Flowguard Privacy Policy

Version 1.0, published on October 31, 2026.

This translation is provided for information only. In case of any divergence, the Portuguese version prevails (clause 21.6 of the Terms of Contracting and Use).

1. Who processes the data

The controller of the personal data processed on the flowguard.com.br website and on the Flowguard Platform is FLOWSPEC SOLUTIONS LTDA, enrolled in the CNPJ under no. 53.730.044/0001-33, headquartered at Alameda Rio Negro, 503, conj. 2301, Alphaville, Barueri/SP, CEP 06454-000.

The data protection officer (encarregado) can be reached by e-mail at soc@flowspec.net.br.

This Policy does not apply to the traffic data of customers' networks. For such data, the customer is the controller and FLOWSPEC is the processor, in accordance with Annex I of the Terms of Contracting and Use.

2. Data collected

Website visitors:

• IP address;
• date and time of access;
• pages accessed;
• browser identification;
• language and theme preferences.

Platform users:

• name, e-mail and telephone number;
• records of access and of the actions performed (audit).

Customer companies:

• corporate name, CNPJ and ASN;
• contact data.

3. Purposes

The data are used to:

• provide the service and comply with the Terms of Contracting and Use;
• ensure the security of the website and the Platform and prevent fraud and abuse;
• send communications about the account, the subscription and the service;
• carry out business-to-business commercial prospecting: identify, through the ASN of the IP address, the organizations whose networks visited the website and contact them through the institutional channels published in the public internet number registries.

4. Legal bases

The legal bases of the General Data Protection Law (LGPD, Lei 13.709/2018) used are:

• performance of a contract, for the provision of the service;
• compliance with a legal obligation, for the retention of access records;
• the legitimate interest of FLOWSPEC, for security and for business-to-business commercial prospecting.

The data subject may object to processing based on legitimate interest by e-mail to the data protection officer.

5. Cookies and browser storage

The website and the Platform use only:

• session and security cookies, essential for login. They last while the session is active, or up to 30 days when the user checks "Remember on this computer";
• browser local storage, to store language and theme preferences.

The checkout of the payment platform (Eduzz) uses its own cookies and anti-bot mechanisms, governed by its own policy.

6. Sharing

The data are shared only:

• with the payment platform, to process the purchase;
• with the messaging services that the user enables to receive alerts;
• with authorities, when there is a legal obligation or a court order.

FLOWSPEC does not sell personal data.

7. Retention

The retention periods are:

• website access records, per visit: 90 (ninety) days;
• aggregated website access data: 180 (one hundred and eighty) days;
• Platform access records: at least 6 (six) months, in accordance with art. 15 of the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet);
• registration data: for as long as the business relationship lasts, and thereafter for the legal periods.

8. Data subject rights

The data subject may request by e-mail at soc@flowspec.net.br:

• confirmation of the existence of processing and access to their data;
• correction of incomplete or outdated data;
• anonymization, blocking or deletion of unnecessary data or data processed in breach of the law;
• data portability;
• information about the sharing of the data;
• review of automated decisions.

9. Security

FLOWSPEC adopts the following security measures:

• encrypted communication (TLS);
• passwords stored only in hashed form;
• access restricted by user profile;
• audit logging of actions.

10. Changes

This Policy is versioned and published on the website, with the date of the last update. Relevant changes are communicated to users by e-mail.