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THE FLOWWOW PRIVACY POLICY

Publication date: 01.04.2024

TERMS AND DEFINITIONS

The Policy shall mean the present document available on the Internet at: https://flowwow.com/ae-en/docs/personal-data/

Personal Data shall mean information relating to an identified or identifiable natural person.

Personal Data Subject shall mean a natural person to whom personal data being processed is related.

Processing shall mean any action or set of actions performed with personal data using or without the use of automation tools, including collection, registration, organisation, structuring, accumulation, storage, adaptation or editing, uploading, viewing, use, disclosure by means of transfer, distribution or other ways of granting access, collating or combining, abridging, deletion or destruction.

The Company shall mean FLOWWOW - FZE, Reg. No. DSO-FZE-16091, trade license 17505, address DSO FZE Technohub, unit G-D_FLEX-G056C, Dubai Technology Entrepreneur Campus, Dubai Silicon Oasis, Dubai, United Arab Emirates.

The Service shall mean all pages of the website available at https://flowwow.com/, as well as mobile applications managed by the Company.

User shall mean a Personal Data Subject who provided their Personal Data to the Company in connection with the use of the Service and/or receipt or provision of services by using the Service.

Seller shall mean a User selling goods using the Service.

Customer shall mean a User purchasing goods using the Service for personal non-commercial purposes.

Recipient shall mean a Personal Data Subject specified by a Customer as the recipient of the goods if the goods are to be accepted by another individual other than the Customer.

A. CONTACTS 

If you have questions, comments, or requests related to the Policy, please email us at: hello@flowwow.com

SUBJECT MATTER

The Policy determines the procedure for processing and protection by the Company (hereinafter referred to ‘the Company’, ‘Flowwow’, ‘we’, ‘of/from/about us’, ‘our’, ‘to us’, ‘by us’) of Personal Data of Personal Data Subjects (hereinafter referred to as ‘you’, ‘of/from/about you’, ‘your’, ‘to you’, ‘by you’) received (collected) by the Company: 

  • when you use the Service; 

  • when we provide services to you or you provide services to us;

  • in connection with entering into any contracts and agreements and the performance of contracts and agreements entered into, to which the Company or the Personal Data Subject is a party;

  • in connection with the exercise of rights and performance of obligations arising from employer-employee relationships, to which the Company is a party;

  • in other cases provided for by the effective legislation of the United Arab Emirates or other regulations governing the conditions for Personal Data processing, or by the Policy.

THE PERSONAL DATA THAT WE COLLECT AND PROCESS

Provided Data: data that you provide to us. You provide data when signing up with the Service, when filling out forms with the Service, or communicating with us, for example, by email, phone, via instant messengers or social media. When you write to us or call us, we may keep a record of such communications.

Usage Data: data that we collect automatically. We collect certain information automatically when you visit, use, or navigate the Service.

Third-Party Data: data we collect from third parties. We may receive data about you from other sources, including from third parties, who help us update, enrich, and analyse the data we already have; prevent or detect fraud; process payments; or analyse the way you use the Service.

Appendix 1 to the Policy provides a complete list of Personal Data that we collect and process. 

Appendix 2 to the Policy provides a complete list of Personal Data Subjects whose Personal Data we collect and process. 

PURPOSES AND LEGAL GROUNDS FOR PROCESSING

We process personal data for the following purposes: 

  • related to proper functioning of the Service, in particular when we provide services to you and/or you provide services to us;

  • related to entering into contracts and agreements and the performance of contracts and agreements entered into;

  • in cases provided for by the effective legislation of the UAE;

  • for other purposes specified in the Policy. 

We process Personal Data in accordance with the following legal grounds:

Consent: we process your Personal Data pursuant to your consent to the processing of Personal Data for a specific purpose.

Contract performance: we process your Personal Data when so required for the performance of a contract entered into with us. 

Legal obligations: we process your Personal Data when required to do so by law to comply with applicable laws, government requests, court orders.

Appendix 3 to the Policy provides a complete list of the purposes of and grounds for Personal Data processing.

RIGHTS OF PERSONAL DATA SUBJECTS

Personal Data Subjects have rights, including the following: 

  • The right to access Personal Data, which includes the right to obtain a confirmation that we are processing your data, as well as the right to access Personal Data and information about the way we use your Personal Data.

  • The right to rectify incomplete or inaccurate Personal Data.

  • The right to demand, under certain circumstances, that we delete your Personal Data. For example, if we no longer need your Personal Data or you withdraw your consent, which constitutes grounds for data processing.

  • The right to restrict processing, i.e. request to restrict or cease collecting, using, processing, and/or disclosing your Personal Data in cases provided for by law.

  • The right to portability of Personal Data: you can request us to provide you with a copy of your Personal Data in a structured, commonly used, and machine-readable format, and, under certain circumstances, you can request us to transfer your data to another operator.

  • The right to withdraw the consent to Personal Data processing. 

  • The right to withdraw the consent to receiving promotional/marketing messages, provision of targeted advertisements. To do this, follow the unsubscribe link in any of our promotional emails. Opt out of receiving targeted advertising by rejecting cookies. Alternatively, please contact us at the address specified in Section A of the Policy.

  • The right to submit a complaint to a personal data protection regulator.

Personal Data Subjects or their representatives have the right to exercise their rights by submitting a request using the contact details specified in Section A of the Policy or in any other way provided for by the Policy.

If we are unable to identify the Personal Data Subject who submitted such a request, we may request additional information that allows us to identify the Personal Data Subject, for example, information confirming the Personal Data Subject’s relations with the Company (contract number, contract date, or other information), or information otherwise confirming the fact that the Company is processing the Personal Data of the Personal Data Subject. 

We have the right to reject a request if this is provided for by or required in accordance with the legislation of the UAE or legal requirements to be complied with by third parties that we cooperate with. 

We do not use automated decision-making, including the creation of User profiles, based on Personal Data.

PROVISION (DISCLOSURE) OF PERSONAL DATA TO THIRD PARTIES

We provide (disclose) Personal Data to third parties, including competent authorities, Sellers, suppliers who provide services to us or on our behalf and require access to such information in order to fulfil their obligations.

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

Appendix 4 to the Policy lists the categories of third parties to whom we provide Personal Data with indication of the purposes of provision. 

STORAGE OF PERSONAL DATA

We store your Personal Data for the periods specified in Appendix 5 to the Policy. A longer storage period may be provided for by the effective legislation of the UAE.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

The countries to which we, or third parties with whom we interact, transfer your Personal Data may not have the same data protection legislation as in your jurisdiction. In these cases, we take reasonable security measures as required by the effective legislation to ensure that your data is adequately protected when it is transferred outside of your jurisdiction.

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

We may transfer your data outside the UAE for the purposes of the performance of a contract/agreement with you and for other purposes specified in the Policy. When we perform such data transfers, we: comply with our legal and regulatory obligations; take appropriate precautions, such as compliance with standard contractual provisions for the protection of Personal Data. We will take all steps required to ensure that your data is processed securely in accordance with the Policy.


 

PERSONAL DATA OF MINORS

The Service is intended for the general public and may be used by minors. Minors may access some publicly available features of the Service and its content without providing us with their Personal Data. However, minors who wish to access all content and features of the Service are required to sign up with the Service. Signing up with the Service requires the collection of certain types of Personal Data. We may ask you to provide us with information and documents that prove your age. If you are a minor, we may require you to provide us with documents certifying the termination of parental custody or a legally binding letter of consent from your parent or other legal guardian.

In addition, we use certain technologies, such as cookies, to automatically collect information about our Users (Customers) (including minors) when they visit or use the Service. We collect, process, store, and disclose data of minors in accordance with the procedure provided for by the Policy.

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

PROTECTION OF PERSONAL DATA

We use appropriate physical, electronic, managerial, and technical means of protection to ensure the security of all Personal Data that we process. However, we cannot ensure or guarantee complete (absolute) security of your Personal Data that you provide to the Service. Although we do our best to protect your Personal Data, you should be responsible when providing your Personal Data to the Service. Please use the Service only in a secure environment: for example, use network security measures, choose an Internet service provider that encrypts traffic.

CHANGES AND AMENDMENTS TO THE POLICY

We have the right to make changes or amendments to the Policy at any time. Any changes or amendments we make to the Policy shall come into effect from the moment of publication of the amended text of the Policy. Each updated version of the Policy as amended shall supersede any and all previous versions of the Policy. We recommend that you review the Policy frequently to stay updated on the way we collect, process, and protect your Personal Data.


 

 

Appendix 1. Personal Data that we collect and process

Data type

Data being processed

 

1. Provided Data

Contact details

 

name; date of birth; language spoken; contact phone number; email address; delivery address, which may be a residence address and/or workplace.

 

Financial information


 

details of a bank account, payment method (upon request, for example, to make a payment or issue a refund).

 

Details of a user account with the Service

User name, password, account settings and preferences, content placed by the User in their user account.

Seller details

 

full name (last name; first name; patronymic, if any); details of the identification document: series, number, sex, citizenship (nationality), date and place of birth, date of issue, place of issue, issuing authority, validity period (if any); language spoken; image (photo); registration address; actual residence address; contact phone number; email address; taxpayer identification number (or similar Tax ID number).

Data of employees / former employees of Flowwow

 

full name (last name; first name; patronymic, if any); details of the identification document: series, number, sex, citizenship (nationality), date and place of birth, date of issue, place of issue, issuing authority, validity period (if any); image (photo); registration address; actual residence address; contact phone number; email address; taxpayer identification number (or similar Tax ID number); bank details; details of education, qualifications, vocational training, and refresher training; marital status; details of children and family ties; details of employment, including commendations, awards and/or disciplinary action; marriage registration data; other data provided by the employee in accordance with the requirements of applicable law.

 

Details of job applicants who may be hired by Flowwow


 

full name (last name; first name; patronymic, if any); residence address; contact phone number; email address; details of education, employment history, and qualifications; other data specified by job applicants in their resumes and cover letters.

Details of natural persons who are or were independent contractors providing services to Flowwow

 

full name (last name; first name; patronymic, if any); details of the identification document: series, number, sex, citizenship (nationality), date and place of birth, date of issue, place of issue, issuing authority, validity period (if any); image (photo); registration address; actual residence address; contact phone number; email address; taxpayer identification number (or similar Tax ID number); bank details.

 

Details of representatives/employees of Flowwow’s counterparties


 

full name (last name; first name; patronymic, if any), business phone number; business email address; name of the employer; place of business of the employer; position/job title.

 

Additional information

information about opening emails and following links contained in them; saved records of correspondence.

 

Details of minors


 

full name (last name; first name; patronymic, if any), details specified in a letter of consent or request.

 

2. Usage Data

Log and Usage Data

 

information about systems and devices used to access the Service, including IP address; operating system type and version; browser type, version, and settings; language settings; time zone settings; device type and identifiers; 

 

information about mobile networks; mobile phone operating system; browser type and version of the mobile device; current location; geolocation; links in URL format; 

 

usage information: for example, sign-in and sign-out time when using the Service; pages visited and features used; technical information available with the Service, for example, about the Internet connection speed; 

 

information about visiting the Service, including full URLs of web pages used to navigate to, via, and away from websites (including date and time); device event information (for example, system activity, error/bug reports, and hardware settings); 

 

mobile application usage information, including the information that you view when using our mobile applications, and date and time of such views; 

 

information to facilitate the use of the Service (in particular, to provide access to third-party websites and services), such as requests of URL, target IP address, or device configuration data; 

 

pages viewed or searched for; page response time; loading errors; time on page; page interaction information (scrolling, clicks, and hovering); interactions with specific variable/dynamic page elements; and methods used to navigate away from a page; 

 

unique identifiers assigned to Personal Data Subjects in order to provide the Service features.

Information received from IT systems

 

information from access systems/logs (for example when visiting offices), automatic monitoring of our websites and technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.

 

Information collected through cookies and other similar technologies

 

For information about the use of cookies and other similar technologies, please refer to Flowwow's Cookie Policy.


 
 

3. Third-Party Data

Third-party services

 

We collect information through third-party services, including Google Ads, Google Analytics, Firebase, Adjust for the purpose of displaying targeted advertisements, personalised content, and analytics.

Information that we collect from other sources

 

information from third parties that helps us combat fraud, provide services, or relates to your interactions obtained from companies that collect aggregated information and share it with us. 

 

Appendix 2. Personal Data Subjects

Personal Data Subjects

Personal Data being processed

Customers

Provided Data: contact details; financial information (upon request); details of a user account with the Service; additional information; details of a minor in cases where the Customer is a minor.

 

Usage Data.

 

Third-Party Data.

Sellers

Provided Data: Seller details, financial information, details of a user account with the Service, additional information.

 

Usage Data.

 

Third-Party Data.

Recipients

 

Provided Data: contact details, additional information.

Potential Users (you sign up with the Service, but then do not use the Service)

Provided Data: contact details and personal data; details of a user account with the Service; additional information; details of a minor in cases where the Potential User (Customer) is a minor.

 

Usage Data.

 

Third-Party Data.

Employees / former employees of Flowwow

Provided Data: data of employees / former employees of Flowwow.

Job applicants who may be hired by Flowwow

Provided Data: details of job applicants who may be hired by Flowwow.

Natural persons who are or were independent contractors providing services to Flowwow

Provided Data: details of natural persons who are or were independent contractors providing services to Flowwow.

Representatives/employees of Flowwow’s counterparties

Provided Data: details of representatives/employees of Flowwow’s counterparties.

Parents of minors

Provided Data: details of a minor

Natural persons who contacted Flowwow to submit requests, messages, statements, complaints, suggestions using contact details or feedback tools

Provided Data: contact details and personal data; in rare cases, details of an identification document.

Natural persons participating in interviews, surveys, analytical and marketing research related to Flowwow’s operations

Provided Data: information required for interaction.

Visitors to Flowwow office spaces

Provided Data: information required for interaction.

 

Appendix 3. Purposes of and grounds for processing

Usage purpose

Data category

Legal grounds

Creation (registration), maintenance, and management of user accounts with the Service. 

Registration and subsequent authorisation with the Service, including the implementation of a seamless authorisation feature. 

Account identification in automated management systems, in particular CRM. 

Sending information messages and push notifications related to the operation of the Service (service messages).

Provided Data, Usage Data.

Performance of contracts and agreements

Entering into contracts/agreements with Users. 

Performance of contracts/agreements entered into with Users, including provision of services, payment for services/orders, fulfilment and management of orders, provision of data to third parties for order fulfilment, communications for the purpose of order fulfilment (providing information about order status; responding to requests, claims; support).

Provided Data.

Performance of contracts and agreements

Loyalty program membership. 

Provided Data. Usage Data. Third-Party Data.

Performance of contracts and agreements

Exercising and securing rights, fulfilling obligations arising from employer-employee relationships.

Provided Data.

Performance of contracts and agreements and legal obligations.

Sending promotional/marketing messages. Providing targeted advertisements using cookies and other similar technologies. 

Provided Data. Usage Data. Third-Party Data.

Consent

Organising promotional/marketing campaigns.

Provided Data.

Consent

Sending information about changes and amendments to terms and conditions, policies, agreements.

Provided Data.

Performance of contracts and agreements

Sending information about new products/services/features/functionality.

Provided Data.

Consent

Search and selection of job applicants who may be hired by Flowwow.

Provided Data.

Legal obligations and legitimate interests

Conducting research and surveys. Requesting and posting reviews.

Provided Data.

Consent

Development of new features, creation of new products/services and offers.

Provided Data. Usage Data.

Consent

Collection, processing, and presentation of statistical data and other research based on depersonalised Personal Data.

Provided Data. Usage Data. Third-Party Data.

Consent

Entering into, performance and termination of contracts with third-party independent contractors.

Provided Data.

Performance of contracts and agreements

Exercising activities provided for by the instruments of incorporation of Flowwow.

Provided Data.

Legal obligations

Prevention of unlawful activities, in particular fraud. Improving anti-fraud practices.

Provided Data. Usage Data. Third-Party Data.

Legal obligations

Assessing and improving the quality of services provided.

Detection and prevention of technical problems of the Service.

Managing the Service in the context of internal operations, including troubleshooting, data analysis, testing, research, statistics, and surveys.

Maintaining the best possible level of operation of the Service. 

Maintaining the security and reliability of the Service.

Provided Data. Usage Data. Third-Party Data.

Contract performance. Legal obligations 

Providing answers in legal, regulatory, arbitration procedures.

Providing responses to requests for information received from government authorities or other third parties.

Preventing harm as required by law.

Provided Data. Usage Data.

Legal obligations

Appendix 4. Third parties to whom we provide Personal Data

Category of third parties to whom we may provide data

 

Categories of data and purposes for providing data

Competent authorities

 

We provide and disclose Provided Data, Usage Data, and Third-Party Data. 

Personal Data is provided upon request and in accordance with the requirements of applicable law.

Sellers

We provide and disclose Provided Data of Customers in order for Sellers to fulfil their obligations under contracts/agreements with Customers.

Payment service providers and invoicing service providers

 

We provide and disclose Provided Data to payment service providers and invoicing service providers only if they request such data. If you do not use the services of payment service providers and invoicing service providers with the Service, we will not share Provided Data with them.

 

We do not collect or store your bank card details. You provide this information to our Payment (incoming/outgoing) service providers and invoicing service providers. The way they use Provided Data for payment processing is governed by their privacy policies.

Data storage service providers

We store Provided Data, Usage Data, and Third-Party Data in data centres. 

 

The purpose is data storage.

Communication service providers

We provide and disclose Provided Data to communication service providers. 

The purpose is exchange of service text messages, service voice messages, sending email messages

Advertising platforms and applications 

 

We provide and disclose Usage Data. The platforms we use for advertising allow us to optimise and display advertisements based on the Service usage data, i.e. by tracking Usage Data, including cookies. 

 

Purposes: (1) tracking the actions of Users (Customers) after they were redirected to the Service by following an advertisement link;(2) measuring the effectiveness of advertisements for the purpose of market research and gathering statistics, in particular to better understand and display advertisements and make them more relevant to Users (Customers).

Marketing and Analytics Platforms

 

We provide and disclose Usage Data, including cookies, for the purposes of web and mobile analytics and to personalise content available with the Service: for example, to offer you only those of our services that you may find relevant. 

 

Purposes: (1) tracking the Service traffic and the behaviour of Users (Customers) while they use the Service;(2) analysing the way Users (Customers) use the Service in order to improve its performance and manage the placement of advertisements based on interests and preferences.

Review aggregators

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

Buyers of the Company's business/assets 

 

We provide and disclose Provided Data and Usage Data in connection with any merger, acquisition, sale of Flowwow's assets, financing, or acquisition of the whole or a part of Flowwow's business/assets by another company, or during negotiations related to any of the above

Affiliated companies 

We provide and disclose Provided Data, Usage Data, and Third-Party Data to affiliated companies if so required to achieve the objectives set out in the Policy.

Other suppliers and partners

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



 

Appendix 5. Storage periods of Personal Data

Personal Data Subjects

Storage period of Personal Data

Customers, including minors

Throughout the entire period of use of the Service and for a period of 96 months from the date of the last use of the Service or the fulfilment of the last order, depending on whichever occurs later.

Sellers

Throughout the entire period of use of the Service and for a period of 96 months from the date of the last use of the Service or the fulfilment of the last order, depending on whichever occurs later.

Recipients

96 months from the date of fulfilment of the last order.

Potential Users (you sign up with the Service, but then do not use the Service)

96 months from the date of signing up with the Service.

Employees / former employees of Flowwow

Throughout the validity period of the employment contract and for 96 months from the date of its termination/expiration, unless a longer period is established by the effective legislation.

Job applicants who may be hired by Flowwow

96 months from the date of receipt.

Natural persons who are or were independent contractors providing services to Flowwow

Throughout the validity period of the contract and for 96 months from the date of its termination/expiration, unless a longer period is established by the effective legislation.

Representatives/employees of Flowwow’s counterparties

Throughout the validity period of the contract and for 96 months from the date of its termination/expiration.

Loyalty program members

96 months from the date of termination of the loyalty program membership.

Parents of minors

Same as the storage period of Personal Data of the minor.

Natural persons who contacted Flowwow to submit requests, messages, statements, complaints, suggestions using contact details or feedback tools

96 months from the date of cessation of communication with such a person.

Natural persons participating in interviews, surveys, analytical and marketing research related to Flowwow’s operations

96 months from the date of receipt.

Visitors to Flowwow office spaces

96 months from the date of receipt.

Previous version of the document: https://flowwow.com/en/docs/personal-data_ae-till-31-03-2024/

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