Accessibility Statment

Privacy Policy of Floworg
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‍Floworg collects some Personal Data from its Users.
This document contains a section dedicated to Californian consumers and their privacy rights.This document contains a section dedicated to Brazilian Users and their privacy rights.This document can be printed for reference by using the print command in the settings of any browser

Owner and Data Controller
Floworg, Ltd. – 1111B S Governors Ave STE 23799 Dover, DE, 19904 US
Owner contact email: [email protected]

Floworg, Ltd. (the “Company”) is committed to maintaining robust privacy protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.

For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at www.Floworg360.com.
“Service” refers to the Company’s services accessed via the Site, in which users can
Multi-channel communication services, omnichannel, integrations, automations, characterization and implementation of CRM systems, product management and marketing strategies, BI data analysis, organizational dashboards, project management and business and advertising strategies.
The terms “we,” “us,” and “our” refer to the Company.
“You” refers to you, as a user of our Site or our Service.
By accessing our Site or our Service, you accept our Privacy Policy and Terms of Use (found here: www.Floworg360.com/Terms), and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

Types of Data collected
Among the types of Personal Data that Floworg collects, by itself or through third parties, there are: Tracker; Usage Data; payment info; first name; last name; email address; Data communicated while using the service; various types of Data; name; calendar information; user content; password; picture.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
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Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Floworg.
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Unless specified otherwise, all Data requested by Floworg is mandatory and failure to provide this Data may make it impossible for Floworg to provide its services. In cases where Floworg specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
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Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
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Any use of Cookies – or of other tracking tools – by Floworg or by the owners of third-party services used by Floworg serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Floworg and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data
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Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
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The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Floworg (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
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provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
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processing is necessary for compliance with a legal obligation to which the Owner is subject;
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processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
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In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
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Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
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The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Tag Management, Handling payments, Hosting and backend infrastructure, Contacting the User, Interaction with live chat platforms, Handling activities related to productivity, Advertising, Registration and authentication, Collection of privacy-related preferences, Content commenting, Data transfer outside the EU, Managing data collection and online surveys, Registration and authentication provided directly by Floworg, Remarketing and behavioral targeting, Social features and Traffic optimization and distribution.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by Floworg
Floworg may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Floworg to connect with the User’s account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me
Provides access to the ‘About Me’ section of the profile.

Instagram basic
Allows reading an Instagram account profile information and media.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts
This type of service allows Floworg to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.

Facebook account access (Meta Platforms, Inc.)
This service allows Floworg to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Instagram basic.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information.

Google account permissions
Floworg may require certain Google permissions (aka scopes) in order to perform actions on the User’s Google account and obtain data, such as Personal Data.

Floworg is able to link with the User’s Google account, which is provided by Google, via this service.

Floworg is using two apps for this service. One is called “Floworg” and an unbranded version used for our partners is named “Chatbot App”

The following are the required permissions (scopes):

userinfo.email
View your email address

Userinfo.profile
See your personal info, including any personal info you’ve made publicly available

Gmail.send
Send email on your behalf

Drive
See, edit, create, and delete all of your Google Drive files

Spreadsheets
See, edit, create, and delete your spreadsheets in Google Drive

Stripe account access
This service allows Floworg to connect with the User’s account on Stripe, provided by Stripe, Inc.
Personal Data processed: Data communicated while using the service; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; commercial information.

Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Floworg to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Floworg.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Vultr Hosting
This type of service has the purpose of hosting Data and files that enable Floworg to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Floworg.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of Floworg, in order to contact and be contacted by Floworg‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Facebook Messenger Customer Chat (Meta Platforms, Inc.)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Meta Platforms, Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

LiveChat Widget (LiveChat, Inc.)
The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Managing data collection and online surveys
This type of service allows Floworg to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Data provided via online forms, managed directly (Floworg)
Floworg makes use of online forms that can be used to collect Data about Users.
Personal Data processed: email address; first name; last name; Usage Data; user content.

Category of personal information collected according to CCPA: identifiers; internet information.

Registration and authentication
By registering or authenticating, Users allow Floworg to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Floworg will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Google OAuth
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location Floworg is accessed from, and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Auth0 (Auth0, Inc)
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; first name; last name; password; picture; Tracker; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; European Union – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information; sensorial information.

Registration and authentication provided directly by Floworg
By registering or authenticating, Users allow Floworg to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (Floworg)
The User registers by filling out the registration form and providing the Personal Data directly to Floworg.
Personal Data processed: email address; first name; last name; Usage Data.

Category of personal information collected according to CCPA: identifiers; internet information.

Remarketing and behavioral targeting
This type of service allows Floworg and its partners to inform, optimize and serve advertising based on past use of Floworg by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.

Facebook Custom Audience
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on the location Floworg is accessed from, that connects the activity of Floworg with the Facebook advertising network. Users can opt out of Facebook’s use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: identifiers; internet information.

Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on the location Floworg is accessed from, that connects the activity of Floworg with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

Social features
Inviting and suggesting friends (Floworg)
Floworg may use the Personal Data provided to allow Users to invite their friends – for example through the address book, if access has been provided – and to suggest friends or connections inside it.
Personal Data processed: various types of Data.

Category of personal information collected according to CCPA: internet information.

Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Floworg in a centralized fashion.
This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location Floworg is accessed from.
Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Traffic optimization and distribution
This type of service allows Floworg to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Floworg and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Floworg, i.e., communication between Floworg and the User’s browser, while also allowing analytical data from Floworg to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data
Equal protection of User Data
Floworg shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
Personal Data collected through sources other than the User
The Owner of Floworg may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Preference Cookies
Preference Cookies store the User preferences detected on Floworg in the local domain such as, for example, their timezone and region.
Push notifications
Floworg may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Floworg, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Floworg.
Push notifications for direct marketing
Floworg may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Floworg). Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for Floworg or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of Floworg. Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Floworg depends on the payment system used.
sessionStorage
sessionStorage allows Floworg to store and access data right in the User’s browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
The Service is intended for adults
Users declare themselves to be adult according to their applicable legislation. Minors may not use Floworg.
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use Floworg only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Floworg.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy
Floworg uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Floworg or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, Floworg may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, Floworg and any third-party services may collect files that record interaction with Floworg (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
Floworg does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Floworg and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Floworg and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to “The California Consumer Privacy Act of 2018” (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, commercial information, internet information and sensorial information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Floworg.

For example, you directly provide your personal information when you submit requests via any forms on Floworg. You also provide personal information indirectly when you navigate Floworg, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of Floworg and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Floworg, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of Floworg and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:

the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
for sales, the personal information categories purchased by each category of recipient; and
for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Floworg, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Additional information about California privacy
CCPA: Collection of personal information about minors
We do not knowingly collect personal information of consumers who are below the age of 16.

Information for Users residing in Brazil
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running Floworg and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:

obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Additional information for Users residing in Brazil
Transfer of personal information outside of Brazil based on contracts and other legal means
We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.

To do so, we may use one of the following legal means:

specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
Transfer of personal information outside of Brazil based on your consent
We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
You may withdraw your consent at any time.

Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD
We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:

the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
the nature of the personal information subject to the transfer;
the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
the adoption of suitable security measures;
the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
any other pertinent circumstance related to the relevant transfer.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through Floworg (or third-party services employed in Floworg), which can include: the IP addresses or domain names of the computers utilized by the Users who use Floworg, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User
The individual using Floworg who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Floworg. The Data Controller, unless otherwise specified, is the Owner of Floworg.

Floworg (or this Application)
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by Floworg as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker
Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Floworg, if not stated otherwise within this document.

Last Updated: This Privacy Policy was last updated on 01 December 2024