Release date: 25 October 2023
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.
01. Should you have any inquiries, comments, or suggestions related to the Policy, please contact us at hu@flowwow.es.
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.
2.1. 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.
3.1. 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.
4.1. 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.
6.1. 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.
7.1. 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.
8.1. 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.
9.1. 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.
10.1. We do not use automated decision-making processes, including creation of User profiles, that rely on the Personal Data.
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.
12.1. 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
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 |
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
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
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
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 |
|
Raiffeisen Bank |
Raiffeisen Bank Zrt., Address: Hungary, 1133 Budapest, Váci út 116-118. |
Payment sending |
|
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 |
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) |
|
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) |
|
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) |
|
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) |
|
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) |
|
How you can opt out |
|
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) |
|
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) |
|
How you can 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) |
|
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 |
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) |
|
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
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/