PRIVACY POLICY

1. Introduction 

Flowace Technologies Private Limited (“Flowace” / “we” / “our” / “us“) develops an automated time tracking software (“Flowace Software“) designed to monitor time spent by you on work-related activities, including idle time tracking. This Privacy Policy outlines our data collection, usage, storage and protection practices. By using any part of the Flowace platform (including applications, websites, and services), you acknowledge our data handling practices.

Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Terms of Service.

2. The Scope of this policy

We appreciate your trust in Flowace. Protecting your privacy and maintaining transparency in our data handling practices is our priority. This Privacy Policy provides an overview of the data collected through our application and highlights the sensitive information that remains confidential. We are committed to securing your data through robust security protocols and ongoing improvements. This policy applies to all users of the Flowace platform, covering all Flowace applications, websites and related services (collectively the “Flowace Platform“). 

Your use of the Flowace Platform is also governed by our Terms of Service and other policies. By accessing or utilizing any part of the Flowace Platform, you confirm your awareness and acceptance of our data practices and policies.

Flowace functions in both the capacity of a data controller and a data processor. As a data controller, we determine the purposes and methods for processing your personal data. In contrast, we serve as a data processor when handling personal data on behalf of our users.

In our role as a controller, we manage information such as supplier contact details, user login credentials, and data utilized for our internal security and research purposes. Conversely, we operate as a processor when managing personal data on behalf of our users, such as when we handle data related to a user’s employee using the Flowace Platform.

3. The Information We Collect

When you use the Flowace platform, we gather the information you provide, details of your usage, and data about your device. Additionally, we may collect information from other sources, such as third-party services and optional programs you engage with, like surveys, which we may merge with other data we hold about you. Below are the types of information we collect:

3.1. Data you Share with Us

a. Account Registration 

When you register for an account with Flowace, we collect the information you provide, including your name, email address, photograph, physical address, and payment details. You may also choose to share additional information during the registration process.

b. Communications 

When you reach out to us or we initiate contact with you, we collect any information you provide, including the content of any messages or attachments you send to us.

c. Background check and identity verification

We collect background check and identity verification information of Users, including but not limited to your family history, place of residential address and proof of identity. This information can be collected by a third-party provider as well on our behalf. 

d. Customer Support 

You provide us with information related to your use of our services, including copies of your messages, and how to contact you so we can provide you customer support. For example, you may send us an email or an in-app feedback with information relating to our app performance or other issues faced by you while using the app.

 e. Billing Information 

If you subscribe to paid services, we ask you for information like full name of the person or entity that will pay for the services, their place of residential address and GST number to authenticate the subscriber of our services. 

3.2. Data collected during use of the Flowace Platform

a. Information from Website Visitor: Like most website operators, Flowace collects basic non-personally identifiable information from visitors to the Flowace Platform that is commonly provided by web browsers and servers. This includes details such as browser type, language preference, referring site, and the date and time of each visitor’s request. We gather this data to better understand user interactions with the website, enhance the website and user experience, and monitor its security.

b. Device Related Data: We collect information regarding the devices used to access the Flowace Platform, including device model, operating system version and device identifiers.

c. Collection of Personal Location Data 

1. Your location may be available to us through any of the following instances (together: your “Location”): 
2. We may collect your exact location, via your Compatible Device, which permission will be deemed to have been provided upon your using of the Flowace Platform and your consent to share your location with the services (in relation to which Software Development Kits (“SDK”) are installed or embedded in). Please note that we collect real time location. 
3. We may assume your location, if you are connected to a Wi-Fi whose assumed location is known to us. 
4. We may assume your location by collecting the data with respect to the network cell which you are connected to, if the location of that cell is known to us. 
5. Your country, city and region may be available to us from your Internet Protocol (“IP”) collected by the SDK or other Data Sources or from other data shared with us by third parties (for example through Real-Time Bidding (RTB) integration). 
6. Please note that by disabling your geo-location permission to the services (through the mobile device operating system), your location may still be assumed and/or collected by us from other available sources detailed hereinabove. 

d. Usage and Log Information 

We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our services) log files, and diagnostic, crash, website, and performance logs and reports. 

e. Transactional Information 

If you pay for our services, we may receive information and confirmations, such as payment receipts, including from other third parties processing your payment. 

f. Device and Connection Information 

We collect device-specific information when you install, access, or use our services. This includes information such as hardware model, operating system information, browser information, IP address, mobile network information including phone number, device identifiers and also whether the device has access to an internet connection at all times. We also collect device location information in order to track the location on real-time basis and for diagnostic and troubleshooting purposes such as if you are having trouble with our app’s location service. 

g. Platform Usage Data 

We collect data regarding your use of the Flowace Platform, including the time you begin and end work, tasks or projects worked on, applications used on your device, websites visited, and screenshots of your desktop. We also gather details about your interactions with the Flowace Platform, such as the pages and content you view, as well as the dates and times of your usage.

The Flowace desktop application records keystrokes and mouse movements but does not track where you click on the screen, nor does it record the content of what you type. It is not designed as a keylogging tool.

h. Use of Cookies, Analytics, and Third-Party Technologies 

We gather information through the use of “cookies,” tracking pixels, data analytics tools (such as [Google Analytics]) and other third-party technologies to analyze how you navigate the Flowace Platform and engage with Flowace advertisements. This data helps us understand popular content, improve your user experience, and retain your preferences.

For more information regarding the cookies we use please refer to our Cookie Notice.

3.3 Information We Receive from Third Parties

a. Third-Party Services 

We receive certain information from third-party services that are essential to the functionality of the Flowace Platform. These third-party services include payment processors, marketing providers, and other business partners. The following types of information may be obtained about you from these third parties:

Financial data, including payment details, transaction history, and fraud detection information;

Information about you shared by marketing service providers (such as Meta and Google), including demographic and market segmentation data.

b. Information from Employers or Organisations 

If you access Flowace through your employer or another organization, we may collect information about you from those parties, such as your name and contact details.

4. Ways we utilize your data

4.1. Provision of the Flowace Platform

We utilize your personal data to enhance your experience on our platform, making it more intuitive, efficient, and valuable. This is done in accordance with the following uses of your personal information:

As a data controller, we:

1. Verify your identity and manage your account, preferences, and settings;
2. Process payments;
3. Communicate with you regarding your user experience;
4. Gather feedback on your experience; and
5. Enable additional services and programs with third-party collaborators.

As a data processor, acting on behalf of our users, we:

1. Operate the platform and provide work activity information to employers.

4.2. Our Services

We operate and provide our services, including providing user support, and improving, fixing, and customizing our services. We understand how you use our services and analyse and use the information we have to evaluate and improve our services, research, develop, and test new services and features and conduct troubleshooting activities. We also use your information to respond to you when you contact us. We use cookies to operate, provide, improve, understand, and customize our services. 

4.3. Payment Facility 

We use the information in order to offer subscription plans and other offers and prepare, execute and facilitate in the payment process required for subscribing to our services or any other features of add-ons that may be availed of, by the user. 

4.4. Account Creation

We use the information to create and update user accounts in order for the services to operate. 

4.5. Ensuring the Security and Safety of the Flowace Platform and its Users

Ensuring a secure and safe experience is fundamental to our Flowace Platform. In this regard, we act as a data controller and use your personal information to:

a.Authenticate users;

b. Identify and prevent fraud; and

c. Block or remove unsafe or fraudulent users from the platform.

4.6. Providing User Support

We strive to offer an optimal experience, including assistance when required. As a data processor, acting on behalf of our users, we utilize your personal information to:

1. Investigate and help resolve any inquiries or issues related to the platform; and
2. Provide support or respond to your queries.

4.7 Enhancing the Flowace Platform

We continuously work to improve your user experience and introduce new features. As a data controller, we use your personal information to:

1. Conduct research, testing, and analysis;
2. Develop new products, features, partnerships, and services;
3. Identify, prevent, and fix software or hardware issues; and
4. Monitor and enhance our operations, processes, security practices, algorithms, and modeling.

4.8. Marketing Activities

Where appropriate consents are obtained, we may use your personal information to contact you for marketing purposes, including informing you about our products, services, and offers.

4.9. Compliance with Legal Requirements and Legal Proceedings

In some cases, we are obligated by law, regulatory authorities, or other governmental bodies to respond to certain demands or obligations. In these instances, we may use your personal information as a data controller to comply with such legal requirements. Additionally, we may use your personal information to defend legal claims or exercise our legal rights when necessary.

5. Lawful Basis for Processing Personal Information

When processing your personal data as a controller under the applicable Indian data protection laws, and other applicable laws along with relevant data protection frameworks, we are required to establish a lawful basis for processing your information. We rely on the following lawful grounds to process personal data:

Purpose of Processing	Lawful Basis
Account setup and Management on the Flowace Platform	Legitimate Interests – It is in our legitimate interests to efficiently set up and manage user accounts to ensure the smooth operation of our business.
Security and Fraud Prevention	Legitimate Interests and Legal Obligation – We have a legitimate interest in maintaining a secure platform and preventing fraud. We are also legally obligated to take steps to protect personal data and ensure its security.
Platform Improvement and Development	Legitimate Interests – It is in our legitimate interests to conduct research, testing, and analysis to improve and enhance our products and services.
Marketing and Promotional Activities	Consent – Where legally required, we obtain your consent before sending marketing communications. Legitimate Interests – Where consent is not required by law, we rely on our legitimate interest in promoting our products and services to support business growth.
Legal Compliances and Legal Claims	Legitimate Interests – We have a legitimate interest in defending legal claims and asserting our legal rights.
Compliance with Government and Regulatory Requests	Legal Obligation – When legally required by Indian laws or regulations or any other applicable law, we will respond to requests from regulatory authorities and government agencies. In other cases, while we may not be legally obligated, it may be in our legitimate interests to provide personal information to support our position.

6. How We Share Your Data

We do not sell your personal data. In order to ensure the functionality of the Flowace Platform, we may need to share your personal data with other users, third parties, and service providers. This section outlines when and why we may share your data.

6.1. Sharing Between Flowace Users

Your Company and Managers

The data collected from your usage of the Flowace Platform is shared with your company’s admin, your manager(s) (as designated by the company admin), and yourself. Monitoring of website and application activity is active for all users when they are actively tracking time. Screenshot monitoring may be individually enabled or disabled by your company’s admin for all or specific members of your team.

6.2. Sharing With Third-Party Service Providers for Business Purposes

Depending on whether you are an admin or a user, Flowace may share the following categories of personal information to facilitate the provision of our services:

1. Personal identifiers, such as your name, address, email address, and phone number;
2. Financial details, such as bank routing numbers, tax information, and payment-related data you provide;
3. Commercial data, including feedback and transaction history;
4. Internet or electronic network activity information, such as your IP address, browser type, operating system version, device manufacturer/carrier, device identifiers, and mobile advertising identifiers.

We share these categories of personal data with service providers to fulfill the following business functions:

1. Account maintenance and servicing;
2. Order processing and fulfillment;
3. Customer support services;
4. Identity verification for users;
5. Fraud detection and prevention;
6. Marketing and advertising services for Flowace;
7. Financial services;
8. Analytics services for Flowace; and
9. Conducting internal research to enhance the Flowace Platform.

6.3. For Legal Purposes and to Safeguard the Flowace Platform

We may disclose your personal data in response to a legal obligation or if it is deemed necessary or appropriate to:

1. Comply with applicable laws, regulations, or regulatory inquiries or legal processes, including enforceable governmental requests;
2. Respond to legal processes such as subpoenas, search warrants, court orders, or summons;
3. Enforce our Terms of Service;
4. Cooperate with law enforcement agencies regarding activities we reasonably believe may violate any applicable laws; or
5. Exercise or defend legal claims and protect the rights, property, and safety of our platform, users, third parties, or the public, as permitted or required by law.

6.4. In Connection with a Corporate Sale or Merger

Your personal data may be shared during negotiations or in relation to a change in corporate control, such as a merger, acquisition, or sale of assets.

6.5. Upon Your Consent or Instruction

With your consent or at your direction, we may disclose your personal data to interact with third parties or for other purposes you specify.

7. International Data Transfers

Your personal data may be transferred, processed, and stored in countries outside of your country of residence. These countries may have different data protection laws than those in your home jurisdiction. When transferring your data internationally, we ensure that appropriate safeguards are in place to protect your personal data in compliance with applicable data protection regulations.

8. Data we do not have access to

We respect your privacy and ensure that certain types of data are not collected or accessed by us.

We prioritize user privacy and security by limiting the data we collect and ensuring strict access controls.

We do not collect or store your passwords for any website or application, keeping your login credentials fully secure and private. Similarly, we do not access the content of your documents or files, only gathering metadata such as file paths and modification timestamps to focus solely on tracking work-related activities. Personal communications, including messages and emails, are not monitored, as our tracking is strictly limited to work-related activities during business hours.

Within our organization, data access is tightly controlled, with only authorized personnel granted access to resolve technical issues or provide support, ensuring user privacy. Additionally, we do not store payment card details; all financial transactions are securely processed through Stripe using PCI-compliant encryption standards.

9. How We Store and Protect Your Information

Flowace ensures that your personal information is stored securely and protected through various security measures. Below are the details of how we store and safeguard your data.

9.1. Data Storage 

All data is securely stored on AWS cloud servers, with different storage types allocated based on the nature of the data. To enhance security, all server communications are protected through TLS encryption. Our servers are housed in highly secure data centers that undergo continuous monitoring and receive dedicated hosting support.

9.2. Software Development Security 

We adhere to strict security protocols in our software development process, utilizing a Git version control system. Every code modification undergoes automated testing, manual code reviews, and extensive staging environment testing. Critical updates are prioritized but are subjected to thorough testing before deployment.

9.3. Security Measures 

The services are equipped with standard security features including implementation of appropriate physical, electronic and managerial procedures to protect and safeguard the confidentiality and security of your information and to help prevent unauthorized access to your information and to maintain data security. Data is encrypted in transit as well as at rest. Personal information provided at the time of registration is encrypted before being uploaded to the cloud where it is stored in a secure encrypted server. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. 

We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your personal information secure. You should not share your user name, password, or other security information for your Flowace account with anyone. If we receive instructions using your user name and password, we will consider that you have authorized the instructions. 

Along with this multiple layers of security are implemented to safeguard user data:

1. Daily Backups : Regular data backups are conducted to maintain consistency and facilitate quick recovery when necessary.
2.  Encrypted Data Transfers (HTTPS) : All communications between user devices and Flowace servers are secured through HTTPS encryption, ensuring safe data transmission.
3. Secure Password Management : We enforce strong password policies and use encryption techniques to protect login credentials.
4. Internal System Logging : Comprehensive logging mechanisms are in place to detect, monitor, and respond to unauthorized activities.
5. Network & Infrastructure Security : Robust security protocols are implemented to protect our network and infrastructure from cyber threats.

10. Your Rights and Control Over Your Personal Data

Flowace provides users with the ability to access, modify, delete, and exercise other rights related to their personal data, giving them control over how their information is handled.

11. General Rights for All Users

11.1. Email Subscriptions 

You may unsubscribe from our promotional or marketing emails at any time by clicking the unsubscribe link in those messages. However, you will continue to receive transactional and account-related emails regarding your use of the Flowace Platform. Flowace Platform sends automated system notifications that are essential for account management, service updates, and usage summaries. These communications may include, but are not limited to:

• Account activation and onboarding messages
• Service updates, including trial expiration reminders
• Important account-related notifications, such as potential data deletion warnings
• Usage summaries and insights

11.2. Push Notifications 

You can disable push notifications by adjusting your device settings. However, opting out may impact your experience and limit certain platform functionalities.

11.3. Profile Information 

Users can review and update their profile details by accessing the profile section within their account settings.

11.4. Location Tracking 

Flowace collects location data only if its mobile application is installed on your device. You can disable location tracking by adjusting your device’s system settings and turning off location services.

11.5. Cookie Tracking 

You can choose to accept or deny cookies through the Cookie Notice on our website. However, disabling or denying cookies may affect certain features of the platform.

11.6. Deleting Your Account 

If you wish to delete your Flowace account, you must contact your company administrator. In some cases, account deletion may not be possible, particularly if the account is involved in an active legal dispute or fraud investigation.

11.7. Retention After Account Deletion 

Even after account deletion, certain information may be retained for legitimate business purposes or to comply with legal and regulatory obligations. For example, data related to an ongoing legal claim must be preserved but will not be used for any other purposes. Aggregated data will continue to exist even after an account is deleted.

11.8. Response Timing and Format 

We aim to process user requests related to data access, correction, restriction, or deletion within 30 days of receiving the request. If additional time is required, we will provide a written explanation outlining the reason and extended timeline.

12. Links to Third-Party Websites

Our website may contain links to third-party websites that are not operated by us. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of these third-party websites before providing them with any personal data. Please contact those websites directly if you have any questions about their privacy policies. 

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. If we make significant changes to this policy, we will notify you by posting an updated policy on our website. The “Effective Date” at the top of this policy will indicate when the latest changes were made. We urge you to periodically check this Privacy Policy for any changes. 

14. Contact Us

If you have any questions or concerns about your privacy or anything in this policy, including if you need to access this policy in an alternative format, please contact us at [email protected].