Privacy and Data Protection Policy

We value the privacy and security of our users' personal information. This Privacy Policy explains how we collect, use, and safeguard your information when you use Fluwerio platform and all the services that are attached to it (the "Service"). By accessing or using the Service, you agree to the terms of this Privacy Policy.

This Cookies Consent Notice (“Notice”) governs the use of cookies, pixels, local storage, and similar tracking technologies (collectively, “Cookies”) on our website and services (the “Service”). It is designed to comply with the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act as amended by CPRA (CCPA/CPRA), Brazilian Lei Geral de Proteção de Dados (LGPD), and Chinese Personal Information Protection Law (PIPL). By continuing to use the Service, you consent to the practices described herein. You may withdraw or manage consent at any time via the Cookie Settings of your browser.

1.1 Personal Information: When you sign up for our Service, we may collect certain personal information, such as your name, email address, contact details, and billing information. We only collect information that is necessary for providing the Service and improving user experience.

1.2 Usage Data: We may automatically collect information about how you interact with the Service, including your IP address, browser type, device type, operating system, and other technical information. This data helps us analyze trends, administer the Service, and improve its functionality.

1.3 Cookies and Tracking Technologies: We use cookies and similar tracking technologies to enhance your experience and collect information about your usage patterns. Cookies are small text files stored on your device that enable us to recognize your browser and capture certain information.

2.1 Cookies are small data files placed on your device to enable core functionality, analyze performance, personalize content, and deliver targeted advertising.

2.2 We classify Cookies into four categories to meet transparency requirements under all applicable laws:

• Strictly Necessary: Essential for site navigation and security (exempt from consent under GDPR Art. 5(3) ePrivacy, CCPA “service delivery,” LGPD “regular exercise of rights,” PIPL “necessary for contract”).
• Performance/Analytics: Measure visits, bounce rates, and errors (e.g., Google Analytics with IP anonymization).
• Functionality: Remember language, login state, or preferences.
• Marketing/Targeting: Serve interest-based ads across sites (e.g., Meta Pixel, Google Ads).

3.1 Strictly Necessary Cookies: GDPR/UK GDPR Art. 6(1)(b) “contract necessity”; LGPD Art. 7(II) “execution of contract”; PIPL Art. 13 “necessary to conclude/perform contract”.

3.2 All other Cookies: GDPR/UK GDPR Art. 6(1)(a) “consent”; LGPD Art. 7(I) “consent”; PIPL Art. 14 “separate consent”. Consent is granular, freely given, and revocable.

4.1 Right to Know/Access: Request list of Cookies, purposes, categories of data, and third-party recipients (GDPR Art. 15; CCPA §1798.110; LGPD Art. 18; PIPL Art. 44).

4.2 Right to Opt-Out of Sale/Sharing: Disable Marketing Cookies via “Do Not Sell or Share My Personal Information” link (CCPA/CPRA “sale” & “sharing” for cross-context behavioral advertising; GDPR “Legitimate Interest” objection; LGPD “treatment opposition”; PIPL “automated decision-making refusal”).

4.3 Right to Delete: Erase non-essential Cookies and associated data (GDPR Art. 17; CCPA §1798.105; LGPD Art. 18; PIPL Art. 47).

4.4 Right to Non-Discrimination: No denial of service or price increase for exercising rights (CCPA §1798.125; GDPR Art. 21).

4.5 Right to Portability: Receive Cookie data in structured format where technically feasible (GDPR Art. 20; LGPD Art. 18).

5.1 First-layer banner offers “Accept Cookies,” option. Settings persist for 12 months (GDPR Rec. 25; PIPL “reasonable period”).

5.2 Withdraw consent anytime via browser reset (clears local storage). Signal honored: Global Privacy Control (GPC) for CCPA opt-out.

5.3 Children: No intentional collection under 13 (COPPA) or 14 (LGPD/PIPL). Parental consent required where applicable.

6.1 Partners (Google, Meta, Cloudflare, etc.) act as independent controllers or processors. Full list in Cookie Declaration (updated quarterly).

6.2 Transfers outside EEA/UK/Brazil/China rely on:

• EU Standard Contractual Clauses (SCCs) + UK International Data Transfer Addendum
• CCPA-limited data contracts
• LGPD Standard Clauses (ANPD)
• PIPL Security Assessment or SCC filing with CAC where >100k records

6.3 Retention: Strictly Necessary (session–6 months); Analytics (13 months); Marketing (90 days max).

7.1 Supervisory Authorities: ICO (UK), CNIL/DPC (EU), Pro-Consumer (CCPA), ANPD (Brazil), CAC (China). Complaints may be lodged with any.

7.2 Data Protection Officer: connect@fluwerio.com

7.3 Requests: Submit via email above . Response within 30 days (GDPR/LGPD) or 45 days (CCPA, extendable).

8.1 We reserve the right to amend this Notice. Material changes notified via banner or email. Continued use post-update means acceptance.

9.1 Provide and Improve the Service: We may use your information to provide, maintain, and improve our Service, including personalizing your experience, processing transactions, and responding to your inquiries and support requests.

9.2 Communication: We may use your email address to send you important updates, announcements, and promotional materials related to the Service. You can opt out of receiving marketing communications at any time by following the instructions provided in the email.

9.3 Analytics and Aggregated Data: We may use the information we collect to analyze trends, monitor the usage of the Service, and gather demographic information. This data is aggregated and anonymized, ensuring that it does not identify individual users.

10.1 Service Providers: We may share your personal information with trusted third-party service providers who assist us in delivering the Service, such as payment processors and customer support platforms. These providers are obligated to protect your information and can only use it for specified purposes.

10.2 Legal Compliance: We may disclose your information if required by law, court order, or government regulation, or if we believe such action is necessary to comply with legal obligations, protect our rights or the rights of others, or investigate potential violations.

10.3 Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction. We will notify you via email and/or a prominent notice on our website before your personal information becomes subject to a different privacy policy.

11.1 We implement reasonable security measures to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please be aware that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

12.1 Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information from our records.

We reserve the right to modify this Privacy Policy at any time. We will notify you of any changes by posting the updated Privacy Policy on our website and updating the "Effective Date" at the top. Your continued use of the Service after the changes take effect constitutes your acceptance of the revised policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our support team at connect@fluwerio.com.