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Privacy Policy

In compliance with applicable data protection regulations, Fusion Projects LLC (hereinafter "Flow" or "we") informs users about the collection, processing and protection of their personal data.

Applicable Regulations

  • General Data Protection Regulation (GDPR) of the European Union - Regulation (EU) 2016/679.
  • Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (LOPDGDD) – Spain.
  • Federal Trade Commission (FTC) regulations and U.S. state privacy laws, including the California Consumer Privacy Act (CCPA), where applicable.

This Privacy Policy explains how Flow collects, uses, stores and protects the personal data of users and merchants that interact with its platform.

Access to and use of Flow's services implies acceptance of this Privacy Policy. If the user does not agree with the terms described herein, he/she must refrain from using the platform.

1. Data Controller

Adapted version for Fusion Projects LLC (Spain and USA)

Data Controller

Fusion Projects LLC (hereinafter "Flow" or "we") is the entity responsible for the processing of personal data collected through its platform and services.

Contact Information

  • United States (Head Office) : Fusion Projects LLC 131 Continental Dr, Suite 305, Newark, DE 19713, USA
  • European Union (Office in Spain) : Fusion Projects LLC – Spain Office Calle Vitruvio 12, Bajo B, 28006, Madrid, Spain
  • Email : contact@getflow.com

2. Data We Collect

Flow collects and processes the following types of personal data in accordance with your relationship with the platform, whether as a merchant or end customer.

2.1 User Registration Data

Users who register with Flow provide:

  • Name
  • Surnames
  • Contact email
  • Phone number
  • Address including country, state and city

Note: Flow does not collect or store users' financial data or payment methods, as transactions are managed directly by Stripe.

2.3 Browsing and Platform Usage Data

Flow automatically collects certain technical and navigation data when a user accesses the platform, with the aim of improving the user experience and optimizing the performance of the service.

Data Collected

  • IP address
  • Cookies and tracking technologies
  • Behavioral data on the platform
  • Unique device identifiers
  • Approximate location (based on IP address, only if user allows)

Analytics Tools

  • Use Google Analytics and other tracking tools

Deactivation Options

  • Cookie settings on the platform
  • Privacy preferences on browser or device
  • Google Analytics Opt-Out Options

3. Purpose of Data Processing

3.1 For Businesses

  • Loyalty program management
  • Account Management and Billing
  • Technical support and customer service
  • Communicating updates on the platform

3.3 For Platform Improvements and Business Development

  • Data analysis and segmentation to optimize promotions and commercial strategies
  • Personalization of the user experience on the platform
  • Evaluating and improving system security

3.4 For Legal Compliance and Regulatory Requirements

  • Compliance with tax, regulatory and data protection regulations
  • Responding to requests from competent legal authorities in the US and the European Union

Limitations on Data Use

Flow will not use personal data for purposes other than those described without the prior consent of the user or merchant.

4. Legal Basis for Processing

Flow processes personal data based on the following legal grounds, in accordance with applicable regulations in the United States (US) and the European Union (EU).

4.1 User Consent

Flow obtains user consent to:

  • The use of cookies and tracking technologies
  • Sending personalized marketing communications and promotions
  • The collection of optional data that is not necessary for the execution of the contract

4.2 Execution of a Contract

Data processing is necessary for the provision of the service when:

  • A user registers on Flow and uses the platform to manage their events, conferences, classes and services.
  • It is necessary to process information for the correct operation of the service

4.3 Legitimate Interests of Flow

Flow has a legitimate interest in processing personal data to:

  • Analyze and improve the platform
  • Detect and prevent fraud or unauthorized access
  • Respond to queries and provide technical support

4.4 Compliance with Legal Obligations

Flow may process data when necessary to:

  • Comply with tax, regulatory and privacy regulations in the US and EU
  • Respond to requests from competent authorities within the applicable legal framework

Right to revoke consent

Users may revoke their consent at any time by sending a request to contact@getflow.dnce. However, this revocation will not affect data processing carried out prior to their request.

5. Cookies and Tracking Technologies

Flow uses cookies and similar technologies to improve user experience, analyse platform traffic and personalise content.

For more details on the types of cookies used, their duration and management options, users can consult the [Flow Cookie Policy], available on our website.

6. International Data Transfers

Flow operates internationally, so personal data collected may be transferred to and stored on servers located outside the user's country of residence, including the United States (AWS) and Spain.

6.1 Data Location

Personal data is stored and processed at:

  • United States (AWS – Amazon Web Services)
  • Spain (Office in Madrid)

6.2 Protective Measures

Flow implements security measures to ensure the protection of personal data in the event of international transfers:

For users in the European Union (EU) and the European Economic Area (EEA)

  • Complies with the General Data Protection Regulation (GDPR)
  • Implements Standard Contractual Clauses (SCCs) approved by the European Commission
  • Apply encryption and access control measures for data security

For users in the United States

  • Follow Federal Trade Commission (FTC) guidelines
  • Complies with state regulations such as the California Consumer Privacy Act (CCPA)

6.3 User Consent

By using Flow services, users agree that their data may be transferred outside their country of residence under the conditions and security measures described.

7. Security and Data Protection

Flow implements technical and organizational measures to ensure the security of personal data and prevent unauthorized access, alteration, loss or disclosure.

7.1 Security Measures Implemented

Data Encryption

  • Personal data stored on AWS servers in the US is protected using encryption in transit and at rest.

Access Control

  • Only authorized Flow personnel have access to personal data, and only for specific operational purposes.
  • Authentication and authorization mechanisms are applied to prevent unauthorized access.

Monitoring and Auditing

  • Periodic audits are carried out and systems are monitored to detect unauthorized access or attempted breaches.

Measures against security breaches

  • In the event of detecting a security breach affecting personal data, Flow will notify the competent authorities and the affected users within the applicable legal deadlines.

8. User Rights

Users have rights over their personal data, in accordance with United States and European Union legislation.

8.1 Recognized Rights

Users may exercise the following rights in relation to their personal data:

  • Access : Obtain information about what personal data is being processed by Flow
  • Rectification : Request the correction of inaccurate or incomplete data
  • Deletion (Right to be Forgotten) : Request the deletion of your personal data when it is no longer necessary or if you withdraw your consent
  • Objection : Request that your data not be used for certain processing purposes (e.g. personalized advertising)
  • Limitation of Processing : Restrict the processing of your data in certain circumstances
  • Portability : Get your data in a structured, commonly used format and transfer it to another service provider

8.2 Exercise of Rights

Users may exercise their rights by sending a request by email to contact@getflow.dance with the subject: "Exercise of Data Protection Rights".

To ensure the security of personal data, Flow may require the user to verify his or her identity before processing the request.

8.3 Data Protection Authorities

If a user considers that Flow has not handled their request appropriately, they may lodge a complaint with the relevant data protection authority:

  • European Union : Spanish Data Protection Agency (AEPD) – www.aepd.es
  • United States : Regulation varies by state, but users in California can contact the California Privacy Protection Agency (CPPA) – www.cppa.ca.gov

9. Data Retention and Deletion

Flow retains personal data only for as long as necessary to fulfill the purposes of the processing and to comply with applicable legal obligations in the United States and the European Union.

9.1 Retention Periods

Business Data

  • They are stored as long as the account is active on the platform.
  • Once the merchant cancels your account, the data is retained for a period of 90 days and then anonymized.

End Customer Data

  • They are kept as long as the client keeps their digital card active on their device.
  • If the customer deletes his loyalty card, the data remains in the merchant's system.
  • If the merchant deletes its account, the associated customer data is anonymized within 90 days.

Browsing Data and Cookies

  • They are stored according to the cookie policy, with variable periods depending on the type of cookie used.

9.2 Data Deletion

When a user requests deletion of their data, Flow will apply one of the following measures:

  • Anonymization : Instead of deleting data completely, Flow anonymizes it so that it cannot be linked to a specific user.
  • Total Deletion : In cases where there is no legal justification for retaining the data, it will be deleted from Flow systems.
  • Data Blocking : If the law requires the retention of certain data, Flow will store it in a restricted manner without using it for other purposes.

Request for Deletion

Users can request deletion of their data by sending an email to contact@getflow.dance with the subject: "Data Deletion Request".

10. Modifications to the Privacy Policy

Flow reserves the right to modify this Privacy Policy to reflect changes in applicable law, its services or its privacy practices.

10.1 Notification of Changes

If material changes are made to this Privacy Policy, Flow will notify users at least 15 days in advance by:

  • Email registered in the user or business account
  • Notification within the platform

Your continued use of Flow services after the effective date of the changes constitutes your acceptance of the new version of the policy.

10.2 Cancellation Option

If a user or business does not agree with the changes, they may request the cancellation of their account before the date the new terms come into effect, without penalty.

Users can send their cancellation request to contact@getflow.dance with the subject: "Account Cancellation Due to Privacy Policy Changes."

11. Contact

For any queries, requests for information or exercise of rights related to this Privacy Policy, users may contact Flow through the following means:

Email

  • General privacy inquiries : contact@getflow.dance
  • Technical support and customer service : support@getflow.dance

Contact Phones

  • Spain - European Union: +34 672 816 160

Physical Addresses

  • EE.UU. : 140 Carl Brashear Dr, Unit 18, Bayonne, NJ, 07002, USA
  • European Union - Spain : Calle Arte Figurativo 14, 5A, 28051, Madrid, Spain

11.1 Hours of Operation

Monday to Friday: 9:00 AM - 6:00 PM (Madrid, Spain time)