SimFlow Privacy Policy

This Privacy Policy (“Policy”) details our practices regarding collecting, gathering, processing or other undisclosed use of any personal data SimFlow may acquire from its Users, Customers and Trade Partners.
General information

§ 1

SimFlow Technologies Spółka z Ograniczoną Odpowiedzialnością, Nowogrodzka 31, 00-511 Warszawa, registered in the National Court Registry under the number 0000435352, REGON 146327825, NIP 7010355760 is the controller of all personal data gathered during the course of any mutual agreements between SimFlow and its users.
For the purpose of this Policy, “controller” should be interpreted in accordance with Article 4 Section 7 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), which is as follows: (…) the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (…)
The aforementioned Regulation is the legal basis for all data processing during the course of mutual agreements between Parties.

Scope of data gathering

§ 2

We do not collect any personal data without prior consent from the Users, Clients or Trade Partners. Please note, that in case of a User, Client or Trade Partner that is not a consumer (e.g. legal entities or other entrepreneurs), the other Party must ensure that any person contacting us on behalf of the aforementioned agrees to have their personal data processed by SimFlow.
We will also never, under any circumstances, process personal data of certain categories, which include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
We do not transfer personal data to third countries nor international organisations.

Types of data processed

§ 3

We collect following data from our Users, Clients and Trade Partners:
contact information: e-mail, Name and Surname;
billing information: name of the Company/other viable entity, address, credit card number and expiration date, bank account number when applicable;
technical information: MAC ID of the device on which our Products are installed, OS version, technical errors regarding the functionality of our Products;
feedback: suggestions, questions and views of our Products;
background information – reasons why a User had chosen our Product and the purpose it is used for;
third party information – provided by selling platforms, such as MyCommerce.
Please note that not all of the abovementioned is personal data as referred to by the law.

Reasons to process your data

§ 4

The purpose of data gathering and processing is first and foremost to provide the User with technical support regarding our Products, when necessary. In certain cases, we may also process your personal data for other reasons, so-called “justifiable purposes”, which include, but are not limited to:
billing, invoicing and other operations involving the purchase of our Products and the matter of payments;
legal claims arisen from any contracts between SimFlow and the Users, Clients and Trade Partners;
processing data at behest of proper authorities, whenever necessary and in accordance with legal procedures;
undertaking steps to secure personal data, should any risks and dangers occur;
entrusting your data to a service provider who will process data on our behalf, in which case you will be informed of their identity and provided with contact details. Note that in this instance we take full responsibility and accountability for all the actions of an appointed data processor.
Aside from reasons stated above, we process other data in order to improve our Products and analyze demand for improvements. Whenever any personal data is processed for reasons other than stated in § 4.1., we ensure that it is anonymized and cannot be linked with a particular User.

Consent to process data for marketing purposes

§ 5

Notwithstanding terms of data processing laid down in § 4, you may also specifically give us the permission to use your personal data for marketing purposes, such as advertising our new Products and/or informing you of updates, patches or other downloadable content of our previously existing Products. This consent does not entail the right to disclose your personal data to third parties.
We shall never give your personal data to third parties, with the exceptions mentioned in § 3.

Your rights as a subject of data processing

§ 6

Your data is processed as long as the relevant Product License Agreement is in effect, or until you request your data to be erased. Any Person who gave us the permission to process their personal data, may revoke that permission at any time and ask us to remove it completely from our database (“the right to be forgotten”). Please note, that in such cases we might not be able to continue providing support for your copy of the software. Your data will be erased without any undue delay.
You may also request of us to provide you with all of your personal data in our possession. In such case, you will receive an .xls file containing all your personal data processed by us.
You may request to have your personal data transmitted directly to other indicated parties.

§ 7

You may at any point request that your data be corrected, should it be inconsistent or invalid. You may also demand that we completed your incomplete data.

§ 8

You may demand that the processing of your personal data be restricted, should you think that:
your data is inaccurate;
data processing is unlawful, yet you choose not to exert the right to be forgotten;
we no longer need your personal data for the purpose of processing, but you need us to keep it for the establishment, exercise or defence of legal claims to which you are a party;
you object, on grounds relating to your particular situation, to processing of personal data related to justifiable purposes mentioned in § 3, in which case we will demonstrate the grounds on which your data is processed.

§ 9

Should you feel that your personal data is being mishandled, you may file a complaint with proper authorities, in this case – President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, PUODO).
Profiling

§ 10

You will never be subject to any automated decision – making process involving your personal data. We do not profile our Clients, Users nor Trade Partners based on personal data gathered.

Security measures

§ 11

We make every effort to ensure that the tools we are using in order to store your personal data are compliant with legal regulations, as well as safe from any possible breaches in security. All of your personal data is protected by multi-layer encryption methods. No third party has access to devices used by SimFlow.
If, however, your personal data were in danger of being compromised or an actual breach should occur, you will be immediately notified.

SIMFLOW, LTD. COOKIE POLICY

Below you will find detailed information on what are cookies and how we use it on our website.

1. What are cookies?

Generally speaking, cookies are small text files which hold certain data sent by a website to the user’s browser. They are usually kept on the user’s hard disk drive and accessed by the website during user’s subsequent visits. Some of the cookies are tailored towards enhancing the user’s experience, other are tools used by the developers of the website for other purposes (e.g. statistics).
Cookies do not collect any personal data stored on the user’s device.

2. What kind of cookies do we use and what is their purpose?

We only use third-party cookies provided by Google Analytics, which is a tool to monitor traffic on our website. We only use cookies for statistics. We do not use them for marketing purposes nor advertising. The information gathered is completely anonymized, so there is no way that we could link information stored in your device to your personal data.

You may read Google Privacy Policy below:

https://www.google.com/intl/en/policies/privacy/

3. Do I have to enable cookies to access Simflow’s website?

No, you don’t. Our website is compatible with browsers that allow to disable cookies – although if you decide not to, it helps us immensely in context of improving user experience. Using the information gathered by Google Analytics, we are also able to further develop our Products, including free trial versions available to anyone interested. In a way, if you’re interested in our offer, enabling cookies is in your best interest, however you’re not obliged to do so in any way.

You may read how to disable cookies in your browser and how to delete them from your hard drive here:

http://www.allaboutcookies.org/

4. Are there any threats involving the use of cookies?

Yes, there are. While cookies themselves are only text files and cannot be executed, if your device is not protected against spyware, such malicious software may read information stored in cookie files (such as your browsing habits) and use it for unlawful purposes (such as displaying contextual advertising without your consent). Please note, that should such things occur, it is very unlikely that the cookies in question are the cause of the issue – it is more likely that your device was infected with malware.
In order to be completely safe, please make sure to update your antivirus software on a regular basis.

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