PRIVACY POLICY — FLASHFLOW
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We value your trust. In order to honour that trust, Flashflow adheres to ethical
standards in gathering, using, and safeguarding any information you provide.
Flashflow Technologies OPC Private Limited (operating under the brand name
Flashflow), is a company incorporated in India. Flashflow provides (a) learning
and educational services through the ‘Flashflow – App’ and related services, and
(b) licensed software products, including StarFlow, an astrophotography image-
processing application. This privacy policy governs your use of the application
‘Flashflow – App’ (‘Application’), www.flashflowtech.com (‘Website’), StarFlow,
and the other associated applications, products, websites and services managed
by the Company.
Please read this privacy policy (‘Policy’) carefully before using the
Application, Website, StarFlow, our services and products, along with the Terms
of Use (‘ToU’) provided on the Application and the Website. Your use of the
Website, Application, StarFlow, or services in connection with the Application,
Website or products (‘Services’), or registrations with us through any modes or
usage of any products, shall signify your acceptance of this Policy and your
agreement to be legally bound by the same. If you do not agree with the terms of
this Policy, do not use the Website, Application, StarFlow, our products or avail
any of our Services.
Because Flashflow operates both a learning service and standalone software
products, different parts of this Policy apply depending on which product you
use. Sections 1–13 describe our learning Application, Website and related
Services. Section 14 describes StarFlow specifically, which works very
differently and collects far less information. Where a section could apply to
both, we say so.
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PART A — FLASHFLOW LEARNING APPLICATION, WEBSITE AND SERVICES
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User Provided Information
The Application/Website/Services/products obtains the information you provide
when you download and register for the Application or Services or products. When
you register with us, you generally provide (a) your name, age, email address,
location, phone number, password and your ward’s educational interests; (b)
transaction-related information, such as when you make purchases, respond to any
offers, or download or use applications from us; (c) information you provide us
when you contact us for help; (d) information you enter into our system when
using the Application/Services/products, such as while asking doubts,
participating in discussions and taking tests. The said information collected
from the users could be categorized as “Personal Information”, “Sensitive
Personal Information” and “Associated Information”. Personal Information,
Sensitive Personal Information and Associated Information (each as individually
defined under the Information Technology (Reasonable security practices and
procedures and sensitive personal data or information) Rules, 2011 (the “Data
Protection Rules”)) shall collectively be referred to as ‘Information’ in this
Policy. We may use the Information to contact you from time to time, to provide
you with the Services, important information, required notices and marketing
promotions. We will ask you when we need more information that personally
identifies you (personal information) or allows us to contact you. We will not
differentiate between who is using the device to access the Application, Website
or Services or products, so long as the log in/access credentials match with
yours. In order to make the best use of the Application/Website/Services/products
and enable your Information to be captured accurately, it is essential that you
have logged in using your own credentials. We will, at all times, provide the
option to you to not provide the Personal Information or Sensitive Personal
Information, which we seek from you. Further, you shall, at any time while using
the Application/Services/products, also have an option to withdraw your consent
given earlier to us to use such Personal Information or Sensitive Personal
Information. Such withdrawal of the consent is required to be sent in writing to
us at the contact details provided in this Policy below. In such event, however,
the Company fully reserves the right not to allow further usage of the
Application or provide any Services/products thereunder to you.
Automatically Collected Information
In addition, the Application/products/Services may collect certain information
automatically, including, but not limited to, the type of mobile device you use,
your mobile device’s unique device ID, the IP address of your mobile device,
your mobile operating system, the type of mobile Internet browsers you use, and
information about the way you use the Application/Services/products. As is true
of most mobile applications, we also collect other relevant information as per
the permissions that you provide. We use an outside payment processing company
to bill you for goods and services. These companies do not retain, share, store
or use personally identifiable information for any other purpose.
At the time you (on behalf of yourself and/or your ward) register with us for our
learning Services, or during the term of Services relating to our
products/services/subscriptions, we may require camera and microphone access
while you avail such products/services/subscriptions to improve the in-classroom
experience. All video, audio and telecalls between you/your ward and our
tutors/representatives/agents are recorded for quality and training purposes.
These recordings shall not be shared with you/your ward for any reasons
whatsoever. By agreeing to this Privacy Policy, you (on behalf of yourself and/or
your ward) consent to our collection/recording and use of your and/or your
ward’s audio/video/telecall recordings and personal information for the above-
mentioned purposes. (This paragraph applies to the learning Services only. It
does NOT apply to StarFlow — see Part B.)
Use of your Personal Information
We use the collected Information to analyse trends, to conduct research, to
administer the Application/Services and products, to learn about each user’s
learning patterns and movements around the Application/Services and products and
to gather demographic information and usage behaviour about our user base as a
whole. Aggregated and individual, anonymized and non-anonymized data may
periodically be transmitted to external service providers to help us improve the
Application, products and our Services. We will share your information with third
parties only in the ways that are described below in this Policy. We may use the
individual data and behaviour patterns combined with personal information to
provide you with personalized content, and better your learning objectives.
Third parties provide certain services which we may use to analyze the data and
information to personalize, drive insights and help us better your experience or
reach out to you with more value added applications, products, information and
services. However, these third party companies do not have any independent right
to share this information. We do not sell, trade or share your Information to any
third party (except subsidiaries/affiliates of the Company for related
offerings) unless we have been expressly authorized by you either in writing or
electronically to do so. We may at times provide aggregate statistics about our
customers, traffic patterns, and related site information to reputable third
parties; however, this information when disclosed will be in an aggregate form
and does not contain any of your Personally Identifiable Information. Flashflow
will occasionally send email notices, messages or contact you to communicate
about our Services, products and benefits, as they are considered an essential
part of the Services/products you have chosen. We may disclose Information:
– as required by law, such as to comply with a subpoena, or similar legal
process;
– to enforce applicable ToU, including investigation of potential violations
thereof;
– when we believe in good faith that disclosure is necessary to protect our
rights, protect your safety or the safety of others, investigate fraud,
address security or technical issues or respond to a government request;
– with our trusted services providers who work on our behalf, do not have an
independent use of the information we disclose to them, and have agreed to
adhere to the rules set forth in this Policy;
– to protect against imminent harm to the rights, property or safety of the
Application/Website/Flashflow Technologies OPC Private Limited or its users
or the public as required or permitted by law;
– with third party service providers in order to personalize the
Application/Website/Services/products for a better user experience and to
perform behavioural analysis;
– Any portion of the Information containing personal data relating to minors
provided by you shall be deemed to be given with the consent of the
minor’s legal guardian. Such consent is deemed to be provided by your
registration with us.
Access to your Personal Information
We will provide you with the means to ensure that your Personal Information is
correct and current. If you have filled out a user profile, we will provide an
obvious way for you to access and change your profile from our
Application/Services/Website/products. We adopt reasonable security measures to
protect your password from being exposed or disclosed to anyone.
Cookies
We send cookies (small files containing a string of characters) to your
computer, thereby uniquely identifying your browser. Cookies are used to track
your preferences, help you login faster, and aggregated to determine user
trends. This data is used to improve our offerings, such as providing more
content in areas of greater interest to a majority of users. Most browsers are
initially set up to accept cookies, but you can reset your browser to refuse all
cookies or to indicate when a cookie is being sent. Some of our features and
services may not function properly if your cookies are disabled.
Links
We may present links in a format that enables us to keep track of whether these
links have been followed. We use this information to improve our customized
content. Clicking on links may take you to sites outside our domain. We are not
responsible for the privacy practices of other web sites. We encourage our users
to be aware when they leave our site to read the privacy statements of each and
every web site that collects personally identifiable information. This Privacy
Policy applies solely to information collected by our Website, Application and
products.
Alerts
We may alert you by email or phone (through sms/call/whatsapp) to inform you
about new service offerings of the Company and its subsidiaries/affiliates or
other information which we feel might be useful for you.
Public Forums
When you use certain features on our website like the discussion forums and you
post or share your personal information such as comments, messages, files,
photos, they will be available to all users, and will be in the public domain.
All such sharing of information is done at your own risk. Please keep in mind
that if you disclose personal information in your profile or when posting on our
forums this information may become publicly available.
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PART B — STARFLOW (ASTROPHOTOGRAPHY SOFTWARE)
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14. StarFlow
StarFlow is downloadable desktop software for processing astrophotography
images. It works very differently from our learning Application, and collects
far less information. This section governs StarFlow; the data practices in Part A
above (such as call recording, learning behaviour, or children’s educational
data) do NOT apply to StarFlow.
14.1 Your images never leave your computer.
StarFlow processes all image files locally on your own computer. We do not
upload, receive, store, or have any access to your images or their contents, the
astronomical targets you image, or your file names or folder structure.
14.2 No analytics or telemetry.
StarFlow does not track how you use it and does not send usage data to us.
14.3 The only data sent is for licensing.
When you activate StarFlow, or when it periodically re-validates your licence,
the software sends to our licensing server:
– your Licence Key;
– a device identifier (“machine_id”) — a value produced by hashing basic,
non-sensitive machine characteristics (such as computer name, machine
type, operating system, and network-adapter identifier) with a one-way
SHA-256 hash. The software transmits only the hashed result, never the raw
underlying values, and uses it solely to enforce the number of devices
your licence permits;
– the IP address and request time inherent to any internet request.
The server checks your licence status, expiry and available device “seats”, and
returns a short-lived, digitally-signed activation token, which the software
verifies and caches locally so it can work offline between periodic
re-validations. If you deactivate a device to free a licence seat, the software
sends your Licence Key and device identifier so the server can release that seat.
14.4 Update checks.
StarFlow may check for new versions by contacting a public software-release
service to compare version numbers. Such a request carries only the network
information inherent to any web request; it does not send your Licence Key,
device identifier, or any images.
14.5 Purchase data.
When you buy a StarFlow licence, your payment is processed by Razorpay (Razorpay
Software Private Limited), our payment gateway, under its own privacy policy
(https://razorpay.com/privacy/). We receive from Razorpay only the information
necessary to issue and support your licence (such as your name, email and order
reference). We do not receive or store your full card number, CVV or other
sensitive payment-instrument details.
14.6 Hosting and international transfers for StarFlow licensing.
Our StarFlow licensing server and database are operated on our behalf by
Cloudflare, Inc., which runs a global network. As a result, your StarFlow
activation data (Licence Key, hashed device identifier, and the IP address
inherent to the request) may be processed on servers located outside your
country, including outside India. Where such transfers occur, we rely on
appropriate legal safeguards as required by applicable law, and Cloudflare
processes this data on our instructions
(https://www.cloudflare.com/privacypolicy/).
14.7 What StarFlow does NOT collect.
We do not collect or receive, in connection with StarFlow, your image files or
their contents, usage/analytics data, or any audio/video recordings.
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PART C — PROVISIONS APPLYING TO ALL FLASHFLOW PRODUCTS
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Security
We are concerned about safeguarding the confidentiality of your Information. We
provide physical, electronic, and procedural safeguards to protect Information we
process and maintain. For example, we limit access to this Information to
authorized employees only who need to know that information in order to operate,
develop or improve our Application/Services/products/Website. For StarFlow
licensing specifically, activation tokens are protected by strong digital
signatures (Ed25519) and the device identifier is one-way hashed. Please be aware
that, although we endeavour to provide reasonable security for information we
process and maintain, no security system can prevent all potential security
breaches.
How Long Do We Retain User Data?
For our learning Services, we plan to retain user data while an account is active
and for at least three years afterward. For StarFlow, we retain licence and
activation records (Licence Key, hashed device identifier, activation
timestamps) for as long as your licence is active and for a limited period
afterwards for support, fraud-prevention and legal/accounting purposes, after
which they are deleted or anonymised; server request logs containing IP addresses
are retained only for a short period for security and troubleshooting. We may
alter these practices according to legal and business requirements.
Log information
When you access our Website, our servers automatically record information that
your browser sends whenever you visit a website. These server logs may include
information such as your web request, internet protocol address, browser type,
browser language, the date and time of your request and one or more cookies that
may uniquely identify your browser.
User communications
When you send an email or other communication to us, we may retain those
communications in order to process your inquiries, respond to your requests and
improve our Services.
Your Rights
Subject to applicable law, including the Digital Personal Data Protection Act,
2023 (DPDP Act), you have the right to access the personal data we hold about
you, request correction of inaccurate data, request erasure of your data, and
withdraw consent where processing is based on consent. If you are in India, you
may also have the right to grievance redressal under the DPDP Act and to nominate
another person to exercise your rights in the event of death or incapacity. To
exercise any of these rights, contact us at the details below.
Changes to this Statement
As the Company evolves, our privacy policy will need to evolve as well to cover
new situations. You are advised to review this Policy regularly for any changes,
as continued use is deemed approval of all changes.
Your Consent
By registering with us or using our products (including StarFlow), you are
expressly consenting to our collection, processing, storing, disclosing and
handling of your information as set forth in this Policy now and as amended by
us. Processing your information in any way — including collecting, storing,
deleting, using, combining, sharing, transferring and disclosing information —
will take place in India, save for the StarFlow licensing infrastructure
described in section 14.6. If you reside outside India, your information will be
transferred, processed and stored in accordance with the applicable data
protection laws of India.
Contact Information
Our Grievance Officer shall undertake all reasonable efforts to address your
grievances at the earliest possible opportunity. You may contact us at:
Flashflow Technologies OPC Private Limited, 15-6-260, Manikya, Arya Samaj Road,
Mangalore – 575003. Reach out to us on info.flashflowtech@gmail.com in case of
any queries.