Privacy Policy
Privacy Policy
Last updated: 07/21/2025
1. Introduction
1. Introduction
With this information, FlowWing Labs LLC, a limited liability company registered in the State of Wyoming, USA, with its principal office at 5830 E 2nd St., Ste 7000 #26210, Casper, Wyoming 82609, USA (hereinafter, the "Company" or "FlowWing Labs LLC" or the "Owner"), as owner of the processing of personal data, intends to provide, in a transparent and detailed manner, the information in relation to the personal data of users that the Company collects, the methods of processing and the subjects to whom the same are transferred, as well as the precautions taken to protect such data and the rights of users.
This information is prepared in compliance with the provisions of EU Regulation 2016/679 (the "GDPR") and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 (jointly, the "Privacy Legislation"). For any question relating to this information, the Data Controller can be contacted at the following email address: contact@flowwinglabs.io.
With this information, FlowWing Labs LLC, a limited liability company registered in the State of Wyoming, USA, with its principal office at 5830 E 2nd St., Ste 7000 #26210, Casper, Wyoming 82609, USA (hereinafter, the "Company" or "FlowWing Labs LLC" or the "Owner"), as owner of the processing of personal data, intends to provide, in a transparent and detailed manner, the information in relation to the personal data of users that the Company collects, the methods of processing and the subjects to whom the same are transferred, as well as the precautions taken to protect such data and the rights of users.
This information is prepared in compliance with the provisions of EU Regulation 2016/679 (the "GDPR") and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 (jointly, the "Privacy Legislation"). For any question relating to this information, the Data Controller can be contacted at the following email address: contact@flowwinglabs.io.
2. Scope Of Application
2. Scope Of Application
FlowWing Labs LLC offers, through its website https://flowwing.io/ (the "Site") the following services: a) Legal consultancy in the financial and blockchain sectors; b) Smart Contract Solution for component development, tokenization and NFT solutions; c) Brand Management. This policy applies to all users who use the Services, the Platform, the applications and/or interact in any other way with FlowWing Labs LLC and/or technologies connected to the Platform. With reference to the processing of personal data through cookies and similar technologies, please refer to the information on cookies.
FlowWing Labs LLC offers, through its website https://flowwing.io/ (the "Site") the following services: a) Legal consultancy in the financial and blockchain sectors; b) Smart Contract Solution for component development, tokenization and NFT solutions; c) Brand Management. This policy applies to all users who use the Services, the Platform, the applications and/or interact in any other way with FlowWing Labs LLC and/or technologies connected to the Platform. With reference to the processing of personal data through cookies and similar technologies, please refer to the information on cookies.
3. Personal Data Being Processed
3. Personal Data Being Processed
FlowWing Labs LLC processes Personal Data to establish and manage commercial relationships and deliver Services. Some data may also be obtained from credit agencies, business registers, public sources, or third-party providers.
FlowWing Labs LLC processes Personal Data to establish and manage commercial relationships and deliver Services. Some data may also be obtained from credit agencies, business registers, public sources, or third-party providers.
3.1 Contact Information
3.1 Contact Information
When you request our services, we may process: Natural persons — name, surname, date of birth, residential address, telephone number, email address, tax code, photo. Legal entities — company name, registered office, tax code.
When you request our services, we may process: Natural persons — name, surname, date of birth, residential address, telephone number, email address, tax code, photo. Legal entities — company name, registered office, tax code.
3.2 Data for Due Diligence
3.2 Data for Due Diligence
For anti-money laundering and know-your-customer checks, we may collect: copy of government-issued ID (passport, driver's license, identity card); proof of address (utility bill); Politically Exposed Person (PEP) status; video or biometric data for remote identification and authentication.
For anti-money laundering and know-your-customer checks, we may collect: copy of government-issued ID (passport, driver's license, identity card); proof of address (utility bill); Politically Exposed Person (PEP) status; video or biometric data for remote identification and authentication.
3.3 Financial Data
3.3 Financial Data
During Service use, we may collect: bank details (IBAN, BIC); payment service provider information; payment data and transaction IDs.
During Service use, we may collect: bank details (IBAN, BIC); payment service provider information; payment data and transaction IDs.
3.4 Log Data
3.4 Log Data
When you use the Site, we collect: IP address and transaction data; device and browser details (OS, browser type, device identification); usage metrics (frequency, timestamps); cookies and similar technologies; crash reports and performance data.
When you use the Site, we collect: IP address and transaction data; device and browser details (OS, browser type, device identification); usage metrics (frequency, timestamps); cookies and similar technologies; crash reports and performance data.
3.5 Company Information
3.5 Company Information
If you represent a business, we may record: corporate records and structure; beneficial owner details; information on commercial activities; powers of attorney or other authority documentation.
If you represent a business, we may record: corporate records and structure; beneficial owner details; information on commercial activities; powers of attorney or other authority documentation.
3.6 Support Requests
3.6 Support Requests
If you contact our support team, we process any Personal Data you provide to assist with your inquiry.
If you contact our support team, we process any Personal Data you provide to assist with your inquiry.
3.7 Marketing Data
3.7 Marketing Data
When you interact with our Website or social media, we may collect: visitor counts and click statistics; geographic location and usage patterns; cookie and pixel data (e.g. ClearGIF); interests, preferences, and survey responses.
When you interact with our Website or social media, we may collect: visitor counts and click statistics; geographic location and usage patterns; cookie and pixel data (e.g. ClearGIF); interests, preferences, and survey responses.
3.8 Application Data
3.8 Application Data
For job applicants, we may process: contact details, CV, qualifications; criminal record checks and credit reports (if required); copies of IDs; links to social media profiles.
For job applicants, we may process: contact details, CV, qualifications; criminal record checks and credit reports (if required); copies of IDs; links to social media profiles.
3.9 Special Categories of Data
3.9 Special Categories of Data
We generally do not process "special categories" of Personal Data (sensitive data under Article 9 GDPR).
We generally do not process "special categories" of Personal Data (sensitive data under Article 9 GDPR).
3.10 Biometric Data
3.10 Biometric Data
With your explicit consent, we may collect biometric data (e.g. facial images, fingerprints) solely to perform due diligence checks.
With your explicit consent, we may collect biometric data (e.g. facial images, fingerprints) solely to perform due diligence checks.
3.11 Data Controller
3.11 Data Controller
Biometric and other Personal Data is processed under the responsibility of our Data Controller, Shehroz Khan.
Biometric and other Personal Data is processed under the responsibility of our Data Controller, Shehroz Khan.
4. Purpose Of The Processing
4. Purpose Of The Processing
In general, the user's Personal Data is collected to allow the Owner to provide the Services, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of other users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: activities relating to pre-contractual information and any further activity instrumental to the signing and execution of the contract with third-party operators; periodically notifying the user about tariffs and responding to requests for assistance; fulfillment of legislative or regulatory obligations; sending of commercial communications and newsletters exclusively with express consent; and profiling and statistics exclusively with express consent. Any use of cookies or other tracking tools has the purpose of providing the Services used from time to time by the user.
In general, the user's Personal Data is collected to allow the Owner to provide the Services, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of other users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: activities relating to pre-contractual information and any further activity instrumental to the signing and execution of the contract with third-party operators; periodically notifying the user about tariffs and responding to requests for assistance; fulfillment of legislative or regulatory obligations; sending of commercial communications and newsletters exclusively with express consent; and profiling and statistics exclusively with express consent. Any use of cookies or other tracking tools has the purpose of providing the Services used from time to time by the user.
5. Legal Bases of the Processing
5. Legal Bases of the Processing
FlowWing Labs LLC will process the user's Personal Data in compliance with the provisions of the Privacy Law by virtue of the following legal bases: where Personal Data is necessary for the execution of the general conditions of the Services; if the Personal Data is subject to profiling, based on express written consent; if the user has given consent for one or more specific purposes; where Personal Data is necessary for the execution of a task of public interest; where processing is necessary for the pursuit of legitimate interests; and for fulfilling legal obligations.
FlowWing Labs LLC will process the user's Personal Data in compliance with the provisions of the Privacy Law by virtue of the following legal bases: where Personal Data is necessary for the execution of the general conditions of the Services; if the Personal Data is subject to profiling, based on express written consent; if the user has given consent for one or more specific purposes; where Personal Data is necessary for the execution of a task of public interest; where processing is necessary for the pursuit of legitimate interests; and for fulfilling legal obligations.
5.1 Fulfillment of Contractual Obligations (Art. 6(1) (b) GDPR)
5.1 Fulfillment of Contractual Obligations (Art. 6(1) (b) GDPR)
The processing of Personal Data may be necessary for the execution of the contractual conditions stipulated with the user or for the execution of pre-contractual measures. This includes: general provision of Services; account management; execution of user orders (e.g. payment processing, chargebacks); requests for assistance and support; implementation of data security on the Site; and procedure for hiring new employees.
The processing of Personal Data may be necessary for the execution of the contractual conditions stipulated with the user or for the execution of pre-contractual measures. This includes: general provision of Services; account management; execution of user orders (e.g. payment processing, chargebacks); requests for assistance and support; implementation of data security on the Site; and procedure for hiring new employees.
5.2 Fulfillment of Legal Obligations (Art. 6(1) (c) GDPR)
5.2 Fulfillment of Legal Obligations (Art. 6(1) (c) GDPR)
The processing of Personal Data may also be necessary for the fulfillment of various legal obligations. This includes: contract management, accounting and invoicing; compliance and risk management; monitoring for the prevention of fraud, money laundering and terrorist financing; providing information to tax or law enforcement authorities; and consultation of credit agencies.
The processing of Personal Data may also be necessary for the fulfillment of various legal obligations. This includes: contract management, accounting and invoicing; compliance and risk management; monitoring for the prevention of fraud, money laundering and terrorist financing; providing information to tax or law enforcement authorities; and consultation of credit agencies.
5.3 Protecting Legitimate Interests (Art. 6(1) (f) GDPR)
5.3 Protecting Legitimate Interests (Art. 6(1) (f) GDPR)
Where necessary, processing may also take place to protect the legitimate interests of FlowWing Labs LLC or third parties. This includes: prevention of fraud and money laundering; risk management; identification of irregular or suspicious activity; data transmission within the corporate group; management of user requests; measures to protect network and information security; processing of requests from authorities in judicial proceedings; market research and development of services; and direct marketing and advertising.
Where necessary, processing may also take place to protect the legitimate interests of FlowWing Labs LLC or third parties. This includes: prevention of fraud and money laundering; risk management; identification of irregular or suspicious activity; data transmission within the corporate group; management of user requests; measures to protect network and information security; processing of requests from authorities in judicial proceedings; market research and development of services; and direct marketing and advertising.
5.4 Consent (Art. 6(1)(a) GDPR)
5.4 Consent (Art. 6(1)(a) GDPR)
The processing of Personal Data will only take place in accordance with the defined purposes and to the extent agreed upon at the time of granting consent. The user can revoke consent at any time without giving reasons and with future effect. On the basis of consent, FlowWing Labs LLC may process Personal Data for: direct marketing and advertising (e.g. newsletters, prize competitions); transfer of Personal Data to third parties; analysis and tracking of the Site; and use of audio, video and photographic data for marketing purposes.
The processing of Personal Data will only take place in accordance with the defined purposes and to the extent agreed upon at the time of granting consent. The user can revoke consent at any time without giving reasons and with future effect. On the basis of consent, FlowWing Labs LLC may process Personal Data for: direct marketing and advertising (e.g. newsletters, prize competitions); transfer of Personal Data to third parties; analysis and tracking of the Site; and use of audio, video and photographic data for marketing purposes.
6. Consequences of Failure to Provide Personal Data
6. Consequences of Failure to Provide Personal Data
Failure to provide the Personal Data in the manner specified in this policy will prevent FlowWing Labs LLC from proceeding with user identification and registration on the Platform, making it impossible to provide the Services. Revocation of consents may affect the proper functioning and availability of certain Services.
Failure to provide the Personal Data in the manner specified in this policy will prevent FlowWing Labs LLC from proceeding with user identification and registration on the Platform, making it impossible to provide the Services. Revocation of consents may affect the proper functioning and availability of certain Services.
7. Data Retention
7. Data Retention
Personal Data will be retained for no longer than 10 years from the date on which the general conditions between the user and FlowWing Labs LLC cease to be effective, and thereafter for the period in which FlowWing Labs LLC is subject to retention obligations for tax or other legal purposes. After the retention period expires, Personal Data will be deleted and rights of access, deletion, rectification and portability can no longer be exercised.
Personal Data will be retained for no longer than 10 years from the date on which the general conditions between the user and FlowWing Labs LLC cease to be effective, and thereafter for the period in which FlowWing Labs LLC is subject to retention obligations for tax or other legal purposes. After the retention period expires, Personal Data will be deleted and rights of access, deletion, rectification and portability can no longer be exercised.
8. Communication of Data to Third Parties
8. Communication of Data to Third Parties
FlowWing Labs LLC transmits Personal Data only as described below or if required by law at the time of collection.
FlowWing Labs LLC transmits Personal Data only as described below or if required by law at the time of collection.
8.1 Data Transfer Within the Company or to Third-Party Processors
8.1 Data Transfer Within the Company or to Third-Party Processors
Personal Data may be communicated to: consultants, accountants or lawyers providing services connected to the execution of the Services; banking and insurance institutions providing services connected to the Services; judicial or administrative authorities to fulfill legal obligations; and data processors performing services on behalf of FlowWing Labs LLC (e.g. IT services, customer support, newsletter distribution).
Personal Data may be communicated to: consultants, accountants or lawyers providing services connected to the execution of the Services; banking and insurance institutions providing services connected to the Services; judicial or administrative authorities to fulfill legal obligations; and data processors performing services on behalf of FlowWing Labs LLC (e.g. IT services, customer support, newsletter distribution).
8.2 Transfers to Other Third Parties
8.2 Transfers to Other Third Parties
FlowWing Labs LLC may transfer Personal Data to joint controllers or other third parties only with the user's prior consent or to fulfill a contract or pre-contractual measures at the user's request.
FlowWing Labs LLC may transfer Personal Data to joint controllers or other third parties only with the user's prior consent or to fulfill a contract or pre-contractual measures at the user's request.
8.3 International Transfers
8.3 International Transfers
Personal Data may be processed and stored on servers located outside the EU, in compliance with Chapter V of the GDPR or other applicable law, using adequacy decisions, Standard Contractual Clauses or user consent as legal mechanisms.
Personal Data may be processed and stored on servers located outside the EU, in compliance with Chapter V of the GDPR or other applicable law, using adequacy decisions, Standard Contractual Clauses or user consent as legal mechanisms.
9. Methods of Processing of Personal Data
9. Methods of Processing of Personal Data
FlowWing Labs LLC adopts appropriate technical and organizational measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational and technological methods strictly related to the purposes indicated.
FlowWing Labs LLC adopts appropriate technical and organizational measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational and technological methods strictly related to the purposes indicated.
10. Profiling of Personal Data
10. Profiling of Personal Data
Personal Data may be subject to automated decision-making, including profiling, only with prior express consent, which may be revoked at any time. Upon consent, FlowWing Labs LLC may profile users to improve Services and identify homogeneous user groups.
Personal Data may be subject to automated decision-making, including profiling, only with prior express consent, which may be revoked at any time. Upon consent, FlowWing Labs LLC may profile users to improve Services and identify homogeneous user groups.
11. Rights of the Data Subject
11. Rights of the Data Subject
Under the GDPR, users have the right to: access their Personal Data; rectify inaccurate or incomplete Personal Data; delete Personal Data (right to be forgotten) under certain conditions; restrict processing of Personal Data; receive Personal Data in a structured, machine-readable format (data portability); object to processing based on legitimate interests; withdraw consent at any time; and lodge a complaint with a supervisory authority.
Under the GDPR, users have the right to: access their Personal Data; rectify inaccurate or incomplete Personal Data; delete Personal Data (right to be forgotten) under certain conditions; restrict processing of Personal Data; receive Personal Data in a structured, machine-readable format (data portability); object to processing based on legitimate interests; withdraw consent at any time; and lodge a complaint with a supervisory authority.
12. Expression and Revocation of Consent
12. Expression and Revocation of Consent
By subscribing to newsletters or other communications, the user expressly consents to receive email messages as described in this policy. The user may revoke consent at any time by contacting FlowWing Labs LLC at: 5830 E 2nd St., Ste 7000 #26210 Casper, Wyoming 82609, USA or via email at contact@flowwing.io. Please note that revocation may affect our ability to provide certain Services.
By subscribing to newsletters or other communications, the user expressly consents to receive email messages as described in this policy. The user may revoke consent at any time by contacting FlowWing Labs LLC at: 5830 E 2nd St., Ste 7000 #26210 Casper, Wyoming 82609, USA or via email at contact@flowwing.io. Please note that revocation may affect our ability to provide certain Services.
13. Method of Exercising Rights
13. Method of Exercising Rights
To exercise any of the rights above, users can send a request at no cost to FlowWing Labs LLC at the contact details above. Requests will be processed without undue delay, and in any event within one month.
To exercise any of the rights above, users can send a request at no cost to FlowWing Labs LLC at the contact details above. Requests will be processed without undue delay, and in any event within one month.
14. Data Controllers
14. Data Controllers
The updated list of data controllers and their contact details is available upon request from FlowWing Labs LLC at the address or email above.
The updated list of data controllers and their contact details is available upon request from FlowWing Labs LLC at the address or email above.
15. Cookie Policy
15. Cookie Policy
FlowWing Labs LLC does not use cookies or any similar tracking technologies on this website. We do not store or access any information on your device for tracking or analytics purposes. Should this change in the future, we will update this policy and obtain your consent where required under applicable laws.
FlowWing Labs LLC does not use cookies or any similar tracking technologies on this website. We do not store or access any information on your device for tracking or analytics purposes. Should this change in the future, we will update this policy and obtain your consent where required under applicable laws.
16. Changes to This Policy
16. Changes to This Policy
FlowWing Labs LLC reserves the right to amend this policy at any time. Changes will be notified via the Site or by email where legally required. Please review this page regularly for updates.
FlowWing Labs LLC reserves the right to amend this policy at any time. Changes will be notified via the Site or by email where legally required. Please review this page regularly for updates.