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Privacy Policy

Updated Jul 27, 2018, version 1

General Information

This Privacy policy contains information to a data subject as required by the EU General Data Protection Regulation (“GDPR”) and the Argentinian Personal Data Protection Law N°25.326. The Privacy policy provides also general information about Flowing Code’s data protection principles to developer community members, customers and other stakeholders.

The controller and contact information

Name: Flowing Code S.A. (“Flowing Code”)
Street address: Boulevard Galvez 1933 Dto. 3, 3000, Santa Fe, Argentina
Contact person: Martín López, [email protected], +54-342-4123621
Related to the rights of the registered or any data protection matters, contact [email protected]

The name of register

Name: Flowing Code CRM and community register

The purpose and legal basis for personal data processing

Purposes of processing personal data

Flowing code uses personal data mainly to maintain information about developer community members and customers, and to distribute this information within the company.
Personal data may be used for the following purposes:

  • Provisioning, supply, production and design of products and services.
  • Order fulfilment, invoicing, reporting and other related matters.
  • Customer service, customer relationship management, direct marketing, advertising and related communications.
  • Polls and market surveys.
  • Fulfilling statutory obligations.

Legal basis of processing

The primary basis for the processing of personal data is 1) a contractual relationship with Flowing Code or actions preceding contractual relationship, 2) a consent of the registered, 3) statutory obligation and 4) legitimate interest of the controller.

Data content of the register

The categories of persons whose data can be processed are 1) customers or suppliers (current or former), 2) registered Service users, or 3) persons who have been in contact with Flowing Code.
The following information may be stored in the register:

  • Basic information, such as name, language, address, e-mail address and telephone number.
  • Customer relationship information, such as order details, invoices, service or product usage data, direct marketing authorizations and prohibitions.
  • Information and content provided by the data subject, such as contact requests or forum messages.
  • Information related to use of products and services, such as the browser, IP address, time of visit, visited pages and browsing history.
  • Information related to communication, such as emails, chat history and call recordings.

Recipients of personal data

Personal data may be disclosed within Flowing Code, and with suppliers responsible for Flowing Code’s data processing tasks. Personal data may also be disclosed to relevant authorities in statutory cases.

Personal data retention period

Personal data may be processed during the contractual relationship and other legal basis for processing the data. Once the legal basis has ended, the data will be erased in accordance with the applicable legislation.

Personal data sources

Personal data is obtained primarily from the data subjects themselves. Personal data may also be collected when using Flowing Code’s products and services.

Transfers of personal data

Personal data may be transferred outside Argentina and/or outside the European Union or the European Economic Area, including the United States, in accordance with and within the limits of data protection laws.

Data protection methods

The use of systems or electronic registers containing personal data is restricted to Flowing Code’s employees and suppliers only, who work under a non-disclosure agreement and are bound by data protection requirements.
Any printed and other physical material is kept in a locked space that is accessible by authorised personnel only.
The data is stored in servers and databases, which are protected by firewalls, passwords and other technical means.
Persons authorised to access personal data receive regular training related to data protection, and data protection arrangements are audited regularly.

Data subject’s rights

The Registered has certain rights related to personal data that Flowing Code possesses of the Registered, including the following:

  • Right to inspect personal data relating to the Registered.
  • Right to rectify incorrect, unnecessary, incomplete or outdated information.
  • Right to erase personal data.
  • Right to restrict processing of personal data.
  • Right to oppose processing of personal data.
  • Right to data portability.

If the registered needs to exercise any of the rights of the Registered, he or she shall contact Vaadin using the contact information provided in this Privacy Notice. In order to ensure effective processing of the request, the registered is advised to specify the request in detail, and describe the content and context accurately. Flowing Code may request additional information regarding the requests, as well as reliable identification of the person making the request.


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Changes in privacy notice

Flowing Code reserves the right to change this Privacy Policy at any time. We recommend that you review the contents of this policy regularly.

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