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Personal data processing policy

Release date: 25 October 2023

TERMS AND DEFINITIONS

Policy means this document posted on the Internet at https://flowwow.co.uk/en/docs/personal-data.

Personal Data means any information relating to the data subject.

Data Subject means an identified or identifiable natural person (a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).

Processing means any action (operation) or set of actions (operations) which is performed on personal data, whether or not by automated means, including collection, recording, organization, structuring, accumulation, storage, adaptation or alteration, uploading, viewing, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Company means FLOWWOW Kft., a legal entity established and existing under the laws of Hungary, registered under No. 01-09-398308 and located at 16 Paulay Ede Street, Budapest, 1061 Hungary.

Service means all pages of the website available at https://flowwow.co.uk/, as well as mobile applications operated by the Company.

User means a Data Subject who has provided his/her Personal Data to the Company in relation to (1) the use of the Service, and/or (2) the receipt or provision of services via the Service.

Seller means a User selling products via the Service.

Purchaser means a User purchasing products via the Service for personal non-commercial use.

Recipient means a Data Subject designated by the Purchaser as the recipient of the product, in cases where the Purchaser is not the recipient of the products.

А. CONTACTS

01. Should you have any inquiries, comments, or suggestions related to the Policy, please contact us at hu@flowwow.es.

1. SUBJECT MATTER. APPLICATION

1.1. This Policy defines the procedure for processing and protecting Personal Data by the Company (the “Company”, “Flowwow”, “we”, “us”, “our”), which is received (collected) by the Company from the Data Subjects (“you”, “your”): (1) when you use the Service, (2) when we provide services to you or you provide services to us, as well as in relation to: (3) the activities carried out in accordance with the Company’s constituent documents, (4) entering into and performance any contracts and agreements, to which either the Company or the Data Subject is a party, (5) exercising rights and performing obligations arising out of the employment relationships involving the Company, (6) in other cases as stipulated by the applicable laws of Hungary or other regulations governing the processing of Personal Data, or by this Policy.

1.2. The Policy shall apply: 

(1) to the Data Subjects (see Appendix 02 to the Policy for more details);

(2) to other persons, if their participation is required for the processing of Personal Data in case of transmitting the Personal Data by the Company to the counterparties under the orders for personal data processing, other agreements and contracts (see Section 5 of the Policy for more details); 

(3) irrespective of where we store or process your Personal Data.

2. WHAT PERSONAL DATA WE COLLECT AND PROCESS

2.1. We collect and process the following categories of Personal Data: 

(1) Provided data: Data you provide to us. You provide the data when signing up for the Service, fill out forms within the Service, or communicate with us via email, phone, messengers, or social media. When you write to us or call us, we keep a record of such messages.

(2) Usage data: Data we collect automatically. We automatically collect specific information when you visit, use, or navigate through the Service.

(3) Third-party data: Data we collect from third parties. We may receive data on you from other sources, including third parties, which help us to update, expand and analyze our available data; to prevent or detect fraud; to process payments; or to analyze your usage of the Service.

See Appendix 01 to the Policy for more details on the Personal Data we collect and process for each category of the Personal Data.

3. PROCESSING OF PERSONAL DATA. PURPOSES AND LEGAL GROUNDS

3.1. We process Personal Data for (1) ensuring the proper functioning of the Service, including where we provide services to you and/or you provide services to us, (2) entering into and performing the existing contracts and agreements, (3) in cases provided by the applicable laws of Hungary or other regulations governing the processing of Personal Data, and (4) for other purposes.

3.2. We process Personal Data on the following legal grounds:

(1) Consent: We process your Personal Data with your express consent to the processing of the Personal Data for a specific purpose.

(2) Legitimate Interests: We process your Personal Data to the extent reasonably required for meeting our legitimate business interests.

(3) Contract performance: We process your Personal Data where it is required to perform the terms and conditions of our contract you have entered into with us.

(4) Legal obligations: We process your Personal Data where it is required by law to comply with the applicable laws, government requests, in the course of a court proceeding, in accordance with court rulings, or in the course of a legal process, e.g., in response to a court ruling or subpoena (including in response to the requests of the public authorities for compliance with the national security or law enforcement requirements).

See Appendix 03 to the Policy for a list of specific purposes of the Personal Data processing, the legal grounds for such processing, and the categories of the processed Personal Data.

4. RIGHTS OF THE DATA SUBJECTS

4.1. The Data Subjects shall have the rights, including (1) the right to access, (2) the right to data rectification, (3) the right to data erasure (the right to be forgotten), (4) the right to restrict processing, (5) the right to data portability, (6) the right to object, as well as (7) other rights stipulated by the applicable laws of Hungary or other regulations governing the processing of Personal Data, or by the Policy.

4.2. The Data Subjects or their representatives may exercise their rights by submitting a request using the details specified in Section A. of the Policy, or in any other manner provided by the Policy.

4.3. If we are unable to identify the Data Subject, who has submitted the request, we may request additional information that may help us to identify the Data Subject, e.g., information confirming the relationship between the Data Subject and the Company (contract number and date, other details), or information otherwise confirming that the Company has processed the Personal Data of the Data Subject. 

4.4. We may reject a request if it is provided or required by the laws of Hungary or by the legislative requirements that third parties, we cooperate with must comply with. The reasons for rejection will be stated in our response.

4.5. You may file a complaint against our rejection with the local supervisory authority for data protection. 

See Appendix 04 to the Policy for the complete list of rights of the Data Subjects and scope thereof.

5. PROVISION (DISCLOSURE) OF PERSONAL DATA TO THIRD PARTIES

5.1. We provide (disclose) Personal Data to third parties provided they are: (1) the competent authorities, (2) the Sellers, (3) the providers, including partners, contractors or agents providing services to us or on our behalf and requiring access to such information to perform their obligations, and (4) the purchasers of the Company’s business/assets.

5.2. By accepting the Policy and providing us with your Personal Data, you give your consent to such provision (disclosure) of the Personal Data. If you do not consent to such provision (disclosure) of the Personal Data, you will be unable to use the Service.

See Appendix 05 of the Policy for the list of third parties, to which we provide (disclose) the Personal Data, the categories of the provided Personal Data, and the specifics of processing such Personal Data by third parties.

6. STORAGE OF PERSONAL DATA

6.1. We store your Personal Data for the periods specified in Appendix 06 to the Policy. The applicable laws of Hungary or other regulations governing the processing of Personal Data may provide for a longer storage period.

7. TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES

7.1. The countries, to which we or third parties we cooperate with transfer your Personal Data, may not have data protection laws equivalent to those in your jurisdiction. In such cases, we take appropriate safeguards as stipulated by the applicable laws to ensure your data is adequately protected during its transfer outside your jurisdiction.

7.2. By accepting the Policy and providing us with your Personal Data, you give your consent to such transfer. If you do not consent to such transfer of the Personal Data, you will be unable to use the Service.

7.3. If your jurisdiction is the European Economic Area (EEA), we may transfer your data outside the EEA in order to perform a contract/agreement entered into with you. During such data transfer, we (1) meet our legal and regulatory obligations; (2) take appropriate precautions, such as abiding by the standard contractual clauses on protection of Personal Data. We will undertake all reasonable steps to ensure your data is securely processed in compliance with the Policy.

8. PERSONAL DATA OF MINORS

8.1. The Service is designed for a broad audience and may be used by the minors. The minors may access certain public features of the Service and its content without having to provide us with the Personal Data. However, the minors wishing to access all the content and functionality of the Service must sign up. Signing up involves collection of certain Personal Data. We may ask you to provide us with the information and documents proving your age. If you are a minor, we may ask you to provide us with the documents proving the emancipation from parents or the legal consent of your parent or other legal representative.

8.2. In addition, we use certain technologies, such as cookies (Section 1 1. of the Policy) to automatically collect information on our Users (Purchasers) (including minors) when they visit or use the Service. We collect, process, store and disclose the data of minors in the manner provided by the Policy.

If you are a parent or other legal representative of a child, and you became aware that your child has provided us with the Personal Data, please contact us at the address specified in Section A. of the Policy.

9. PROTECTION OF PERSONAL DATA

9.1. We use appropriate physical, electronic, managerial and technical safeguards to ensure the security of all Personal Data that we process. However, we cannot ensure or guarantee the complete (absolute) security of your Personal Data that you transfer to the Service. Despite the fact that we do our best to protect your Personal Data, you should act responsibly while transferring your Personal Data to the Service. Please use the Service only in a secure environment: in particular, use firewalls, choose a provider that encrypts traffic, etc.

10. AUTOMATED DECISION-MAKING

10.1. We do not use automated decision-making processes, including creation of User profiles, that rely on the Personal Data.

11. USE OF COOKIES AND SIMILAR TECHNOLOGIES

11.1. See our Cookie Policy to learn more about how we use cookies and similar technologies, and how you can control and/or opt out of such technologies.

 

12. AMENDMENTS

12.1. We may amend the Policy at any time. Any amendments we make to the Policy shall become effective upon release of the revised Policy. Every new version shall supersede any prior version of the Policy. We advise you to frequently review the Policy to stay informed about how we collect, process, and protect your Personal Data.

 

Appendix

to the Personal Data Processing Policy

CATEGORIES OF COLLECTED AND PROCESSED PERSONAL DATA

Provided data:

Data type

Data processed

Information required for interaction

Name, contact phone number, and/or email address

Contact and personal data

Name, date of birth, language of communication, contact phone number, email address, delivery address, which could be your home and/or work address

Identity card details

Copies of identification documents such as passport, citizen identity card, driver’s license; documents proving age; details of such documents: full name (surname, name, patronymic, if any), series, number, gender, citizenship (nationality), date and place of birth, date and place of issue, issuing authority, and expiration date (if any)

Financial information

Bank account and payment method details (upon request, e.g. for payment or refund purposes)

Service account data

Username, password, account settings and preferences, User-generated content in the account

Seller’s data

Full name (surname, name, patronymic, if any), identification document details: series, number, gender, citizenship (nationality), date and place of birth, date and place of issue, issuing authority, expiration date (if any); language of communication, picture (photograph); registration address, actual residence address, contact phone number, email address, taxpayer identification number (or equivalent)

Data of Flowwow current or former employees

Full name (surname, name, patronymic, if any), identification document details: series, number, gender, citizenship (nationality), date and place of birth, date and place of issue, issuing authority, expiration date (if any), picture (photograph); registration address, actual residence address, contact phone number, email address, taxpayer identification number (or equivalent), bank details, education background, qualifications, professional training and advanced training, marital status, children and relatives, employment history including recognition, rewards and/or disciplinary sanctions, marriage registration data, other data provided by the employee in accordance with the applicable laws

Data of candidates for Flowwow vacancies

Full name (surname, name, patronymic, if any), place of residence, contact phone number, email address, education background, employment history and qualifications, other data provided by the candidates in their CVs and cover letters

Data of natural persons who have or had civil-law relations with Flowwow

Full name (surname, name, patronymic, if any), identification document details: series, number, gender, citizenship (nationality), date and place of birth, date and place of issue, issuing authority, expiration date (if any), picture (photograph), registration address, actual residence address, contact phone number, email address, taxpayer identification number (or equivalent), bank details

Data of representatives/employees of Flowwow counterparties

Full name (surname, name, patronymic, if any), office phone number, office email address, employer’s name and location, position/title held

Additional information

Information on opening emails and following links contained therein; recorded phone conversations, saved correspondence

Information on a minor

Full name (surname, name, patronymic, if any), data provided in the consent or request

Usage data

Log and usage data

Information on the systems and devices used to access the Service, including the IP address, type and version of the operating system, type, version and settings of the browser, language preferences, time zone configurations, type and identifiers of devices; 

information on the mobile network, mobile operating system, type and version of the mobile browser, current location, geolocation, URL links; 

usage information: for example, time of logging into and out of the Service, on pages visited and features used, technical information provided within the Service, such as Internet connection speed; 

information on Service visits, including the full URL address of navigations to, through and from the sites (including date and time), information on device events (like system activity, error reports, and hardware settings); 

information on mobile application usage, including information viewed in our mobile applications, along with the date and time of viewing; 

information for easing the usage of the Service (including for granting access to third-party websites and services), such as URL requests, destination IP addresses, or information on device configuration; 

pages viewed or searched for, page response time, loading errors, duration of page visits, information on interaction with the page (scrolling, clicks and rollover), interaction with specific variable/dynamic elements of the page and methods used to navigate from the page; 

unique identifiers assigned to the Data Subject for providing Service functionality.

Information retrieved from IT systems

Information from access systems/logs (for example, during the office visits), automatic monitoring systems of our websites and technical systems, such as our computer networks and connections, video surveillance and access control systems, communication systems, email and instant messaging systems

Information collected through cookies and similar technologies

Information on usage of cookies and similar technologies is available in Section 11 of the Policy.

Third-party data

Third-party services

We collect information via third-party services, including Google Ads, Google Analytics, Firebase, Adjust, for presenting targeted advertising, personalized content, and analytics.

Information we collect from other sources

Information from third parties that helps us to combat fraud, provide services, or relates to your interactions, including your communication with the individuals, organizations, potential Users, and other stakeholders, which was obtained from the companies that collect combined information and share it with us Information from the companies we have acquired

 

 

Appendix 02

to the Personal Data Processing Policy

DATA SUBJECTS. PROCESSED PERSONAL DATA OF DATA SUBJECTS

Data Subjects

Processed Personal Data

Purchasers, including minors

(1) Provided data: Contact and personal data, financial information (upon request), Service account data, additional information, information on a minor if the Purchaser is underage

(2) Usage data

(3) Third-party data

Sellers

(1) Provided data: Seller’s data, financial information, Service account data, additional information

(2) Usage data

(3) Third-party data

Recipients

(1) Provided data: Contact and personal data, additional information

Potential Users (you sign up for the Service but do not use it thereafter)

(1) Provided data: Contact and personal data, Service account data, additional information, information on a minor if a potential User (Purchaser) is underage

(2) Usage data

(3) Third-party data

Flowwow current or former employees

(1) Provided data: Data of the Flowwow current or former employees

Candidates for Flowwow vacancies

(1) Provided data: Data of the candidates for Flowwow vacancies

Natural persons who have or had civil-law relations with Flowwow

(1) Provided data: Data of the natural persons who have or had civil-law relations with Flowwow

Representatives or employees of Flowwow counterparties

(1) Provided data: Data of the representatives/employees of Flowwow counterparties

Members of loyalty programs

(1) Provided data: Contact and personal data, financial information (upon request), Service account data, additional information, information on a minor if the Purchaser is underage

(2) Usage data

(3) Third-party data

Parents of minors

Provided data: Information on a minor

Flowwow shareholders and founders

(1) Provided data: Contact and personal data, identity card details

Natural persons who have reached out to Flowwow with inquiries, communications, applications, complaints, suggestions using contact information or feedback tools

(1) Provided data: Contact and personal data, and, in rare cases, identity card details

Natural persons involved in the interviews, surveys, analytical and marketing studies related to Flowwow operations

(1) Provided data: Information required for interaction

Visitors to the Flowwow office spaces

(1) Provided data: Information required for interaction

 

 

Appendix 03

to the Personal Data Processing Policy

PROCESSING OF PERSONAL DATA. PURPOSES AND LEGAL GROUNDS. CATEGORIES OF PERSONAL DATA

Usage purpose

Data category

Legal ground

Creation (registration), maintenance and management of a Service account. Registration and further signing in the Service, including implementation of seamless authorization features. Identification of the account in automated management systems, such as CRM. Sending informational messages and push notifications related to the Service operation (service notifications)

Provided Data, Usage Data

Contract performance

Entering into contracts with the Users. Performance of terms and conditions of the contracts entered into with the Users, including provision of services, payment of services/orders, order fulfilment and management, provision of data to third parties for order fulfilment, communication during the order fulfillment (providing information on order status, responding to inquiries, complaints, providing support)

Provided data

Contract performance

Membership in loyalty programs 

Provided data, Usage data, Third-party data

Contract performance

Exercising of rights and performance of obligations arising out of employment relationships

Provided data

Contract performance and legal obligations

Sending promotional/marketing messages. Presenting targeted advertising using cookies and similar technologies 

Provided data, Usage data, Third-party data

Consent

Holding promotional/marketing events

Provided data

Consent

Sending information on amendments in terms and conditions, policies, agreements

Provided data

Legitimate interests

Sending information on new products/services/features

Provided data

Legitimate interests

Searching and selecting candidates for Flowwow vacancies

Provided data

Legitimate interests

Conducting researches and surveys. Requesting and posting feedback

Provided data

Legitimate interest

Developing new features, creating new products/services and offers

Provided data, Usage data

Legitimate interests

Collecting, processing and presenting statistical data and other research based on the anonymized Personal Data

Provided data, Usage data, Third-party data

Legitimate interests

Entering into, performing and terminating civil-law contracts with third parties

Provided data

Legitimate interests

Carrying out activities provided for by the Flowwow constituent documents

Provided data

Legitimate interests

Preventing misconduct, specifically fraud. Enhancing methods for combating fraud

Provided data, Usage data, Third-party data

Legitimate interests

(1) Assessment and improvement of service quality

(2) Identification and prevention of technical issues within the Service

(3) Management of the Service in terms of internal operations, including fault searching and correction, data analysis, testing, research, statistics and surveys

(4) Ensuring optimal performance of the Service 

(5) Maintenance of security and robustness of the Service

Provided data, Usage data, Third-party data

Legitimate interests

(1) Providing responses during legal, regulatory, and arbitration proceedings

(2) Responding to the information requests received from the public authorities or other third parties

(3) Preventing damage in accordance with the laws

Provided data, Usage data

Legal obligations

 

Appendix 04

to the Personal Data Processing Policy

RIGHTS OF THE DATA SUBJECTS

Right

You may

How to exercise your rights

Access to Personal Data

(1) Obtain confirmation on whether your Personal Data are processed by us;

(2) Obtain access to your Personal Data along with the information on how we use your Personal Data.

Please contact us at the address specified in Section A. of the Policy.

Rectify incorrect data

Demand correction of any incomplete or incorrect Personal Data concerning you.

Please contact us at the address specified in Section A. of the Policy.

Object to processing

Object to processing of your Personal Data if we process them in our legitimate interests.

Please contact us at the address specified in Section A. of the Policy.

Demand to make data portable

Under specific circumstances, demand that we provide you with a copy of your Personal Data in a structured, widely-accepted and machine-readable format.

Please contact us at the address specified in Section A. of the Policy.

Erase data

Under specific circumstances, demand us to erase your Personal Data. For example, if they are no longer necessary to us or you revoke your consent that served as a basis for data processing.

Use your account features to erase your Personal Data. Using the features of your account, you may opt out of receiving promotional/marketing emails. Alternatively, please contact us at the address specified in Section A. of the Policy.

Revoke consent to data processing

Revoke consent to processing of your Personal Data.

Please contact us at the address specified in Section A. of the Policy.

Restrict processing

Request the restriction or termination of collection, use, processing, and/or disclosure of your Personal Data.

Please contact us at the address specified in Section A. of the Policy.

Revoke consent to receiving advertising/marketing messages and targeted advertising.

Opt-out of receiving promotional mailings.

Follow the unsubscribe link in any of our promotional emails. Opt out of targeted advertising by refusing the use of cookies as provided for in Section 11. of the Policy. Alternatively, please contact us at the address specified in Section A. of the Policy.

Be informed about the precautions we take when transferring Personal Data to third countries or international organizations.

Ask us about those precautions.

Please contact us at the address specified in Section A. of the Policy.

File complaints.

File a complaint with the authority overseeing compliance with the personal data protection laws regarding our collection and use of your Personal Data.

Please contact your local supervisory authority.

 

Appendix 05

to the Personal Data Processing Policy

THIRD PARTIES TO WHICH WE PROVIDE (DISCLOSE) PERSONAL DATA

1. Competent authorities

1.1. We transfer and disclose Provided Data, Usage Data, and Third-Party Data. Personal Data is provided upon request and in compliance with the applicable laws.

2. Sellers

2.1. We transfer and disclose the Purchasers’ Provided Data for the Seller to perform their contractual obligations to the Purchasers.

3. Providers

3.1. Payment acceptance and invoicing service providers.

3.1.1. We only transfer and disclose Provided Data to mentioned providers upon their request. If you do not engage services of the payment acceptance and invoicing service providers within the Service, we will not share Provided Data with them.

3.1.2. We neither collect nor store your credit card information. You provide such information to our payment acceptance and invoicing service providers. The way they use the Provided Data for payment acceptance is governed by their privacy policy.

Service

Provider

Usage purpose

Where to find the Service Privacy Policy (if available)

Stripe

Stripe, Inc., Address: 354 Oyster Point Boulevard, South San Francisco, CA 94080, United States

Payment acceptance

https://stripe.com/privacy

Raiffeisen Bank

Raiffeisen Bank Zrt., Address: Hungary, 1133 Budapest, Váci út 116-118.

Payment sending

https://www.raiffeisen.hu/raiffeisen-csoport/raiffeisen-bank-zrt/jogi-nyilatkozatok/adatkezelesi-tajekoztato

Zen.com

UAB “ZEN.COM”, Address: Lvivo g. 25-104, LT-09320, Vilnius, Republic of Lithuania

Payment sending

https://www.zen.com/privacy-policy/

Revolut Business

Revolut Ltd. 7 Westferry Circus, Canary Wharf, London, England, E14 4HD

Payment sending

https://www.revolut.com/privacy-policy/

Szamlazz

KBOSS.hu Kft., 1031 Budapest, Záhony utca 7/D

Invoicing

https://www.szamlazz.hu/szamla/

3.2. Data storage service providers.

3.2.1. We store Provided Data, Usage Data and Third-Party Data at the Amazon Web Services Data Processing Center (Frankfurt, Germany):

Service

Provider

Usage purpose

Where to find the Service Privacy Policy (if available)

Amazon Web Services

Amazon Web Services EMEA SARL, Address: 38 Avenue John F. Kennedy, L-1855, Luxembourg.

Data storage

https://aws.amazon.com/ru/privacy/

3.3. Telecommunication service provider.

3.3.1. We transfer and disclose Provided Data to the Telecommunication Service Providers.

Service

Provider

Usage purpose

Where to find the Service Privacy Policy (if available)

SMS Works

SMS Works Ltd., Address: St Brandon’s House, 29, Great George Street, Bristol, BS1 5QT.

Service text messaging

https://thesmsworks.co.uk/privacy

Mensagia

Sinergyne Global Communications, SL, Address: Plaça del Marquès de Camps, 17, 17001 Girona.

Service text messaging

https://mensagia.com/legal#privacidad

Twilio MessagingX

Twilio Ireland Limited, Address: 3 Dublin Landings, North Wall Quay, Dublin 1, Ireland.

Service text messaging

https://www.twilio.com/legal/privacy

Voximplant

Voximplant Inc., Address: 150 West 25th Street, RM 403 New York, NY 10001, United States of America.

Service voice messaging

https://voximplant.com/legal/privacy

GetResponse

JSC GetResponse, Gdansk (80-309), Grunwaldzka 413 

Email sending

https://www.getresponse.com/legal/privacy

3.4. Advertising platforms and applications:

3.4.1. We transfer and disclose the Usage Data. The advertising platforms we use enable us to optimize and present ads based on the Service usage data, i.e., by tracking Usage Data, including cookies.

Platform

Google Ads

Usage purpose

(1) Tracking actions of the Users (Purchasers) after being redirected to the Service by clicking an advertising link on Google;

(2) Measuring the performance of Google ads for market research and statistics gathering purposes, specifically to better understand and display ads, making them more relevant to the Users (Purchasers).

Who stores and processes data

Google LLC, Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States.

Where to find the Service Privacy Policy (if available)

https://policies.google.com/privacy

How you can opt out

According to the instructions available at https://policies.google.com/technologies/ads under the How You Can Control Advertising Cookies section.

Platform

Yandex Direct

Usage purpose

(1) Tracking actions of the Users (Purchasers) after being redirected to the Service by clicking an advertising on Yandex;

(2) Measuring the performance of Yandex.Direct for market research and statistics gathering purposes, specifically to better understand and display ads, making them more relevant to the Users (Purchasers).

Who stores and processes data

Global DC Oy, Address: Moreenikatu 6, 04600 Mäntsälä, Finland.

Where to find the Service Privacy Policy (if available)

https://yandex.ru/legal/confidential/

How you can opt out

Via your Yandex account settings

3.5. Marketing and analytics platforms.

3.5.1. We transfer and disclose the Usage Data, including cookies, for web and mobile analytics purposes, as well as to customize content within the Service: for example, to offer you not all but only those of our services that might provoke your interest.

Platform

Google Analytics; Firebase

Usage purpose

(1) Tracking the Service traffic and the behavior of Users (Purchasers) within the Service;

(2) Analyzing usage of the Service by the Users (Purchasers) for enhancing its performance and managing advertising placement in line with their interests and preferences.

Who stores and processes data

Google LLC, Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States.

Where to find the Service Privacy Policy (if available)

https://policies.google.com/privacy

How you can opt out

(1) For Google Analytics: by installing the browser plugin: https://tools.google.com/dlpage/gaoptout

(2) For Firebase: by adjusting device settings, such as mobile advertising settings.

Platform

BigQuery

Usage purpose

Data analysis, storage, consolidation.

Who stores and processes data

Google Cloud EMEA Limited, Address: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland.

Where to find the Service Privacy Policy (if available)

https://cloud.google.com/terms/cloud-privacy-notice 

How you can opt out

Follow the instructions available at https://cloud.google.com/support/docs/close-account#delete_project 

Platform

Adjust

Usage purpose

(1) Tracking the Service traffic and the behavior of Users (Purchasers) within the Service;

(2) Analyzing usage of the Service by the Users (Purchasers) for enhancing its performance and managing advertising placement in line with their interests and preferences.

Who stores and processes data

Adjust GmbH, Address: Saarbrücker Str. 37A, 10405 Berlin, Germany.

Where to find the Service Privacy Policy (if available)

https://www.adjust.com/terms/privacy-policy/

How you can opt out

https://www.adjust.com/forget-device/

Platform

Yandex.Metrica

Usage purpose

(1) Tracking the Service traffic and the behavior of Users (Purchasers) within the Service;

(2) Analyzing usage of the Service by the Users (Purchasers) for enhancing its performance and managing advertising placement in line with their interests and preferences.

Who stores and processes data

Global DC Oy, Address: Moreenikatu 6, 04600 Mäntsälä, Finland.

Where to find the Service Privacy Policy (if available)

https://yandex.ru/legal/confidential/

How you can opt out

By installing the browser plugin available at https://yandex.com/support/metrica/general/opt-out.html

Platform

Appsflyer

Usage purpose

(1) Tracking the Service traffic and the behavior of Users (Purchasers) within the Service;

(2) Analyzing usage of the Service by the Users (Purchasers) for enhancing its performance and managing advertising placement in line with their interests and preferences.

Who stores and processes data

AppsFlyer Germany GmbH Kurfürstendamm 11, c/o WeWork, 10719 Berlin, Germany

Where to find the Service Privacy Policy (if available)

https://www.appsflyer.com/legal/services-privacy-policy/ 

How you can opt out

https://www.appsflyer.com/legal/opt-out/ 

Platform

Meta Pixel

Usage purpose

(1) Tracking the Service traffic and the behavior of Users (Purchasers) within the Service;

(2) Analyzing usage of the Service by the Users (Purchasers) for enhancing its performance and managing advertising placement in line with their interests and preferences.

Who stores and processes data

Described at https://www.facebook.com/about/privacy 

Where to find the Service Privacy Policy (if available)

https://www.facebook.com/about/privacy 

How you can opt out

Described at  https://www.facebook.com/about/privacy

3.6. Review aggregators. We transfer Provided Data for the purpose of requesting reviews related to the operation of the Service.

Platform

Trustpilot

Usage purpose

Sending emails inviting recipients to review the operation of the Service

Who stores and processes data

Trustpilot A/S, Pilestraede 58, 5th floor, 1112 Copenhagen K, Denmark
CVR no.: 30276582.

Where to find the Service Privacy Policy (if available).

https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms

How you can opt out

By sending an email to privacy@trustpilot.com or by following the ‘unsubscribe’ link in emails received

Platform

Typeform

Usage purpose

Request for feedback on the Service

Who stores and processes data

TYPEFORM SL, C/ Can Rabia 3-5, 4th floor, 08017 – Barcelona

Where to find the Privacy Policy (if available)

https://www.typeform.com

How you can opt out

https://www.typeform.com/help/a/right-to-rectification-360029665671/

4. Purchasers of the Flowwow business/assets.

4.1. We transfer and disclose the Provided and Usage Data in relation to any merger, acquisition, sale of the Flowwow assets, financing, or purchase of all or a portion of the Flowwow business/assets by another company, or in course of negotiation regarding any of the above.

5. Affiliated companies

5.1. We transfer and disclose the Provided Data, Usage Data, and Third-Party Data to the affiliated companies to the extent required for achieving the objectives outlined in the Policy. 

6. Other suppliers and partners. We may transfer and disclose Provided Data, Usage Data, and Third-Party Data to other suppliers and partners with which we enter into agreements for the purposes set out in the Privacy Policy.

 

Appendix 06

to the Personal Data Processing Policy

STORAGE PERIOD OF PERSONAL DATA

Data Subjects

Storage period of Personal Data

Purchasers, including minors

Throughout the entire period of the Service usage and for 96 months following the most recent use of the Service or the completion of the most recent order, whichever comes later.

Sellers

Throughout the entire period of the Service usage and for 96 months following the most recent use of the Service or the completion of the most recent order, whichever comes later.

Recipients

96 months after the completion of the most recent order

Potential Users (you sign up for the Service but do not use it thereafter)

96 months after the signing up for the Service

Flowwow current or former employees

Term of the employment contract, and for 96 months after its termination, unless the laws of Hungary provide for a longer period

Candidates for Flowwow vacancies

For 96 months after the receipt

Natural persons who have or had civil-law relations with Flowwow

Term of the contract, and for 96 months after its termination, unless the laws of Hungary provide for a longer period

Representatives or employees of Flowwow counterparties

Term of the contract, and for 96 months after its termination

Members of loyalty programs

96 months after the termination of membership in the loyalty program

Parents of minors

Symmetrical to the minor’s data storage period

Flowwow shareholders and founders

Throughout the term of being a shareholder/founder, and for 96 months after the cessation

Natural persons who have reached out to Flowwow with inquiries, communications, applications, complaints, suggestions using contact information or feedback tools

96 months after the cessation of communication with such a person

Natural persons involved in the interviews, surveys, analytical and marketing studies related to Flowwow operations

96 months after the receipt

Visitors to the Flowwow office spaces

96 months after the receipt


 

Previous version of the document: https://flowwow.com/en/docs/personal-data_en-till-24-10-23/