Privacy Policy

Privacy Policy on the Protection of Personal Data 

As a seller and repairer of computer hardware, GM ASSOCIATION SRL, a company registered with the CBE under No. BE0715399546, processes a certain amount of data, some of which is personal data (information that allows us to identify you). 

We take the protection of your personal data very seriously and want you to feel safe and confident when visiting our website. We therefore ensure that the personal data we collect is processed in accordance with the relevant legal requirements. 

 Your data is processed in accordance with the Law of December 8, 1992, on the protection of privacy with regard to the processing of personal data, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (hereinafter referred to as the “General Data Protection Regulation, effective as of May 25, 2018”). 

 The purpose of this Privacy Policy is to inform you about the commitments and practical measures taken by FlowUP to ensure the protection of your personal data. It may be updated in response to changes in the legal and regulatory environment.

When a new version is made available to users on our website, that new version will automatically and immediately take effect. FlowUP advises users to review this privacy policy regularly to stay informed of any changes. 

 By using our website, you accept this Privacy Policy and expressly consent to the data controller at FlowUP collecting and processing, in accordance with the terms and principles described in this Privacy Policy, the personal data you have provided via the website and/or in connection with the services offered on the website, for the purposes indicated below in section 3.

The user has the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent given prior to withdrawal. 

​1. Data Privacy Guarantees 

Your personal data is intended for internal use only. It will never be sold, shared, or disclosed to third parties without your prior consent. 

Your personal data may be disclosed to a third party if we are required to do so under applicable law or regulation, a court order, or a government regulation, or if such disclosure is necessary in connection with an investigation or criminal proceeding, whether within the country or abroad. 

 Our employees and contractors are required to maintain the confidentiality of the data they process. 

​1. Data Collected 

FlowUP ensures that the personal data collected is adequate, relevant, and not excessive in relation to the purpose for which it is processed. 

 The following categories of data are subject to processing:

– Last name, first name, address, gender, date of birth 

– Company name – Business registration number (+VAT number) 

– National ID number 

– Email address 

– Phone number 

 – Password 

– Billing address (Country, Street address and number, City, ZIP code) 

– Shipping address (Country, Street address and number, City, ZIP code) 

– Biometric data (copy of electronic ID card or passport), 

– Connection information (IP address, location, etc.) 

 This data is collected when you fill out our contact form and/or online order form on our website, or when you contact us via email or chat. Other personal data may be collected at a later date, for example, in connection with the fulfillment of your order. This data is necessary for the provision of our goods and services.

 The personal data recorded may contain transactional information regarding your purchases, such as items purchased, date of purchase, any returns, payment status, and payment details.

 We may also record responses or comments regarding purchased products that we receive from you as part of satisfaction surveys or market research, or any complaints you submit to us.

 In the context of processing financing requests submitted to us, the following data is also processed: number of dependent children, salary amounts, loan amounts, and other expenses, …

 In this context, FlowUP processes personal data that the data subject or their relatives have provided themselves.

 In addition, we may use cookies to recognize users and provide them with a personalized experience, to remember their technical preferences (such as language), and to detect and correct any errors on our website. A cookie does not allow us to identify you. However, it records information about your computer’s browsing activity on our site (the pages you have visited, the date and time of your visit, etc.) that we can read during your subsequent visits. Please note that you can opt out of cookies by changing your web browser settings.

FlowUP does not collect personal data concerning children under the age of 18 and encourages parents or legal guardians to accompany their children online to participate in their online activities and supervise them. 

Under no circumstances do we collect or process sensitive data. 

​1. Use of Personal Data 

Visiting our website does not require any form of registration or sign-up, allowing you to visit it without having to identify yourself. 

 In order to respond to certain requests you may have, we may ask you to provide us with some of your personal data.

 This information allows us to provide you with products or services, send you a quote, bill you for the products and services you’ve requested, deliver them to you, and offer you products and services that may interest you, or simply to communicate with you for other obvious purposes.

 With your consent

 – To send you newsletters or other promotional emails to which you have subscribed;

 In accordance with the law, we may send you promotional emails about our products and services based on your implied consent if you have provided us with your email address in connection with a purchase. You may opt out of this at any time at no cost (you can unsubscribe simply by clicking the link at the bottom of each email);

– To track and process your participation in one of our promotional campaigns or contests; 

– To process your request when you ask us questions via our website or through our customer service department; 

– To compile statistics; 

– To improve the quality of the website and the products and/or services offered; 

– To provide information about new products and/or services; 

– For direct marketing purposes; 

– To better identify the user’s interests; 

 – To respond to your job application submitted through our “Jobs” section. 

You may withdraw your consent at any time. 

 In connection with the performance of your contract

– To process and fulfill your order, as well as for billing purposes; 

– To track and process complaints and returns; 

– For general customer management, including accounting, dispute resolution and legal proceedings, debt collection or transfer, and the protection of our rights in general. 

The processing of this personal data is a legal requirement. Without this data, we cannot enter into a business relationship with our customers (Article 33 of the Law of September 18, 2017). 

Personal data is not transferred to third countries or international organizations. 

You are free to withhold this information, but in that case, we will obviously be unable to respond to certain requests you may have. 

​1. Cookie Policy:  
2. a) What is a cookie?

 A cookie is a small file consisting of text and numbers that we store on your browser or your computer’s hard drive. This allows us to remember your preferences when you use our website.

To do this, we use functional cookies that make the website easier to use during your visits. We also use non-functional cookies to collect statistics about our visitors and thereby improve our website for the future. 

Our system will place cookies as soon as you visit our website, unless you have changed your browser settings to refuse cookies. 

1. b) Information About Our Use of Cookies 

 Our website uses cookies and other similar technologies to distinguish your usage preferences from those of other users of our website. This helps us provide you with a better user experience when you visit our website and allows us to optimize it.

 However, cookies and similar technologies do not systematically collect information that can identify users of our website. They only help us improve the functioning of our website, understand our users’ interests and measure the effectiveness of our website content.

 Following recent changes in the law, all websites targeting certain parts of the European Union are required to ask for your permission to use and store cookies and other similar technologies on your computers and mobile devices. This Cookie Policy clearly and comprehensively informs you about the cookies we use and their purpose.

 Please read our Privacy Policy to understand the privacy rules that apply to the website. For more information about this Cookie Policy, you can always contact us.

 For more information about deleting and blocking cookies, you can visit the following website: http://www.aboutcookies.org/Default.aspx?page=2.

1. c) Google Analytics 

Another cookie used by this website and mobile application comes from Google Analytics. By using this cookie, we can know how many visitors we have on our website and mobile application, why they visit the website and mobile application, etc. This information allows us to improve the website and mobile application. This cookie does not record any personally identifiable information. Google provides further information about privacy and cookies at http://www.google.com/policies/privacy/ and explains how you can choose not to share information with Google Analytics at https://support.google.com/analytics/answer/6004245 or install a specific plug-in for this purpose at https://tools.google.com/dlpage/gaoptout/ .
https://tools.google.com/dlpage/gaoptout/
 The Google advertising features that may be used are intended for remarketing, displaying advertisements for goods and services in which you have shown interest, and for demographic and interest reports: https://support.google.com/analytics/answer/3450482?hl=en . You also have the option to manage how Google may use your interests to display relevant advertisements: https://www.google.com/settings/ads/preferences?hl=en .

 Some advertisements on our website and mobile application may be managed by an external party, which may also place cookies. These are used, among other things, to prevent you from repeatedly seeing the same campaign. In addition, these cookies are used for retargeting: this means that you may see an advertising campaign based on your previous visit to another website, for example.

Right of Access, Rectification and Objection

If you are registered as a user, using your login and password, you have the possibility to view your personal data yourself and, where applicable, modify it. You can click on “My Account”. You will then be able to update your personal data.

By means of a written, dated and signed request sent to the data controller at the address referred to in the “Contact Details” section of this Privacy Policy, the user may, after proving their identity by attaching a copy of their identity card, obtain free written communication or a copy of the personal data concerning them that has been collected.

The data controller may require the payment of reasonable fees based on administrative costs for any additional copy requested by the user.

 When the user submits this request electronically, the information is provided in a commonly used electronic form, unless the user requests otherwise.

 A copy of their data will be communicated to the user no later than one month after receipt of the request.

If, despite our efforts to ensure the accuracy and updating of data, incorrect information has been recorded, we will correct it at your request.

You may object to processing when you have this right. This is only the case when the processing is not necessary to comply with an obligation to which the data controller is subject by or under a law, decree or ordinance, and when you have serious and legitimate reasons to object concerning your particular situation, for example if your data has been processed unlawfully.

Right to Be Forgotten

 You have the right to request the deletion and removal of your personal data when there is no sufficient reason for its continued processing, or when the person has objected to the processing and there is no overriding legitimate reason justifying such processing.

 The persons responsible for the protection of personal data may refuse to delete the data for specific reasons, such as compliance with a legal obligation.

 Security and Confidentiality

To ensure the security and confidentiality of the personal data we collect online, we use networks protected by standard devices such as firewalls, passwords, secure access and encryption.

When processing your personal data, we take all reasonable measures to protect it against any loss, misuse, unauthorized access, disclosure, alteration or destruction, including encryption of stored data.

FlowUP COMPUTER has implemented security measures intended to prevent data loss, preserve data integrity and control access to data. These measures comply with personal data protection regulations.

The security measures we implement are subject to continuous improvement and take technological developments into account.

 Overview of Security Measures

Overview of the main technical security measures:

– Use of professional antivirus software that is systematically updated;

– Installation of a firewall on workstations and a general firewall on the network;

– Use of a password policy, meaning unique login codes and regularly updated personal passwords;

– Systematic secure backups to protect against data loss;

– Protection of physical access to personal data for persons who do not need access to it for their duties;

– No use of unsecured hard drives;

– Use of encryption techniques for the recording of personal data;

– Physical security of access to premises where personal data is processed and stored, using security codes.

 Overview of the main organizational measures:

– General policy informing staff about privacy protection;

– Organization of periodic training and awareness sessions for staff regarding the management of personal data;

– Establishment of confidentiality clauses with employees who manage personal data;

– Application of personal registration and identification systems for building access control so that unauthorized persons cannot access company premises;

– Appointment of an IT security officer;

– Use of paper shredders or other means to destroy any confidential data;

– Application of a specific procedure for deleting personal data stored on storage media and discarded equipment, such as laptops and smartphones, and on devices returned by employees leaving the company.

 In this way, our IT data is stored on a server hosted in a secure location, and our paper-format data is stored in archive rooms with restricted access for certain employees.

Only authorized FlowUP COMPUTER employees have access to your personal data. Each of them has been informed of the privacy protection policy implemented by FlowUP COMPUTER and has been required to comply with it.

1. Retention Period

Your personal data will not be kept for longer than necessary to achieve the purpose of the processing, unless retention of the data is required by law, decree or ordinance, for example accounting and tax obligations.
It will be deleted from our database as soon as it is no longer necessary for the pursued purpose, for the retention required by law, and if you have validly exercised your right to deletion.

1. Internet Tags
 We may collect and process information relating to your visit to our website, such as the pages viewed, the website visited immediately before this one, and searches carried out. This information allows us to improve the content of the website and compile statistics on individuals using our website for internal market research purposes.

The current document from the European Commission makes a clear distinction between “useful” cookies, which are non-intrusive with regard to privacy, and cookies related to advertising. The document explains that technical cookies, or audience measurement and analytics cookies, will be tolerated without the need for consent. This will not be the case for third-party cookies, which are clearly targeted by the new rules and whose operation must be subject to the explicit consent of the Internet user for each processing operation carried out.
Cookies are mentioned only once in the GDPR, as the regulation is intended to be as general as possible. Nevertheless, they are also mentioned in the proposed evolution of the ePrivacy Directive, which must be updated and should be applied together with the European regulation, within a period ranging from 6 months to 2 years after May 25, 2018.

 What we currently know:

 – Cookies essential to the functioning of the website will continue to be tolerated;

 – Some analytics cookies will be tolerated if they correspond to the activity of the website and do not harm the Internet user;

– Advertising cookies may be prohibited.

 Our website uses cookies to make browsing more useful and reliable. Some of these cookies are essential to the functioning of the website, while others help improve the user experience.

Most web browsers are configured to automatically accept cookies. If the user wishes to customize their management, they must change their browser settings. Further information on this subject can be found in the “Cookie Management” section of this provision.

By visiting and using our website, the user expressly agrees to the management of cookies.

​  1. Personal Information and Children

 The services available on our website are intended for persons aged 18 or over. We strictly comply with laws designed to protect children.

1. User Responsibility

Although FlowUP COMPUTER makes every possible effort to protect your privacy, effective protection is naturally only possible if you also take the necessary measures yourself to protect your privacy.

When using the services organized by FlowUP COMPUTER, you are required to:

 Ensure the confidentiality of any user data, such as a username or password, so that this data remains accessible only to you.

 Choose a secure password. This means that it must consist of at least 8 characters combining both letters and other characters, arranged in an order that cannot be easily discovered.

 Provide valid and usable contact information so that you can be contacted within a reasonable timeframe and in a reasonably confidential manner.

 Maintain the security of your workstation, including up-to-date antivirus protection.

1. Links to Other Websites

 This data protection policy applies only to our website, and not to websites owned by third parties. We sometimes provide links to other websites that we believe may be of interest to our visitors. In such cases, we ensure that these websites meet the highest standards. However, due to the very nature of the Internet, we cannot guarantee the confidentiality and personal data protection rules of websites for which we provide an access link, and we cannot be held responsible for the content of websites other than our own.

1. In the Event of a Data Breach

FlowUP COMPUTER will notify the Client in detail if a data breach that may have an impact on the Client occurs on its side and is attributable to it, no later than 2 business days after FlowUP COMPUTER becomes aware of it.

FlowUP COMPUTER will, on its own initiative, communicate to the Client all available information concerning the data breach, in particular the nature and scope of the personal data involved and the planned security measures.

Nevertheless, even in the event of a data breach, FlowUP has taken preventive measures by heavily encrypting all end-user data, thereby making stolen data unusable.

1. As Part of Our In-Store Backup Services

 As part of our backup services, we implement all reasonable measures to assure our customers that their personal data processed by us is limited solely to the personal data reasonably necessary for the purposes set out in our Privacy Policy, in particular the provision of services to them. Our customers’ personal data is processed only for the time necessary for the intended purposes and for which we have a valid legal basis, namely their explicit request for data backup, and because it is in our legitimate interest to process this data for the continuation of our business and the performance of our obligations arising from said contract. In addition, we will retain the Personal Data for a period of one month, after which the data will be destroyed, except in the event of written instruction from the customer validating immediate destruction.

1. How to Contact Us

 If you have any questions regarding the protection of personal data, or if you wish to send us recommendations or comments aimed at improving its quality, please contact us by post at the address above or by email at [email protected] .

GM ASSOCIATION SRL

Terms of Use

​ Intellectual Property This website is protected by copyright, all rights reserved. Any reproduction and/or redistribution of content by any means whatsoever must be subject to specific authorization from FlowUP via [email protected] . All information reproduced on this website, including products, articles, photos and logos, is protected by intellectual property rights held by FlowUP. Consequently, none of this information may be reproduced, modified, transmitted, redistributed, translated, sold, commercially exploited or reused in any way whatsoever without the prior written consent of FlowUP.

[email protected]