OUR COMMITMENT TO YOUR PRIVACY

FLOW.ING ESCOLA DE IDIOMAS E GASTRONOMIA LTDA (“Flow.ing”), registration number (CNPJ) 36.280.152/0001-32 takes all necessary measures to protect the User’s privacy, in compliance with applicable privacy and data protection legislation. This document details the forms of collection, storage, use, sharing and disclosure of your personal data, as well as it clearly outlines the measures taken to ensure the protection of the collected data.

DATA COLLECTION, USE AND STORAGE

User account

To create a User Account on the platform, the User must fill out a registration form.

The registration data may be used to send advertising and promotional messages to the User about products, services, promotions and / or news from Flow.ing and its partners.

The data provided by the User will be stored and used by Flow.ing or hired third parties, to supply the products for the site, carry out commercial and financial transactions, process payments, share data, send promotional e-mails, products, services and marketing campaigns, store the history of interactions with the website, promote retargeting campaigns, generate statistics and leads, personalize website pages and verify bank details to prevent fraud.

The data may be shared with third parties or Flow.ing’s partners under the terms of this Policy, noting that the creation of each User Account or any registration on the Site, for which it is necessary to send any personal data of the User,  presupposes consent regarding the collection, use, storage and processing of personal data, including with regard to the generation of statistics and data processing.

The User is responsible, for the accuracy and updating of the data provided (including personal data) and Flow.ing disclaims any liability for damages resulting from the          incomplete or inaccurate registration given by the User, under any means or form, or, even, by the use of this registration in an improper way by any third party not authorised to use such data or, still, by third parties who have, duly or improperly, obtained the User’s data for access on the Site.

In case of cancellation of the account by the User, Flow.ing reserves the right to save the information and / or data whose maintenance is imposed due to legal and / or regulatory obligations or whose maintenance is necessary for compliance judicial order, within the scope of judicial and / or administrative proceedings and questioning of third parties arising from the activities performed by the User on the Platform.

Cookies

In order to offer the best browsing experience to the User, Flow.ing uses technologies to collect and store information related to the User’s visits on the Site and this may include the sending of one or more cookies or anonymous identifiers that collect data related to browsing preferences and pages visited by the User. In this way, the presentation of the Site is personalised and aligned with the User’s personal interests. The use of this data can assist in the generation of statistics and leads. The User can, at any time, if he disagrees with the cookie policy above, use the tools of his browser that prevent the installation of cookies, or delete any existing cookies on his internet connection device. In this case, some features of the Site may have errors. Flow.ing may also use other technologies for the collection of User browsing data, committing itself to save, treat and use them in accordance with this Policy.

Usage Data

Flow.ing will keep in its database all information related to the User’s access to the Site, including, but not limited to, the IP address, the pages accessed, the access times and dates, and the access device used, under current legislation. Such records may be used in internal or public investigations to investigate practices that may cause any damage to Flow.ing or third parties, including the practice of crimes in virtual environments, as well as in the generation of statistics and leads.

Generation of Statistics and Leads

Flow.ing may collect browsing data from its User in the form of this privacy policy, in order to assist in the generation of statistics and leads.

Other

Flow.ing may collect personal data about the User that are voluntarily entered by him / her in the Site navigation process. Finally, Flow.ing may access public or private databases to confirm the accuracy of the personal data provided by the User, including data related to payments.

USE OF DATA

Flow.ing will use the User’s e-mail primarily to send information about their registration and their interactions with the system, as well as anything else necessary so that there is no harm to the parties. The registered email will also be used for communication and to recover the Client’s access password, in case of loss or forgetting.

In addition to the above, Flow.ing may, at its sole discretion, use the User’s personal data in the following ways: (i) registration update; (ii) ensuring the safety of the User; (iii) responding to requests from the User; (iv) information about changes to the Terms and Conditions of Use or Policies; (v) preparation of statistics and leads regarding the use of the Site, including for the purpose of improving and understanding the profile and for improving the Site; (vi) improvement of interactivity tools between the Site and the User; (vii) compliance with court orders; and (viii) defense of Flow.ing’s rights against the user in judicial or administrative proceedings.

STATISTICS AND LEADS

The registration data and navigation information of the User may be used for the preparation of statistics, as well as for the generation and commercialisation of non-reversible leads to the User.

RETENTION OF DATA

Flow.ing will store all data collected in its protected and secure databases. In case the User requires the deletion of his data from the database, Flow.ing reserves the right to keep the data in question in backup copies for up to 6 (six) months, in order to comply with legal obligations of mandatory custody.

Flow.ing may delete your information when the purpose for which the information was collected has been achieved or when the data is no longer necessary to achieve this purpose, when the consent provided by the User is revoked or upon determination of the competent authority.

The User may also request the deletion of his collected data by contacting Flow.ing, through one of our indicated Service Channels, informing by request. Flow.ing will make every effort to fulfill your requests in the shortest time possible.

The User understands that the exclusion of certain data may make it impossible to make certain functionalities available, through the Platform, due to its operational aspect, without any indemnification. Flow.ing reserves the right to keep all data necessary to comply with Brazilian legislation in force, even if it is requested to be excluded.

INTELLECTUAL PROPERTY

The contents made available on the Platform, such as computer programs, files, texts, icons, drawings, videos, sounds, brands, logos, layouts, teaching materials, logos, distinctive signs, algorithms, templates, images, content, photographs, graphics, links , visual and audiovisual works in general, are the exclusive property of Flow.ing, or third parties who have granted authorisation for such use and exploitation, and are protected by international laws and treaties, and their copying, reproduction, storage, transmission, exhibition, placement, edition, commercialisation, as well as the creation and development of new works and materials derived from the contents of the Platform, or any other type of use (total or partial), through any type of material support that exists today or that may exist in the future, be it analogue or digital, with offenders subject to the corresponding civil and criminal sanctions, under the terms of Laws 9.279 / 96, 9.610 / 98 and 9.609 / 98.

Thus, the User must use the Platform in accordance with Brazilian and International legal order regarding the protection of intellectual property, as well as the other specific instructions, terms and regulations existing on the Platform, refraining from reproducing, copying, storing, transmitting, displaying, publishing, editing, marketing, assigning, licensing improperly or without prior authorisation from Flow.ing, by any means, platform or existing support or that may exist in the future, the content available on the Platform and other social networks, blogs and domains owned by Flow.ing.

All brands, distinctive signs, commercial names or logos of any kind, made available on the Platform are the property of Flow.ing or third parties that have granted authorisation for such use and exploitation, without the use of the Platform being understood as authorisation so that the User can quote, use, explore and reproduce such marks, distinctive signs, commercial names and logos.

The User acknowledges that Flow.ing may, at any time, remove from the Platform and / or replace, alter any service available, without the need for prior notice and without any indemnity of any kind to the User due to such removal / replacement / change.

SECURITY

Technological resources. Flow.ing adopts advanced technological resources to guarantee the security of sensitive, confidential data and passwords, such as the use of encryption and the installation of barriers against improper access to the database (firewalls).

Password secrecy. Flow.ing recommends that the User keeps his/her password completely confidential, avoiding its disclosure to third parties. Flow.ing will never ask the User to enter their password outside the Site, by phone, e-mail or any other means of communication. The User’s password must be used exclusively when accessing the User’s account on the Site. If the User suspects that his password has been exposed to third parties, Flow.ing recommends the immediate replacement of the password.

Suspicious emails. Flow.ing sends the User emails only with advertising messages, promoting products and services or updating information. Flow.ing does not send messages (i) requesting personal data from the User; (ii) requesting the User’s password or financial data; (iii) or with attached files (except PDF). If you receive an email with such features, please disregard it and contact us.

Impossibility of accountability. Despite Flow.ing’s greatest efforts, the current stage of technology does not allow the creation of a database absolutely safe from attacks. In this way, Flow.ing disclaims any liability for damages eventually caused by third parties, including invasions on the Site or in the database, by viruses or by leakage of information, unless it is proven by a court decision to be Flow.ing’s fault.

DISCLAIMERS OF LIABILITY

Flow.ing will not be responsible:

• For any unavailability, errors and / or failures of the Platform;

• For possible errors and / or inconsistencies in the transmission of data from the network, as well as related to the quality or availability of the internet connection capable of preventing the adequate receipt of information by Flow.ing or by the User;

• For outdated, incomplete and / or untrue data possibly presented through the Platform;

• For using the Platform in violation of these Terms;

• For the damages and losses of all kinds resulting from the knowledge that unauthorised third parties may have to data made available through the Platform, due to a failure exclusively related to the User or to third parties that are beyond the reasonable control of Flow.ing; and

• For the presence of viruses or other harmful elements on the Platform, capable of causing changes in their computer systems (software and hardware) or in electronic documents stored in their computer systems.

USE OF DATA IN CASE OF FLOW.ING CONTROL CHANGE

The collected data may eventually be transferred to a third party in the event of a change of control, an acquisition, a merger, a merger or a sale of Flow.ing assets in any way or form.

CONTACT

If you have questions about our privacy policy, please email us at contact@flowingbv.com

Flow.ing – Updated July 15, 2020.