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PRIVACY POLICY

updated on: 9th April 2025

Introduction

At Web8, Josip Rajkovic s.p., Zelena pot 3, 1241 Kamnik, Slovenia, EU ("we," "us," or "our"), we value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and safeguard your information when you visit or use our website flowwwtin.com (the "Website").

We have developed this Privacy Policy in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") to ensure transparency about our data practices and to inform you about your rights regarding the personal data we process.

Please read this Privacy Policy carefully. By accessing or using our Website, you acknowledge that you have read, understood, and agree to the practices described in this document. If you do not agree with this Privacy Policy, please refrain from using our Website.

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes through the Website or via email if appropriate. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

1. Data Controller

The Data Controller for your personal data is:

Web8, Josip Rajkovic s.p.
Zelena pot 3
1241 Kamnik
Slovenia, EU
Email: hello@flowwwtin.com

2. Personal Data We Collect

For the purposes of this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable natural person.

We collect and process the following categories of Personal Data:

2.1. Account Registration Data

When you create a user account on our Website, we collect:

  • Identification Data: Your email address and password to establish and manage your account, verify your identity, and enable secure access to our services.
  • Contact Information: Your email address for account management communications, including registration confirmation, password reset requests, account updates, and important notices about our services or this Privacy Policy.
  • Marketing Communications: If you consent to receive our newsletters and promotional content, we will use your email address for these communications. You can opt out of these communications at any time.

2.2. Transaction Information

When you subscribe to our services or make a purchase, we collect:

  • Billing Information: Your name (personal or business), billing address, postal code, city, country, and if applicable, your tax identification number (TIN) or VAT ID number.
  • Payment Details: We process payment information necessary to complete your transactions. Note that we do not store complete payment card details on our servers.

2.3. Technical Data

When you browse our Website, we automatically collect:

  • Usage Data: Information about how you interact with our Website, including pages visited, time spent on pages, navigation paths, and features used.
  • Device Information: Technical details about the device you use to access our Website, such as IP address, browser type and version, operating system, screen resolution, and device type.
  • Location Data: General location information derived from your IP address.

3. How We Collect Your Personal Data

We collect Personal Data in the following ways:

  • Direct Interactions: Information you provide when you create an account, subscribe to our services, fill out forms, respond to surveys, or communicate with us.
  • Automated Technologies: As you navigate through our Website, we may automatically collect technical data about your equipment, browsing actions, and patterns through cookies and similar technologies.
  • Third Parties: In limited circumstances, we may receive information about you from third parties, such as business partners, technical service providers, and payment processors.

4. Legal Basis and Purpose for Processing

We process your Personal Data based on the following legal grounds:

4.1. Performance of a Contract

We process much of your Personal Data because it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This includes:

  • Managing your account
  • Processing your payments
  • Providing customer support
  • Delivering our services

4.2. Legitimate Interests

We process some of your Personal Data based on our legitimate interests, which include:

  • Improving and personalizing our Website and services
  • Ensuring the security and proper functioning of our Website
  • Analyzing usage patterns to enhance user experience
  • Preventing fraud and protecting our rights

4.3. Consent

Where required by law, we will only process your Personal Data with your explicit consent. This applies particularly to:

  • Sending marketing communications
  • Using certain types of cookies
  • Processing special categories of Personal Data

You have the right to withdraw your consent at any time.

4.4. Legal Obligation

We may process your Personal Data to comply with a legal obligation to which we are subject, such as tax regulations or in response to legal proceedings.

5. Cookie Policy

A cookie is a small text file that is stored on your device when you visit our Website. Cookies help us make your experience more efficient and user-friendly.

5.1. Types of Cookies We Use

Essential Cookies

These cookies are necessary for the Website to function properly. They enable core functionality such as security, network management, and account authentication. You cannot opt out of these cookies.

Preference Cookies

These cookies remember your preferences and settings to enhance your experience on our Website.

Analytics Cookies

These cookies help us understand how visitors interact with our Website by collecting and reporting information anonymously. This helps us improve our Website and services.

5.2. Third-Party Cookies

Our Website may use cookies from the following third parties:

  • Google Analytics: Used to understand how visitors use our Website
  • Hotjar: Used to analyze user behavior and improve user experience
  • Payment processors: Used to process transactions securely

5.3. Cookie Control

You can control cookies through your browser settings. Most web browsers allow you to manage your cookie preferences. You can:

  • Delete cookies from your device
  • Block cookies by activating the setting on your browser that allows you to refuse all or some cookies
  • Set your browser to notify you when you receive a cookie

Please note that if you choose to block or delete cookies, you may not be able to access certain areas or features of our Website, and some services may not function properly.

For more information about how to modify your browser settings to block or filter cookies, visit:

6. Data Sharing and Transfers

6.1. Service Providers

We may share your Personal Data with third-party service providers who perform services on our behalf, such as:

  • Payment processors
  • Cloud hosting providers
  • Email service providers
  • Analytics providers
  • Customer support services

These service providers are bound by contractual obligations to keep your Personal Data confidential and secure, and to use it only for the purposes for which we disclose it to them.

6.2. International Transfers

Some of our service providers may be located outside the European Economic Area (EEA). Whenever we transfer your Personal Data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as:

  • Using specific contracts approved by the European Commission that give Personal Data the same protection it has in Europe
  • Transferring data to countries that have been deemed to provide an adequate level of protection by the European Commission
  • Using service providers that are certified under approved data protection frameworks

Our payment processor, Stripe, is based in the United States. When you make a payment through our Website, your payment information is transferred to Stripe for processing. Stripe's Privacy Policy is available at https://stripe.com/privacy.

6.3. Legal Requirements

We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

6.4. Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your Personal Data may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your Personal Data.

7. Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider:

  • The amount, nature, and sensitivity of the Personal Data
  • The potential risk of harm from unauthorized use or disclosure
  • The purposes for which we process your Personal Data
  • Whether we can achieve those purposes through other means
  • Legal requirements

In general, we will retain your Personal Data for a period of 5 years from the end of the tax year in which our last interaction occurred. At the end of this retention period, your user account and associated Personal Data will be automatically deleted or anonymized.

You can request deletion of your account and Personal Data at any time. For information about how to access, modify, or delete your Personal Data, please refer to Section 9 of this Privacy Policy.

8. Data Security

We have implemented appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing, accidental loss, destruction, or damage.

These measures include:

  • Encryption of sensitive data
  • Secure storage in protected databases
  • Access controls and authentication systems
  • Regular security assessments
  • Staff training on data protection
  • Physical security measures at our facilities

We limit access to your Personal Data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Your Rights

Under the GDPR, you have several rights regarding your Personal Data. These include:

9.1. Right to Access

You have the right to request copies of your Personal Data. We may charge a reasonable fee when a request is manifestly unfounded or excessive.

9.2. Right to Rectification

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

9.3. Right to Erasure

You have the right to request that we erase your Personal Data, under certain conditions.

9.4. Right to Restrict Processing

You have the right to request that we restrict the processing of your Personal Data, under certain conditions.

9.5. Right to Object to Processing

You have the right to object to our processing of your Personal Data, under certain conditions.

9.6. Right to Data Portability

You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

9.7. Right to Withdraw Consent

Where we rely on consent as the legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the contact details provided in Section 1. We will respond to your request within one month.

9.8. Right to Complain

You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your Personal Data infringes upon your rights. In Slovenia, the supervisory authority is the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec Republike Slovenije).

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the "Last updated" date displayed at the bottom of this Privacy Policy.

11. Contact Us

If you have any questions about this Privacy Policy, or if you would like to exercise any of your rights, please contact us at:

Web8, Josip Rajkovic s.p.
Zelena pot 3
1241 Kamnik
Slovenia, EU
Email: hello@flowwwtin.com

Last updated: April 9, 2025

Web8, Josip Rajkovic s.p.

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