Privacy Policy
At Flowa, we value the privacy and security of your personal information. This Privacy and Cookie Policy (“Policy”) outlines how we collect, use, store, and protect the personal data of our employees, clients, partners, and visitors. Our mission is to handle your information with the utmost respect and confidentiality, in accordance with current laws and regulations, such as the General Data Protection Law (LGPD).
We are committed to being transparent about our privacy practices and ensuring that your information is always protected. Thank you for trusting Flowa. We are always available to clarify any questions you may have about our privacy practices.
Purpose
As part of our daily operations, we need to collect personal data from our employees, clients, and potential clients in order to provide products and services aligned with their values, interests, and profiles.
Your privacy is extremely important to us. Our policy is to respect the confidentiality of your information and the privacy of individuals. This Privacy and Cookie Policy sets out how Flowa Technologies (“Flowa”) processes personal data in compliance with applicable data protection laws and regulations.
This Policy establishes general principles and guidelines for privacy protection for the company and its clients. The need to develop and adopt information security and privacy standards aligns with the requirements of current regulations, such as Law No. 13.709/2018 (LGPD), rules from the National Data Protection Authority, the Code of Ethical Conduct, and other applicable industry standards.
Scope and Definitions
This Policy applies to the processing of personal data of our employees, clients and their users, potential clients, potential employees, website visitors, users of our platform or service channels (such as WhatsApp, Skype, Email), suppliers, and others (“Data Subjects”).
General Aspects
Flowa respects the privacy of all Data Subjects and is committed to taking all reasonable measures to ensure the protection of collected personal data. All information is processed in accordance with applicable data protection laws and regulations.
We have implemented technical and organizational procedures to ensure your information remains secure. As part of this, we regularly train and raise awareness among our employees about the importance of safeguarding personal information. Any violation of privacy is taken seriously and appropriate measures are in place to handle breaches.
We may collect data through various methods, such as:
- Completing forms or questionnaires;
- Sending emails;
- Accessing websites, platforms, or apps;
- Phone calls;
- Signing contracts;
- Submitting personal documents;
These interactions may occur in situations such as:
- Employment relationships;
- Provision or request for products/services;
- Contracting services;
- Marketing or institutional material requests;
- Customer support;
- Feedback collection;
- Website or platform access.
What Data Does Flowa Collect?
We collect a variety of data depending on how users interact with our platform and services, including:
From Platform Users:
- Username;
- IP address;
- Access date and time;
- Platform version;
- User’s internet service provider;
- Actions taken on the platform.
From Website Users:
- Browser type;
- IP address;
- Access date and time;
- User location;
- Actions taken on the website.
From Job Applicants and Employees:
- Name, ID number, date of birth, address, phone, email, marital status, nationality, profession, position, salary, benefits, health data, bank details, among others.
Cookies
Cookies are files stored on your device when visiting our website. They do not transfer viruses or malware and function as records of user activity. Once you grant permission, cookies are stored and used to enhance website functionality and performance.
5.1. Why We Use Cookies?
We use cookies to analyze user navigation on our website, track performance, and improve functionality. This includes identifying popular pages and measuring ad campaign effectiveness.
5.2. Types of Cookies We Use
- Essential Cookies: Necessary for the website to function properly. Stored temporarily and expire when the browser is closed.
- Analytical Cookies: Provide anonymous information about user behavior to improve site performance.
- Preference Cookies: Remember your settings such as preferred language or region.
Users are responsible for managing their cookie preferences through browser settings
What Data Is Collected to Create a User Account?
To register on our platform, we require:
- Full name;
- Institution;
- Business phone;
- Business email;
- CPF (Individual Taxpayer Registry Number - Brazil).
Why Do We Collect and Use Your Data?
We may use your personal information for the following purposes:
I. To Create a User Account
We must verify your identity to validate access to our site/platform, ensuring secure login practices.
II. To Perform Contracted Services
Once registered, your data is necessary for service usage and compliance with legal obligations.
III. To Comply with Legal Obligations
We are subject to various laws (financial, tax, etc.) and regulations that require personal data processing.
IV. To Send Communications and Satisfaction Surveys
We may send operational messages and request user feedback to improve our services.
V. To Respond to Requests
In case of support requests or complaints, we may use personal data to ensure proper identification and resolution.
VI. To Analyze Behavior on the Platform
We may use tools to analyze user behavior anonymously to enhance your experience.
VII. For Marketing Purposes
We may send communications (Email, SMS, WhatsApp) with relevant information based on your consent.
VIII. For Physical and Property Security
When visiting our facilities, we may record images via security cameras and request identification data for access control.
IX. For Fraud Prevention and Security
We treat personal data to improve fraud prevention, enhance protection against breaches, and safeguard user data.
X. To Protect Legitimate Interests
Processing is conducted to safeguard our legitimate interests while respecting legal principles. This includes:
- Legal claims and defense;
- Financial analysis and strategic reports;
- Security system monitoring;
- Business management and service optimization;
- Anti-money laundering verification;
- Service and product personalization.
XI. For Human Resources Management
We process data for HR purposes such as:
- Legal compliance;
- Employment contract execution;
- Payroll and benefits management;
- Recruitment and selection;
- Training and development.
Obtaining your consent
If the purpose of data collection requires your consent for any personal data processing, it will be provided through our channels.
If you wish to withdraw your consent and no longer receive communications and marketing emails, this can be done via the cancellation option, which is clearly identified in our emails.
Processing data of children and adolescents
The processing of personal data of children and adolescents is limited to the execution of our contracts with Employees, ensuring compliance with the provisions of the LGPD.
Sharing of personal data
Subject to the criteria defined in this Policy, Flowa will not disclose personal data of its Employees and clients to third parties, except:
· to meet a necessary requirement under applicable laws, rules, or regulations;
· in the presence of a disclosure obligation;
· due to legitimate interest requiring disclosure; or
· at the request of the client or Employee, with their consent.
Third-party entities to which personal information is shared for the purpose of performing contracted services must process such data in compliance with legal obligations. We also require that organizations outside Flowa that handle or access personal data recognize the sensitivity of this information, commit to respecting all individual privacy rights, and comply with all relevant data protection laws.
As part of the use of your data for the purposes mentioned above, we may occasionally disclose your personal information to:
i. other companies in the Flowa Group within the scope defined by this policy;
ii. third-party entities such as commercial service providers and specialized consultants contracted for administrative, financial, legal, security, research, and other services;
iii. third parties conducting audits;
iv. business partners, courts, regulatory bodies, and authorities;
v. in the event we disclose your personal data to business partners for service delivery purposes, these partners may store your data to comply with legal obligations;
vi. any individual or company, provided we have your consent;
vii. clients agree and consent that we may occasionally analyze the collected data when visiting our websites and platform or through other means, such as surveys, for statistical purposes to improve our services.
International data transfers
Flowa processes your personal information within national territory and in countries with similar and equivalent legislation. In addition, we maintain specific clauses to ensure proper handling in line with Brazilian laws and regulations.
Personal data storage and retention period
Flowa will retain your personal information for the time necessary to fulfill the purposes for which the information is processed or for other valid reasons, such as legal compliance.
Access your personal data
If you wish to access your personal data processed in our environment, please contact the Data Protection Officer via the email: encarregadodedados@flowatech.com.br.
Consultar seus dados pessoais
Se desejar realizar a consulta dos seus dados pessoais que são tratados em nosso ambiente, entre em contato como o Encarregado de Dados através do e-mail encarregadodedados@flowatech.com.br.
Update your personal data
If you wish to update your personal data, you can do so by contacting the Data Protection Officer at: encarregadodedados@flowatech.com.br. Established procedures exist for updating Name, Phone Number, Email, and other registration data.
Request cancellation of data processing
If you no longer want your personal data to be processed, you may request its removal by contacting the Data Protection Officer via the email: encarregadodedados@flowatech.com.br. Please note that even after requesting cancellation, we may need to retain your personal data to comply with legal obligations, including potential requests from regulatory authorities such as the Central Bank or CVM.
Data Protection Officer
We have a Data Protection Officer who oversees issues related to this Policy. Questions about privacy, accessing your data, or exercising your rights as a data subject should be directed to: encarregadodedados@flowatech.com.br.
Legal Notice
Flowa is not responsible for misuse or loss of personal data to which it has no access or control. We are also not liable for the illegal and unauthorized use of such information resulting from misuse or theft of your access credentials, or from negligent or malicious conduct on your part or by someone authorized on your behalf.
To comply with current Data Protection legislation, we inform the name and email of the Data Protection Officer at ATG: Felipe Deco – encarregadodedados@flowatech.com.br. Through this contact, you can exercise your data subject rights, request clarification, and ask questions regarding LGPD.