FLOWX.AI BUSINESS SYSTEMS with registered office on Charles de Gaulle Plaza 15, Charles de Gaulle Plaza street, 9th floor Bucharest, Romania and VAT no RO43370465 is a company registered and organized under the laws of Romania responsible for developing low code, no-code software development platform.
Your privacy is one of our fundamental commitments at FLOWX.AI BUSINESS SYSTEMS (referred to as “FlowX.ai” or “we”) and we will make our best efforts to protect your personal data.
This is why we take great care when we process your personal data in accordance with the principles set forth in the data protection legislation, including the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). Personal data represents any information relating to an identified or identifiable natural person, and an identifiable person is that person that may be identified directly or indirectly, particularly by reference to an identification number or to one or more factors specific to its physical, psychological, mental, economic, cultural or social identity.
This privacy policy regards the personal data of our clients, business partners, participants in the FlowX.ai Academy learning environment, other persons contacting and visiting us and of the representatives thereof, potential employees and interns, and it applies to data collected through our website, www.FlowX.ai, as well as to all other personal data we collect through e-mail or other off-line contacts. The Privacy Policy describes:
Client data
This is the personal data that is provided by you as a client or potential client of FlowX.ai, as well as any of client’s representatives, contact persons, employees, clients or other collaborators. This data may also be collected by us to enable you to sign up for and use the services and products we provide. Such data may include your name, title/position, email address, phone, fax, business address IP, as well as other personal data FlowX.ai processes, in order to fulfill the purposes described below.
Business Partner Data
This is the personal data that is provided by you or that we collect from you and process, as a FlowX.ai business partner or as the representative, contact person, employee, clients or other collaborator of a FlowX.ai business partner. Such data may include your name, title/position, email address, phone, fax, business address IP, as well as other personal data FlowX.ai processes, in order to fulfill the purposes described below.
Usage Data
This is the personal data that is collected and processed when you’re accessing and/or using and visiting our website www.FlowX.ai. Such data may include URL information, IP addresses, online identifiers including cookies, which are subject to our Cookie Policy and to this Privacy Policy.
FLOWX.AI Academy Data
This is the personal data that is collected about you when you’re accessing and/or using the FlowX.ai Academy in accordance with the terms located here […].Such data may include your name, telephone number, your organization, title and email address, your answers to tests and examining questions and the results (scores) of the exams and tests taken in the FlowX.ai Academy, records of your interactions with the FlowX.ai Academy (such as your Content, Course completion, Course progress and learning progress, Certifications obtained (as such terms are defined under the FlowX.ai Academy Terms), your Credentials status (as such terms are defined the FlowX.ai Academy Terms).
Image Data
This is the personal data that is collected about you when you take an exam or test to obtain a Certification or Designation from FlowX.ai Academy, in accordance with the FlowX.ai Academy Terms, or when you visit FlowX.ai premises.
Job Applicant Data
We use the personal data contained in the CVs we receive in order to assess the applicants’ qualifications for a position within FlowX.ai, including in relation to our internship program.
The categories of data processed in the context of our relationship with you are the personal data included in the provided CV, which can contain your name, e-mail, phone, fax, address, education and training details, professional qualifications, as well as other personal data you may provide directly to us, as per additional request.
Visitor Data
This is the personal data that we collect and that you provide us as a visitor of our premises, in order to ensure the security of our premises, assets, and personnel and fulfilling the legal requirements. The categories of data processed in this context are your name and your image taken by the CCTV cameras – if implemented, as well as other personal data you may provide us directly, as per our request, as needed to ensure the security of our premises, assets, and personnel and observance of legal provisions.
Contest, Surveys, Sweepstakes Data
When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.
IT IS NOT MANDATORY TO PROVIDE US WITH THE REQUESTED PERSONAL DATA. THOUGH, IF YOU CHOOSE NOT TO PROVIDE THEM, IN SOME CASES WE WILL BE UNABLE TO EFFICIENTLY FULFIL YOUR REQUESTS AND PROVIDE YOU WITH OUR PRODUCTS/SERVICES.
When you use or interact with our services, products and infrastructures we use a variety of technologies to process the personal data we collect about you for various purposes. We have set out in the table below the purposes of processing your personal data, the associated legal bases we rely upon, to legally permit us to process your personal data, and the categories of personal data (identified above under ‘Personal data we collect from you’) used for these purposes:
| Purpose of Processing | Legal basis for the processing | Categories of personal data used for the processing purpose |
|---|---|---|
| To provide and perform the services and products you requested from us# to execute a contract | "Performance of a contract Legitimate Interest" | "Client Data Business Partner Data Usage Data Academy Data" |
| It is mandatory for you to provide these data to FlowX.ai# so that we may perform the contract executed with you or with your employer/contractor. | ||
| To communicate with you with respect to any relevant business-related matters in connection to your requests (such as making you an offer) | "Performance of a contract Legitimate Interest" | "Client Data Business Partner Data Usage Data Academy Data" |
| If you do not provide us these personal data# we might not be able to initiate or continue such business communication with you. | ||
| To understand# diagnose# troubleshoot# and fix issues with the services and products we offer | "Performance of a contract Legitimate Interest" | "Client Data Business Partner Data Usage Data Academy Data" |
| It is mandatory for you to provide these data to FlowX.ai# so that we may provide the support services and to perform the contract executed with you or with your employer/contractor. | ||
| For marketing# promotion# and advertising purposes (including newsletters) | "Consent Legitimate Interest" | "Client Data Business Partner Data Usage Data Academy Data" |
| It is not mandatory for you to provide us these data. In case you have given your consent for receiving marketing communication from Flowx.ai# you can always withdraw your consent# with no consequences on the performance of our contract. | ||
| To comply with legal obligations and law enforcement requests | "Compliance with legal obligations Legitimate interest Performance of a contract" | "Client Data Business Partner Data Usage Data Visitor Data Academy Data Contests# Surveys and Sweepstakes Data" |
| To take appropriate action with respect to reports of intellectual property infringement and inappropriate content | Legitimate Interest | "Client Data Business Partner Data Usage Data Academy Data" |
| To establish# exercise# or defend legal claims | Legitimate Interest | "Client Data Business Partner Data Usage Data Visitor Data Contests# Surveys and Sweepstakes Data Academy Data" |
| To conduct business planning# reporting# and forecasting | Legitimate Interest | "Client Data Business Partner Data Usage Data Academy Data" |
| To detect fraud# including fraudulent payments and fraudulent use of the services and products | "Performance of a contract Compliance with legal obligations Legitimate Interest" | "Client Data Business Partner Data Visitor Data Usage Data Academy Data" |
| To conduct research# contests# surveys# and sweepstakes | "Consent Performance of a contract Legitimate Interest" | "Client Data Business Partner Data Usage Data Contests# Surveys and Sweepstakes Data Academy Data" |
| To maintain and ensure the safety of our premises# assets and personnel | Legitimate Interest | "Client Data Business Partner Data Visitor Data Image Data" |
| To process job and internship applications | "Legitimate Interest Consent" | Job Applicant Data |
| If you chose not to provide us these data# we may not be able to process your application. | ||
| "In accordance with the FlowX.ai Academy Terms: to generate reports on your usage and activity in the FLOWX.AI Academy; for your registration to exams/tests to be passed after a Course completion# administering exams and to determine if you passed the exams to acquire the Certifications; for providing you# in case you are a successful test taker# with Certification# as well as with digital certificates and printable/downloadable versions of the certificates; for tracking your individual Certifications renewals and additional Certifications obtained over time; for tracking the number of certified professionals employed by FLOWX.ai Partners# having acquired the Certifications under the FLOWX.AI Academy; for providing your employer/contractor# who is a FLOWX.AI Business Partner# with a general overview regarding its employees/collaborators learning activity in the FLOWX.AI Academy# the learning progress# how may learners completed the Courses and the Credentials obtained by such; for contacting you in relation to a potential partnership on sales." | "Performance of a Contract Legitimate Interest" | Academy Data |
| If you chose not to provide us these personal data# we will not be able to provide you the products and services available in the FlowX.AI Academy and your employer/contractor may not be able to benefit of a certain level in the FlowX.AI Business Partner Program. | ||
| "In accordance with the FlowX.ai Academy Terms: for statistical purposes# to generate reports on the general use and activity of/in the FLOWX.AI Academy# and to analyze the Materials# Courses# Credentials# Features and Certification made available in the FLOWX.AI Academy; for analyses# research# fulfilment and for any other purposes deemed necessary or appropriate to provide the FLOWX Academy under the FlowX.AI Academy Terms; to improve the testing program and testing experience in the FLOWX.AI Academy." | Legitimate Interest | Anonymized Academy Data |
| To confirm your identity# prevent fraud# and to otherwise help administer the services offered in the FlowX.ai Academy | Consent | Image Data |
If you do not provide us these data, we might not be able to allow you acces to a test/exam and to provide you the Certifications further to atending a Course in the FlowX.AI Academy.
If the data is processed based on FlowX.ai legitimate interest, you may require further information about the balancing test that FlowX.ai has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR - please contact us at mydata@FlowX.ai/ privacy@flowx.ai
When the personal data is required directly from you, FlowX.ai kindly asks you to provide the categories of personal data we request in the aforementioned purposes. In certain cases, if you do not provide the requested personal data, we shall not be able to carry out our activity (including, among others, to provide you with our services and products or to provide you the benefits of our FlowX.ai Academy).
If you provide to FlowX.ai the personal data of other natural persons, we kindly ask you to communicate to them, to inform them that you pass their personal data to FlowX.ai and on the modality in which FlowX.ai intends to process their personal data, as described in this Privacy Policy. If required by the GDPR and applicable legal provisions, you will also obtain their consent for FlowX.ai processing their personal data in the manner described under this Privacy Policy, if the basis for processing will the data subject consent.
We will not disclose nor sell your data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your data with certain third parties, as set forth below.
FlowX.ai affiliates
As FlowX.ai is a global company, we may disclose your contact details to our affiliates within FlowX.ai group, to be able to provide our services and products and to fulfill the purposes stated above.
Service providers
For the purposes described in this Privacy Policy and based on the legal grounds stated in this Privacy Policy, we may disclose your personal data to service providers we work with, and which may need access to certain personal data in order to provide their services to us and in order for us to provide our services and products to you.
These service providers may include those we've hired to provide customer support, to operate the technical infrastructure that we need to provide the services, assist in protecting and securing our systems and services, digital service providers, providers of marketing products and services, providers of platform allowing us to manage our data and activity (such as HubSpot) as well as service providers that helps us organize events, manage business information and contracts, store data, analyze and organize data.
Some of our contractors are also controllers on their own, carrying out processing activities while using their services and products, which include online advertising technologies, search engine, cloud computing.
Some of the contractors are third parties who are not intended to process the personal data but may have access to it upon fulfilling their tasks or interacting with us, such as technical maintenance companies, financial entities or legal auditors.
Your Academy Data may also be shared with the FlowX.ai Academy administrators, tutors and instructors, solely for the purpose of providing you the services and products associated with the FlowX.ai Academy and the support services required for your access and use of the FlowX.ai Academy.
Law enforcement
We might share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We might also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest, rights and safety, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business
We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer or to a potential investor. In this situation, FlowX.ai will continue to ensure the confidentiality of your personal data your personal data is transferred to the buyer or to the investor or becomes subject to a different privacy policy.
Relevant authorities
We will share your personal data to public authorities, auditors or institutions competent to exercise inspections on FlowX.ai, which may ask us to provide information, based on their legal obligations. Such public authorities or institutions may be relevant data protection authorities or authorities for consumer protection.
Credit and fraud-prevention parties
We may share your personal data with credit reference and fraud prevention agencies.
Academy users’ employees
As set forth under the FlowX.ai Academy Terms, if your Certifications are required to ascertain that a FlowX.ai Partner fulfils the necessary conditions to be qualified under a Partner program implemented at the level of FlowX.ai, your Certifications and Designations may be shared with Your employer/contractor if you perform any Course or obtain such a Certification in relation to your job at such employer/contractor.
You may also opt that your learning progress in the general reports shared with your employer/contractor. You may opt out of identifying you in the reports provided by FlowX.ai to your employers on its employees learning process in the FlowX.ai Academy.
Please note that by using a corporate email address or by choosing an affiliation in your profile, part of your Academy Data associated with your account, your learning progress and other usage data may be shared with the owner of the domain (e.g., your employer/contractor). You can always choose to use a personal email address instead of a corporate one when creating and using your account in the FlowX.ai Academy.
We will store and process your personal data only for the period of time necessary in order to achieve the purposes described to you in this Privacy Policy and in accordance with our legal and contractual obligations.
For executing the contracts we have concluded with you or with your employer/contractor, for the FlowX.ai products and services we store your personal data for the duration of the contract and after its termination, for a period of up to 3 years from such termination, except for the cases when legal requirements state otherwise. After the duration of the processing expires and FlowX.ai no longer has legal or legitimate basis to process your personal data, the data will be deleted in accordance with FlowX.AI procedures, which may involve archiving, anonymizing or destroying it.
In the case of Job Applicant Data, if no offer shall be provided to you in the recruitment process, or if you shall decline the offer provided you with, we shall immediately erase all your personal data from our system, as long as you do not request us to keep your data in our data base for future recruitments.
When we process your personal data based on your consent, we will stop the processing and delete such data as long as you notify us that your decided to withdraw you consent, unless we have compelling legitimate interests that override your rights under this policy and the GDPR.
When we process your personal data based on our legitimate interest, we shall process your personal as long as necessary to protect such interest.
When the processing is based on the need to comply with a legal obligation, we shall retain the data for as long as it is required to comply with such obligation.
With respect to your Academy Data, your data associated with your account in the FlowX.AI Academy note it is kept for fourteen (14) days after you close your account in the FlowX.ai Academy. We may retain and process your Academy Data after the fourteen (14) days period following the closing of your account in case of:
dispute resolutions around test taking and passing – until the dispute is finally settled;
if the Academy Data regarding the Courses and Certification you have acquired are required to confirm that your employer/contractor fulfils the necessary conditions to be qualified under a Business Partner Program implemented at the level of FlowX.ai – for the period of time until you are no longer an employee/collaborator of such Partner or until Partner decides to remove you from the list of such certified individuals.
With respect to your Academy Data, please bear mind that you may be subject to additional privacy policies available at the level of your employer/contractor or privacy laws applicable in the country of your jurisdiction. You are responsible for assessing compliance with your applicable privacy policies and laws when using the FlowX.ai Academy and the products and services available in the Academy.
In all cases, if you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data. We will make sure not to keep excessive or irrelevant data, such as data which is out of date.
In your capacity as data subjects, the GDPR provides you with a series of rights including:
the right of access – allowing you to obtain confirmation that your personal data is being processed by us and, if affirmative, the relevant details of such processing activities;
the right to rectification – allowing you to rectify your personal data if inaccurate;
the right to erasure (right to be forgotten) – allowing you to obtain the erasure of your personal data in certain cases (e.g., if the data is no longer necessary in relation to the purposes for which it was collected);
the right to restriction – allowing you to obtain the restriction of processing your personal data in certain cases (e.g., when you contest the accuracy of your personal data, for a period enabling us to verify such accuracy);
the right to object – allowing you to object to further processing of your personal data within the conditions and limits set forth by law. In particular, where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time;
the right to data portability – allowing you to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another data controller.
the right to object to direct marketing – from time to time, FlowX.ai may send emails containing information about new features and other news about us. This is considered direct marketing. Where personal data are processed for direct marketing purposes, you have the right to object at any time and free of charge to the processing of your personal data for direct marketing purposes by clicking “Unsubscribe” when you receive the respective e-mail or by writing at mydata@FlowX.ai. If you object to the processing for direct marketing purposes, your personal data shall no longer be processed for such purposes. These options, however, do not apply to communications which are related to finalizing orders, agreements, assistance, warnings regarding the safety of our products, or other administrative and transactional notifications, where the main purpose of such communications is not of promotion.
the right to submit a complaint: you will always have the right to lodge a complaint your national Data Protection Authority, including the National Supervisory Authority for Personal Data Processing (NSAPDP) at 28 – 30 Gheorghe Magheru Blvd., District 1, Bucharest (post code: 010336; phone no.: 0040 318.059.211). You also have the right to submit a claim with the competent courts against us should you consider that your rights under GDPR have been infringed as a result of our processing of your personal data, and against a NSAPDP legally binding decision concerning you and your personal data.
No fee is usually required for the exercise of the above rights.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond and contact details
We are happy to ensure your exercise of these rights. You may exercise your aforementioned rights and find out more about such rights by filing with us, as data controller, a written request at Charles de Gaulle Plaza 15, Charles de Gaulle Plaza street, 9th floor, Bucharest, Romania or by e-mailing us at mydata@flowx.ai/ privacy@flowx.ai. We shall review your request and reply within a 30-day term. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.
For preventing the unauthorized access or disclosure and for assuring the proper use of your data, we ensure reasonable and adequate, physical, technical and administrative measures, for protecting the data we collect and process.
When sensitive information is collected, transferred and kept, , we use appropriate technologies and procedures to help protect your data for the unauthorized access, use or disclosure.
Currently, the data is stored in our Google Drive, the access to it being restricted on a ‘need to know basis’. The Privacy Policy of Google Drive can be read here https://policies.google.com/privacy?hl=en-US#intro. A list of locations of the servers where the data stored in Google Drive are processed can be found here: https://www.google.com/about/datacenters/locations/.
FlowX.ai is a global company so your data is shared with FlowX.ai’s affiliates; therefore, in order to achieve the purposes described to you in this policy and in accordance with our legal and contractual obligations we may share your data with our affiliates located in Europe, United Kingdom and in the Unites States. We make sure that your data is kept and transferred safely, by respecting GDPR and the European legal requirements for data transfers.
Some of our external third-party suppliers may be based outside the European Union (“EU”). Their processing of your personal data will involve a transfer of data outside the EU. Whenever we transfer your personal data out of the EU, we endeavor to ensure one of the following safeguards is implemented:
we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy decisions;
where we use certain service providers, we may use specific contracts (standard contractual clauses) approved by the European Commission which give personal data the same protection it has in Europe and which cannot be changed by the parties;
where such data cannot be afforded one of the safeguards above, we shall only transfer such data outside the EU where it is necessary for performing our contract with you or we have your fully informed, active, clear and specific consent. We shall take all steps necessary to ensure that your personal data is protected when we transfer it outside the EU.
