Privacy Policy

Created on 7 March, 2020 • 6,039 views • 11 minutes read








We will NEVER sell your personal data



This Privacy Policy applies to personal data processed by FlowReplay in our business, including on our websites and other online or offline offerings (a “Service” or collectively, the “Services”). FlowReplay enables the visitors of its site, www.flowreplay.com, to be in control of their personal data. We also provide controls that allow FlowReplay’s users/customers to have control over the privacy of personal data that is captured by our service. This Privacy Policy provides information about how FlowReplay processes and protects this data.


FlowReplay considers data protection and privacy to be of paramount importance. We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”) (specifically but not limited to Article 6(1)(b) to (f) and Article 28) as well as the Laws of Spain, where FlowReplay is incorporated.


If you are a visitor of a site which is running services provided by FlowReplay (“FlowReplay Enabled Site”), the ‘End Users’ section of this Privacy Policy applies to you.


For the purpose of this Privacy Policy, personal data means any information relating to an identified or identifiable natural person (or household as applicable); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “Personal Data”).


Responsibility for Processing Personal Data


FlowReplay bears responsibility for lawfully processing your data as carried out on our site.


What kind of Personal Data is processed and for what purpose?


Usage Data


When you visit our site we store the name of your internet service provider, the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit. While we process your IP address during the duration of your session, the IP address is not stored.


We process this usage data to facilitate your access to our services (e.g. to adjust our services to the device you are using), and to recognize and stop any misuse which is in our legitimate interest. The legal basis for this data processing is Article 6(1)(f) GDPR. We also process usage data in an aggregated or de-identified form for statistical purposes and to improve our site.


Cookies


FlowReplay uses cookies to process information including standard internet log information and details of the visitor’s behavioral patterns upon visiting our site. This is done to provide you with a better experience, and to facilitate the use of certain functions. Cookies are small data files transferred onto computers or devices by sites for record-keeping purposes and to enhance functionality on our site. FlowReplay stores this information in a pseudonymized user profile. FlowReplay does not process this information to identify individual users or to match it with further data on an individual user.


Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit FlowReplay’s site with cookies deactivated, you may possibly not be able to use all of the functions on our site to the full extent.


Analytics


We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.


Contact with us via email


On our site you have the opportunity to contact us to ask us questions. We can ask you for your contact information (e.g. name, email address etc.). We use this data solely in connection with answering the queries we receive.


If you receive emails from us, we may use certain analytics tools, to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns.


FlowReplay Account


When you sign up for and open an account with FlowReplay, or sign up for content or offers, we may ask you to provide us with information such as your name, email address and details about your organization. As otherwise detailed in this Privacy Policy, we will solely process this information to provide you with the service you signed up for. Please refer to our Terms and Conditions for further details on registering and using the services offered by FlowReplay.


You may deactivate your FlowReplay account and/or unsubscribe from receiving content or offers from us at any time by accesing to https://flowreplay.com/account and clicking over the "Delete" button. Following termination of your account, we may retain your personal data (in part or in whole) in order to meet any regulatory and reporting requirements for the timeframes stipulated by law and in order to be able to address customer service issues. Any other personal data we would have been processing on your behalf would be deleted permanently within 30 calendar days.


Access and Disclosure to Third Parties


FlowReplay does not sell, and has not sold, consumers’ Personal Data at any time. Except as provided below, we also do not share or disclose your Personal Data.


We use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered  and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions. In addition to services providers, other categories of third parties may include:







  • Vendors/public institutions: to the extent that this is necessary in order to make use of certain services requiring special expertise (such as legal, accounting or auditing services) we may share your personal data with vendors of such services or public institutions that offer them (e.g. courts). The legal basis of this data processing is Art. 6(1)(f) GDPR.

  • Disclosures to Protect Us or Others: we may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity; depending on the concrete issue, the legal basis for such processing may be Art. 6(1)(b), (c) or (f) GDPR.

  • Disclosure in the Event of Merger, Sale, or Other Asset Transfers: if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. The legal basis for such processing would be Art. 6(1)(f) GDPR as such processes are in the legitimate interest of FlowReplay.


Other than the cases mentioned above, we will only pass your data on to third parties without your express consent if we are obliged to do so by statutory law or an instruction by a public authority or court as outlined in our Terms and Conditions.


Notice regarding Third-Party Websites


The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by FlowReplay. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.


We want to Communicate with You


We may occasionally send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach), you shall have the opportunity to unsubscribe from receiving these messages free of charge.


Your Data, Your Rights


You have a right to be informed of Personal Data processed by FlowReplay, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from FlowReplay a structured, common and machine-readable format of Personal Data you provided to us.


We can only identify you via your email address and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with us directly and/or you using our site and/or service. We cannot provide, rectify or delete any data that we store on behalf of our users or customers.


To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of Personal Data you may contact FlowReplay’s support team: info@flowreplay.com.


Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the FlowReplay Site and/or Services. You further agree that FlowReplay shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.


Where Personal Data is processed for the above purposes on the basis of FlowReplay’s legitimate interests, under the GDPR, you may object to such processing at any time. To do so please contact : info@flowreplay.com.


In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.


Duration of Processing


We will store your usage data until such time when you withdraw your consent for us to do so. All other data as specified above will be retained for as long as is necessary for the purpose(s) for which we originally collected it. We may also retain information as required by law.


International Transfers of Personal Data


FlowReplay’s customer information is stored in the European Union.  In some limited cases, customer information may be accessed from, or other data (e.g., e-mail) may be transferred to, the United States or other countries which may have data protection laws that are different from the laws where you live. FlowReplay has taken appropriate safeguards to require that your Personal Data will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.


Children’s Information


The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Data from children. If you learn that your child has provided us with Personal Data without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Data in violation of Applicable Law, we will promptly take steps to delete such information and terminate the child’s account.


Revisions to this Privacy Policy


We may revise this Privacy Policy from time to time. The most current version of this Privacy Policy will govern our practices for collecting, processing, and disclosing personal data. We will provide notice of any modifications by posting a written notice on our site. All changes to this Privacy Policy automatically take effect on the sooner of the day you use the site and/or services, or 30 calendar days after they are initially posted on our site. Your use of the site and/or services following the effective date of any modifications to this Privacy Policy will constitute your acceptance of the Privacy Policy, as modified.


End Users


If you are a visitor of a FlowReplay Enabled Site, this section applies to you.


The data that FlowReplay processes for a FlowReplay Enabled Site is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers, not this Privacy Policy. This section should always be read in conjunction with the specific Privacy Policy of the FlowReplay Enabled Site which will contain further details regarding the processing of your personal data by the FlowReplay Enabled Site.


FlowReplay assists its users/customers in providing their end users with a better experience and service as well as assist them in diagnosing technical problems and analyzing user trends. Most importantly, through FlowReplay’s services, the functionality of the FlowReplay Enabled Site can be improved, making them more user-friendly, more valuable, and simpler to use for the end users.


You may opt-out from having FlowReplay collect your information when visiting a FlowReplay Enabled Site at any time by adding the following query parameter in your browser to the FlowReplay Enabled Site: ?pixel_optout=true (eg: if the FlowReplay Enabled Site URL is domain.com, then your can opt-out of the tracking by accessing domain.com/?dpixel_optout=true).


Contact Email


You can contact us by sending an email to:


info@flowreplay.com