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INFLOWW.COM

PRIVACY POLICY

 

Last update: June 11, 2024

 

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the infloww.com website (“Website”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“Users, “you” or “your”) and Infloww (“Infloww”, “we”, “us or “our”). If you are entering into this agreement in behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “Users”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services.
 

By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

 

Table of Contents

  1. Collection of personal information
  2. Automatic collection of personal information
  3. Privacy of children
  4. Use and processing of collected information
  5. Managing information
  6. Disclosure of information
  7. Retention of information
  8. Your rights
  9. International Transfers of Data
  10. Links to other resources
  11. Information security
  12. Data breach
  13. Use of AI powered algorithms
  14. Changes and amendments
  15. Acceptance of this policy
  16. Contacting us

 

 

 

 

 

 

 

 

 

 

 

 

I. Collection of personal information
 

When you wish to use our Services offered on our Website, you will be asked to provide Personal Information such as name, phone number, email address, postal address, billing information, date of birth, and other relevant information about you.

 

This type of information is collected by the following means:
 

-          Profile information : you give us information when on register and create a user account which will be used to verify your identity when you access the Services, including your username, password, date of birth, email address and/or telephone number and information you disclose in your profile.
 

-          User Content and Behavior Information : we collect and process the content you generate and view on the Service, including but not limited to the preferences you set, the videos, photographs, and audio you upload and the comments you make (“User Content”). We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content in order to provide personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect. We may access content, including text, images, and video, found in your device’s clipboard, with your permission. For example, if you choose to initiate content sharing with a third-party platform or choose to paste content from the clipboard into the Service, we access this information stored in your clipboard in order to fulfill your request. We also collect information regarding your use of the Services e.g., how you engage with the Services, including how you interact with the content we show to you and the videos you watch.
 

-          Survey and Promotions : we collect information through surveys, marketing campaigns and other events in which you participate. We use the personal information collected to communicate with or notify you about any campaigns, promotions, or special offer and generally to manage your participation.
 

-          Direct Messages : when you communicate with others using direct messages, we collect the content of the messages and the associated metadata such as the time when the message was sent, received and/or read). We use this information to block spam, detect crime and to safeguard our users.
 

-          Purchase Information :  Ordering or purchasing. When you make a purchase on the Service, we will use the personal information that is collected to process your request, to complete your transaction using the payment services offered by our preferred third-party payment services provider and when applicable, to deliver any information you may request on the Service.

 

 

 

II. Automatic Collecting of Information

Other personal information is automatically collected when you use our Services, including your IP address, the domain name and host from which you access the internet, the pages of the website that you visit, your browsing history, your browser software or operating system and your browser’s country setting. These informations are automatically collected in the following ways:

-          Consulting the content on the Websites:  when you browse our Services, information pertaining to your user behavior is collected by cookies and other technological means, as further described below. This personal information is used to personalize the content displayed on our Services and to improve the content recommendations intended for you.
 

-          IP addresses and navigation routes:  we collect the IP addresses (internet protocol) of all visitors to our website and their browsing history, as well as other information such as the pages visited immediately before or after our website, the pages requested, the type of browser, the operating system, your internet service provider, the number of times you have visited our website and the date and average time you spend on our website. We use this information to administer, monitor and improve our website and to analyze trends and usage patterns.
 

-          Cookies and other technologies: Cookies are small pieces of data stored on your device (computer or mobile device). Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a site upon a future visit. When used, cookies are downloaded and stored on your device. Such information, on its own, will not identify you personally. It is statistical data. You have the option to accept all cookies, accept some cookies while rejecting others, or reject them all. Rejecting functional cookies may prevent you from using certain portions or functionalities of our sites and Services. We may use such cookies to deliver and improve our Services. Some third-party services that we use to improve the Services (including usage, measuring performance, and advertising), such as Google Analytics, may also place cookies on your device.

Examples of Cookies we use:

            Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems.

            Performance & Analytic Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites.

            Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization.

            Advertising Cookies. These cookies deliver and measure the effectiveness of our marketing campaigns and may be set through our site by our advertising partners.

            Social Media Cookies. These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks.
The validity period of cookies for our sites and Services is 6 months. We will request a new prior consent after this period.
 

-          Other Security Specific Features: certain security-specific features of our Service may scan and analyze your files or network for security vulnerabilities and automatically collect certain information, such as IP address, device ID, MAC address, Mobile/PC environment, file metadata, URLs, Domains and IP addresses of websites visited, user or application behaviors, personal information contained within email content or files to which Infloww is provided access, information from suspicious emails, including sender and receiver email address, and attachments, network connection information, debug logs, network architecture/topology or screen capture of errors.
 

-          Content Characteristics and Features. We detect and collect characteristics and features about the video and audio recordings that are part of your User Content for example by identifying objects and scenery, the existence or location within an image of a face or other body parts and the words spoken in your User Content. We do this for content modernization and to provide special effects.


 

III. Privacy of Children
 

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us at [email protected] to request that we delete that child’s Personal Information from our Services.

 


IV. Use and processing of collected information
 

Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are data controllers because we determine the purpose and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.

 

In order to make the Website and Services available to you, or to meet legal obligations, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes :

        Create and manage user accounts

        Request user feedback

        Send product and service updates

        Respond to inquiries and offer support

        Improve user experience

        Enforce terms and conditions and policies

        Protect from abuse and malicious users

        Respond to legal requests and prevent harm

        Run and operate the Website and Services

        Informing our algorithm

        Marketing and promotion purposes

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies : (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with legal obligation to which we are subject; (iv) processing is necessary for the purpose of the legitimate interest pursued by us or by a third party.
 

 

V. Managing Information

 

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described above. If you would like to delete your Personal Information or permanently delete your account, you can do so by contacting us at [email protected].

 

 

VI. Disclosure of Information

 

Depending on the requested Services or as necessary to complete any transaction of provide any Service you have requested, we may share your information with our affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated third parties.

 

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.

 

We will share and disclose your information only with the following categories of Service Providers:
 

-          Cloud computing services

-          Communication and collaboration services

-          Data analytics services

-          Data storage services

-          Performance monitoring services

-          Product engineering and design services

-          User authentication services

-          Website hosting service providers

 

We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

 

 

VII. Retention of information

 

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information  after you update or delete it, but not in a manner that would identify you personally.

 

 

VIII. Your rights

 

Your Rights Under GDPR:

 

If you are a resident of the European Economic Area, you have certain data protection and privacy rights. In certain circumstances, you have the following privacy rights:

            - The right to access the information we have on you.

            - The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

            - The right of deletion. You can request us to delete the personal information we hold about you. Please note that this is not an absolute right and we might need to retain your personal information for compliance with laws or other legitimate reasons.

            - The right to object. You have the right to object to our processing of your personal information.

- The right of restriction. You have the right to request that we restrict the processing of your personal information.

            - The right to data portability. In certain circumstances, You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

            - The right to withdraw consent. You also have the right to withdraw your consent at any time when Platform.sh relies on your consent to process your personal information, though we may have other lawful bases for  processing your information for other purposes, such as those set above.

            - The right not to be subject to automated decisions including profiling. You have the right not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affects you.

             

            Please note that we may ask you to verify your identity before responding to such requests.

 

 

Your Rights Under Canada’s PIPEDA (Privacy Rights):

 

The Personal Information Protection and Electronic Documents Act (‘PIPEDA’) is the Canadian federal privacy law that regulates how private-sector organizations handle personal information in the course of commercial activity.

Infloww continuously strives to comply with PIPEDA Principles. We have procedures in place to receive and respond to any complaints and inquiries you may have. Contact us or email our Support Team  at [email protected].

 

If you are a resident of Canada you have certain privacy rights: the right to know why your personal information is being collected, how it will be used, and to whom it will be disclosed.  You also have the right to access, or correct, your personal information. This Privacy Policy serves this purpose.

 

 

 

 

 

Your rights under California Privacy Laws

 

The California Consumer Privacy Act (‘CCPA’) and the California Privacy Rights Act (‘CPRA’), (together ‘California Privacy Laws’), give California consumers/residents (or your authorized agent) certain privacy rights and impose corresponding, and independent, obligations on businesses processing California consumers’ personal information.

 

Infloww does NOT sell your personal information. We do NOT collect sensitive personal information as defined under California Privacy Laws. Where applicable, we have added contractual requirements instructing our service providers to not further collect, sell, share, or use the consumers’ personal information except as necessary to perform their respective business purpose.

 

If you are a resident of California you have certain privacy rights:
 

            - Right to know. You have the right to know about the personal information we  collect about you and how it is used and shared. This Privacy Policy serves this purpose.

            - Right to delete. You have the right to  request us to  delete your personal information and to tell our  service providers to do the same. However, there are many exceptions that allow businesses to keep your personal information. Please note that this is not an absolute right and we might need to retain your personal information for compliance with laws or other legitimate reasons.

            - Right to Correct. You have the right to request that we correct any inaccurate personal information about you.

            - Right to portability. You have the right to receive your personal information  in a portable and, to the extent technically feasible, readily usable format.

            - Right to opt-out of sale or sharing. Platform.sh does not sell or share your personal information within the meaning of California Privacy Laws.

            - Right not to be discriminated against for exercising any of your rights. We do not use financial incentive practices that are unjust, unreasonable, coercive, or usurious, and do not retaliate against those who choose to exercise their rights.

            - Right to Limit Use and Disclosure of Sensitive PI. You have the right to direct that we limit the use of sensitive PI to the use that is reasonably necessary to perform the services expected by you. We do not collect sensitive personal information as defined under the CCPA.

 

Your rights under Nevada Privacy Law

 

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.


 

IX. International Transfer of Data

 

We are located in Hungary, but the servers on which the Services and Website are currently hosted on are located in the United States of America. The Services and Website are hosted by Amazon Web Services. Therefore, you hereby grant your consent to the processing of your Personal Information outside of your current jurisdiction, and you acknowledge that such transfer is carried out in compliance with local privacy laws in relation to the collection, use, and saving of Personal Information. We will take all reasonable steps to ensure that your Personal Information is treated securely and in accordance with this Policy.

 

If you reside in the European Economic Area (EEA) or the United Kingdom (UK), your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK. When we transfer personal data outside the European Economic Area (EEA) to countries with and without an EU adequacy decision, pursuant to article 46 of the General Data Protection Regulations (GDPR), Infloww signs Data Processing Agreements (DPAs) or Standard Contractual Clauses (SCCs) with all processors. We also conduct Supplementary Measures Assessments on vendors who store personal data in non-adequate countries.

 

 

X. Links to other resources

 

The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.

 

 

XI. Information security

 

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclose. We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

 

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

 

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

 

 

XII. Data breach

 

We will report any unlawful data breaches to any and all relevant persons and authorities within 72 hours (or sooner if it is required under applicable privacy laws) of the breach when such breach is likely to result in a high risk to the rights and freedoms of data subjects. Infloww’s obligation to report or respond to a personal data breach or security incident will not be construed as an acknowledgement by Infloww of any fault or liability with respect to the personal data breach or security incident. Should you have any complaint about a breach, or the way in which we will handle a breach, please contact us.

 

XIII. Changes and amendments

 

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided. 

 

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different from what was stated at the time your Personal Information was collected.

 

 

XIV. Acceptance of this policy

 

You acknowledge that you have read this Policy and agree to all its terös and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

 

 

XV. Contacting us

 

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:

[email protected]