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Privacy Policy

Last updated 07/11/2025

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" ). As regards the meaning of the terms used in this information with the initial capital letter and which are not defined within the same, please refer to the definitions of the GDPR. 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

FlowWing Labs LLC offers, through its website https://flowwing.io/ (the “Site”) the following services (collectively, the “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 (e.g. business partners, interested parties, service providers, APIs, etc.). 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

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

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

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

During Service use, we may collect:

  • Bank details (IBAN, BIC).
  • Payment service provider information.
  • Payment data and transaction IDs.

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.

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.

3.6 Support Requests

If you contact our support team, we process any Personal Data you provide to assist with your inquiry.

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.

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.

3.9 Special Categories of Data

We generally do not process “special categories” of Personal Data (sensitive data under Article 9 GDPR).

3.10 Biometric Data

With your explicit consent, we may collect biometric data (e.g. facial images, fingerprints) solely to perform due diligence checks.

3.11 Data Controller

Biometric and other Personal Data is processed under the responsibility of our Data Controller, Shehroz Khan.

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, including the activation of products and services offered by such operators;
  • periodically notify the user about the tariffs; respond to requests for assistance or information from the user; fulfillment of legislative or regulatory obligations (e.g. of a fiscal nature);
  • sending of commercial communications and newsletters, as described below, exclusively with the express consent of the user; and
  • profiling and statistics, as described below, exclusively with the express consent of the user. Any use of cookies - or other tracking tools - by FlowWing Labs LLC, unless otherwise specified, has the purpose of providing the Services used from time to time by the user, in addition to the additional purposes described in this information and in the cookie policy of FlowWing Labs LLC. If FlowWing Labs LLC should ask the user to provide further Personal Data not included among those indicated above, the Company will communicate to the user, at the same time as the request, which data it needs, what the purpose of the processing is and the legal bases relation to this request.

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:

  • As the Personal Data is necessary for the execution of the general conditions of the Services stipulated between the user and FlowWing Labs LLC; and/or
  • If the Personal Data is subject to profiling, based on the express written consent of the user; and/or if the Personal Data is processed for direct marketing purposes as described below, based on the user's express written consent; and/or
  • If the user has given their consent for one or more specific purposes; and/or
  • As the Personal Data is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller; and/or
  • The processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties; and/or
  • For the purposes of fulfilling legal obligations to which the Data Controller is subject. In any case, it is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing (i) takes place on the basis of the provisions of the Privacy Law and/or other applicable laws and regulations, (ii) is required by a contract or necessary to conclude a contract. Below is detailed information in relation to the legal bases underlying the processing of Personal Data in the context of use of the Platform and/or in case of communication with FlowWing Labs LLC:

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 adopted at the user's request. The following Personal Data processing operations fall within the scope of the fulfillment of contractual obligations:

  • General provision of the Services, all actions necessary for the operation, execution and administration of FlowWing Labs LLC.
  • Account management (e.g. continuous updating of user data).
  • Execution of user orders (e.g. payment processing, chargebacks, proof of purchase and sale).
  • Requests for assistance and support from the user.
  • Implementation of data security and IT security on the Site and safeguarding the Company’s network (for example, to prevent identity theft and irregular or suspicious access to the Company’s websites).
  • Procedure for hiring new employees.

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. The following Personal Data processing operations fall within the scope of legal obligations:

  • Contract management, accounting and invoicing.
  • Compliance and risk management.
  • Monitoring for the prevention of fraud, abuse (e.g. for illegal purposes), money laundering and terrorist financing.
  • Providing information to tax or law enforcement authorities in the context of legal proceedings.
  • Consultation of credit agencies to determine solvency and insolvency risks.

5.3 Protecting Legitimate Interests (Art. 6(1)(f) GDPR)

Where necessary, the processing of Personal Data may also take place after the validity of the general contract conditions stipulated with the user, in order to protect the legitimate interests of FlowWing Labs LLC or third parties. The following operations are carried out on the basis of a legitimate interest:

  • The prevention of fraud, abuse, money laundering and terrorist financing.
  • Risk management and risk minimization (for example, through inquiries to credit bureaus, debtor lists or business analytics providers).
  • Identification and examination of cases of potentially irregular or suspicious activity and access to the Site (e.g. website analysis via third‑party services).
  • Data transmission within FlowWing Labs LLC or companies within its corporate group for internal administrative purposes.
  • Management of user requests and general inquiries.
  • Measures to protect our users, partners and employees and to safeguard network and information security.
  • Processing of requests from authorities, lawyers or collection agencies in the course of judicial proceedings.
  • Market research, business management and continuous development of services and products.
  • Processing of statistical data, performance data and market research data through the Site or social platforms.
  • Processing user preferences (e.g. language, region) via cookies on our Site.
  • Direct marketing and advertising (e.g. execution of marketing strategies, user targeting, sending of coupons, advertising by FlowWing Labs LLC and its partners).
  • Use of audio, video and photographic data from public spaces for marketing and representation purposes.

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 by the user. The user can revoke consent at any time without giving reasons and with future effect if they no longer agree with the processing carried out by FlowWing Labs LLC. On the basis of the user’s consent, FlowWing Labs LLC will process Personal Data for the following purposes:

  • Direct marketing and advertising (for example, user satisfaction surveys, newsletters, prize competitions and other promotional communications).
  • Transfer of Personal Data to third parties.
  • Analysis and tracking of the Site (for further information please read the Privacy Policy).
  • Use of certain audio, video and photographic data (for example, advertising, interviews) for marketing and representation purposes through various channels.

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.

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.

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.

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.
  • 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

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

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

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

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

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.
  • Lodge a complaint with a supervisory authority.

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: FlowWing Labs LLC 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

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

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

FlowWing Labs LLC uses tracking tools (cookies). For more information, please read our Privacy 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.

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