletion of personal information we have collected, subject to certain exceptions (e.g., information needed to complete a transaction, comply with a legal obligation, or exercise a legal right).
• Right to Correct — to request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing — FL Marketing does not sell or share personal information, but you may still submit a request. We will confirm receipt and that no action is required.
• Right to Limit Use of Sensitive Personal Information — FL Marketing does not collect or use sensitive personal information beyond what is necessary for the purposes described in this policy.
• Right to Data Portability — to receive a copy of your personal information in a portable, machine-readable format where technically feasible.
• Right to Non-Discrimination — we will not deny you services, charge you different prices, or provide a different quality of service because you exercised any of these rights.

9.2 How to Submit a Request

To exercise any of the rights described above, please contact us by one of the following methods:

• Email: contact@flmarket.ing (subject line: "Privacy Rights Request")
• Mail: FL Marketing, Inc., Attn: Privacy, 55 Cambridge Pkwy, Suite 800E, Cambridge, MA 02142

We will respond to a verified request within 45 days of receipt. If we require additional time (up to 45 additional days), we will notify you in writing within the initial 45-day period. If you are located in the European Economic Area or United Kingdom, we will respond within one month of receipt, extendable by up to two further months for complex or numerous requests, as required by the GDPR and UK GDPR. We may need to verify your identity before processing your request.

9.3 Authorized Agents

You may designate an authorized agent to submit a privacy rights request on your behalf. To do so, the authorized agent must provide written proof of authorization from you, and we may require you to verify your identity directly with us before processing the request.

9.4 Appeals

If we deny your request to exercise a privacy right, you may appeal our decision by contacting us at contact@flmarket.ing with the subject line "Privacy Rights Appeal." Please include your original request and our response. We will respond to your appeal within 60 days.

9.5 Rights for EU/EEA/UK Residents (GDPR)

If you are located in the European Economic Area or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR, including:

• Right to Restriction of Processing (Article 18)
• Right to Object to processing based on legitimate interests (Article 21)
• Right not to be subject to automated decision-making or profiling (Article 22) — FL Marketing does not engage in automated decision-making
• Right to Withdraw Consent — where we process your data based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing
• Right to Lodge a Complaint — you have the right to lodge a complaint with your local data protection supervisory authority (e.g., the Irish DPC, the UK ICO, or another relevant authority in your member state)

10. Legal Basis for Processing (GDPR)

To the extent GDPR or UK GDPR applies to our processing of your personal information, we rely on the following lawful bases:

• Email inquiries and responses: Performance of a contract or pre-contractual steps at your request (Article 6(1)(b)), or our legitimate interest in responding to business inquiries (Article 6(1)(f)).
• Server log data: Our legitimate interest in maintaining the security, integrity, and operation of the Site (Article 6(1)(f)). We have balanced this interest against your privacy rights and concluded that routine server logging does not override those rights given its limited scope and short retention period.
• Legal compliance disclosures: Compliance with a legal obligation (Article 6(1)(c)).

We do not rely on consent as a lawful basis for any processing described in this policy. If we ever collect data based on consent in the future, we will update this section accordingly.

11. Do Not Track

Some browsers transmit "Do Not Track" (DNT) signals to websites. Our Site does not respond to browser-based DNT signals. However, because we do not engage in cross-site tracking, behavioral advertising, or third-party analytics on the Site, a DNT signal has no practical privacy impact on your visit.

As described in Section 6, we do honor Global Privacy Control (GPC) signals, which is the legally operative opt-out mechanism under California law and other applicable state privacy laws.

12. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. The Site is served over HTTPS (TLS encryption in transit).

No method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify affected individuals and any relevant authorities as required by applicable law. If you believe your information has been compromised, please contact us immediately at contact@flmarket.ing.

13. Children's Privacy

The Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children. We also do not knowingly collect or sell the personal information of minors under the age of 16. If you believe we have inadvertently collected information from a child under 13, please contact us at contact@flmarket.ing and we will delete such information promptly.

14. Third-Party Links

The Site may contain links to third-party websites or resources. We are not responsible for the privacy practices, content, or policies of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this policy and post the revised policy on the Site. For significant changes that materially affect your rights or how we use your information, we will provide additional notice as appropriate (such as by posting a notice on the Site homepage for a reasonable period).

Your continued use of the Site after the effective date of a revised policy constitutes your acceptance of the changes. We encourage you to review this policy periodically.

16. Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us:

FL Marketing, Inc.
Attn: Privacy
Address: 55 Cambridge Pkwy, Suite 800E, Cambridge, MA 02142, USA
Email: contact@flmarket.ing
Phone: (617) 868-1888

Disclaimer: This Privacy Policy is provided for informational purposes. It does not constitute legal advice. FL Marketing, Inc. recommends consulting with a qualified privacy attorney to confirm compliance with all applicable privacy laws and regulations. This policy reflects requirements as understood as of its effective date and may not capture all applicable laws or the most recent regulatory guidance.