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Privacy Policy

Last updated: 17 July 2026.

Last updated: 17 July 2026. This version supersedes the version effective 29 April 2026.

This privacy policy sets out how Value Chain Lab Ltd (the parent of the VCL group) and VCL Trading Europe Limited (a wholly-owned subsidiary) use and protect your personal data. The two companies act as separate data controllers for distinct processing activities, as explained in clause 1.2 below.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

  1. Important information and who we are

    1. Privacy policy. This privacy policy gives you information about how Value Chain Lab Ltd collects and uses your personal data through your use of this app or website, including any data you may provide when you register with us, sign up to our newsletter, purchase a product or service, take part in a competition or to receive other marketing materials from us such as brochures and eBooks. In this privacy policy references to "app" will be construed as including the "website" and vice versa. The FLOX Platform is intended for use in a business context only, by persons aged 18 or over. We do not knowingly collect personal data from children. If you are under 13 (the UK age of digital consent), you must not use this website or provide any personal data to us; if we become aware that we hold personal data collected from a child under 13 without parental consent, we will delete it promptly.
    2. Controllers. Two members of our group are separate controllers of the personal data processed in connection with the FLOX website and the FLOX Platform, each for distinct categories of processing:
      1. Value Chain Lab Ltd (company number 07980832; registered office Marlborough House, 298 Regents Park Road, London, United Kingdom, N3 2SZ) is the controller for personal data collected through website-visitor analytics, marketing activities, and the cookies and similar technologies described in our Cookie Policy. This includes data processed by Cookiebot, Google Analytics 4 and Apollo.io.
      2. VCL Trading Europe Limited (company number 07784688; VAT number GB288257261; registered office Marlborough House, 298 Regents Park Road, London, United Kingdom, N3 2SZ) is the controller for personal data collected and processed in connection with the operation of the FLOX Platform, including Account registration, Master Data, Orders, billing, dispute resolution and platform communications.
      In this Privacy Policy, "we", "us" and "our" refer to whichever entity is the controller for the relevant processing activity. Where a term applies to both, we use "the FLOX group". The two entities operate under an intra-group data-sharing arrangement and each is independently responsible for its own processing under UK data-protection law. Questions about either controller can be directed to the contact details in clause 10.
    3. Registration and oversight. The UK Information Commissioner's Office (ICO) is the UK supervisory authority for data-protection matters, and both Value Chain Lab Ltd and VCL Trading Europe Limited are subject to its oversight. You have the right to make a complaint to the ICO at any time (see clause 11). Neither controller is required to appoint a Data Protection Officer under Article 37 of the UK GDPR; data-protection enquiries should be sent to info@flox.is, which is monitored on behalf of both entities.

  2. The types of personal data we collect about you

    1. Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      1. Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
      2. Contact Data includes billing address, delivery address, email address and telephone numbers.
      3. Financial Data includes bank account and payment card details.
      4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
      5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
      6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
      7. Usage Data includes information about how you interact with and use our website, products and services.
      8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    2. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

  3. How is your personal data collected?

    1. We use different methods to collect data from and about you including through:
    2. Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; post materials on our app or website; create an account on our app or website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us.
    3. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
    4. Technical Data is collected from analytics providers such as Google based outside the UK. Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe and Yapily based inside the UK. Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

  4. How we use your personal data

    1. Legal basis. The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
      1. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
      2. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
      3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
      4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
    2. Purposes for which we will use your personal data. We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
    3. Purpose/Use Type of data Legal basis
      To register you as a new customer (a) Identity
      (b) Contact      		 Performance of a contract with you. We must be able to identify and contact you to perform our obligations.
      To process and deliver your order including:
      (a) Manage payments, fees and charges, including exchanging data with External Third Parties who are providers of technical, payment and delivery services such as Stripe and Yapily, based inside the UK.
      (b) Collect and recover money owed to us      		 (a) Identity
      (b) Contact
      (c) Financial
      (d) Transaction
      (e) Marketing and Communications      		 (a) Performance of a contract with you.
      (b) Necessary for our legitimate interests (to recover debts due to us).
      To manage our relationship with you which will include:
      (a) Notifying you about changes to our terms or privacy policy
      (b) Dealing with your requests, complaints and queries      		 (a) Identity
      (b) Contact
      (c) Profile
      (d) Marketing and Communications      		 (a) Performance of a contract with you.
      (b) Necessary to comply with a legal obligation.
      (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you.
      To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
      (b) Contact
      (c) Technical      		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
      (b) Necessary to comply with a legal obligation.
      To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
      (b) Contact
      (c) Profile
      (d) Usage
      (e) Marketing and Communications
      (f) Technical      		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
      To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing (a) Technical
      (b) Usage      		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
      To carry out market research through your voluntary participation in surveys — Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
      AI-assisted features (Holly and Wingman) identity and business contact data of account users, content and data fragments you submit to or process with AI features, usage data performance of our contract with your organisation and our legitimate interests in providing and improving the platform. See AI providers entry and retention note.
      Dispute resolution administration identity and business contact data of party representatives, dispute submissions and records performance of contract and legitimate interests. Retained 6 years from conclusion of the dispute.
    4. Direct marketing. You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving the marketing. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
    5. Third-party marketing. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
    6. Opting out of marketing. You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication we send you. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, updates to our Terms and Conditions, checking that your contact details are correct.
    7. Cookies. For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.
    8. Our AI features assist registered users with matching, pricing and operational suggestions in private, bilateral interactions between accounts. They do not make automated decisions producing legal or similarly significant effects about any individual: every action affecting a counterparty or an individual (including any pricing, matching or account action) is reviewed and actioned by a registered human user with the relevant permissions. Public prices, rankings and search results on our site are not AI-determined.

  5. Disclosures of your personal data

    1. We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
    2. Internal members of our group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
    3. External Third Parties if either Value Chain Lab Ltd or VCL Trading Europe Limited is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce our Website Terms of Use, Platform Terms, Acceptable Use Policy or any other agreement, or to protect the rights, property or safety of either controller, our users or others. The principal categories of External Third Parties to whom your personal data may be disclosed are:
      1. Payment processors — Stripe Payments UK Limited (UK) for card processing;
      2. Open Banking providers — Yapily Connect Limited (UK);
      3. Customer-relationship management — HubSpot Ireland Limited (Republic of Ireland), engaged by Value Chain Lab Ltd;
      4. Analytics — Google Ireland Limited (Republic of Ireland), with onward transfer to Google LLC (USA), engaged by Value Chain Lab Ltd;
      5. Hosting and infrastructure — Google Cloud EMEA Limited (Republic of Ireland), engaged by VCL Trading Europe Limited. Google Cloud also hosts and processes AI model inference for our AI features on UK-region endpoints under the Google Cloud Data Processing Addendum, using Anthropic Claude models made available through Google Cloud; neither Google nor Anthropic is permitted to train models on content submitted through our services;
      6. Identity and access management — FusionAuth Inc. (USA), engaged by VCL Trading Europe Limited;
      7. Notifications — Novu Co., engaged by VCL Trading Europe Limited;
      8. AI services — Anthropic Ireland Limited (Republic of Ireland) and Anthropic PBC (USA), engaged by VCL Trading Europe Limited.
    4. Analytics and website-visitor identification. Value Chain Lab Ltd uses Google Analytics 4 (GA4), with a contract held by Google Ireland Limited as processor and Google LLC (USA) as sub-processor under the EU-US Data Privacy Framework and UK IDTA / EU SCCs. GA4 is set only after consent to Statistics cookies via Cookiebot. Value Chain Lab Ltd also uses Apollo.io (provided by ZenLeads, Inc. (USA), an independent controller) for B2B website-visitor identification; Apollo.io identifies the company (rather than the individual) and is set only after consent to Marketing cookies via Cookiebot. Visitor insights are shared by Value Chain Lab Ltd with VCL Trading Europe Limited for FLOX-related sales follow-up. Further information is in the Cookie Policy.
    5. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
    6. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  6. International transfers

    1. We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer your personal data out of the UK to service providers, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy to ensure a similar degree of protection is afforded. We rely on the UK International Data Transfer Addendum (UK IDTA) and / or EU Standard Contractual Clauses (SCCs) for transfers to non-adequate jurisdictions. Specifically: transfers to Google LLC (USA, GA4 sub-processor) are protected by the UK IDTA / EU SCCs and the EU-US Data Privacy Framework; transfers to ZenLeads Inc (USA, Apollo.io) are protected by the UK IDTA / EU SCCs and the EU-US Data Privacy Framework; Cybot A/S (Cookiebot, Denmark) is in the EU and benefits from the UK adequacy decision in respect of the EU.

  7. Data security

    1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  8. Data retention

    1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    2. 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 unauthorised 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.
    3. By law we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers. In some circumstances you can ask us to delete your data: see paragraph 10 below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
    4. Content submitted to AI features is retained by us as part of your account records in line with this policy; our AI providers are not permitted to retain it beyond the transient processing needed to generate responses, and do not use it to train their models.

  9. Contact details

    1. You can contact us in any of the following ways. The same contact channels reach both controllers and your message will be routed to the right team.
      1. Email (general, including data-protection / subject rights): info@flox.is
      2. Email (account, security, abuse): support@flox.is
      3. Postal address: Value Chain Lab Ltd / VCL Trading Europe Limited (please indicate the entity, where relevant), Marlborough House, 298 Regents Park Road, London, United Kingdom, N3 2SZ
      4. Telephone: +44 (0)20 8150 1623

  10. Complaints

    1. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  11. Changes to the privacy policy and your duty to inform us of changes

    1. We keep our privacy policy under regular review. The current version is always available at https://www.flox.is/privacy-policy. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.