CASHEWW CONSULTING LLC

PRIVACY POLICY

Casheww Consulting, LLC, d/b/a Flowt, a Delaware limited liability company (“Flowt” or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (this “Privacy Policy”). This Policy describes the types of Personal Information (as defined below) we may collect from you through our website at www.flowtnow.com (the “Website”), whether through a computer or on a mobile device and when you register with us or otherwise engage with our services. This Privacy Policy is intended to be read by and pertains to the processing of Personal Information in connection with users of the Website, anyone who receives services from Flowt (the “Services”), Flowt’s customers, and any other person who provides Flowt with Personal Information. Any use of the Website or the Services may contain links to other websites for your convenience and information; we are not responsible for the privacy practices or the content of those websites.

This Privacy Policy covers the following sections:

• Personal Information We Gather About You

• How We Collect Your Personal Information

• What We Do with Your Personal Information

• How We Share Your Personal Information

• Flowt’s E-mail Policy

• Email Opt-Out Policy

• Personal Information Rights and Choices

• Other Information

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. When you visit the Website, use the Services, or take certain other actions described below, you consent to our collection and use of information about individuals as described below.

If you do not agree with our policies and practices, your choice is to not visit the Website, use the Services, or provide us with any Personal Information. This Privacy Policy may change from time to time. Your continued use of the Website or Services, in each case after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

If you have any questions about this Privacy Policy or how we manage the information that you provide to us, please email us at privacy@flowtnow.com, or write to us at Casheww Consulting, LLC., 1330 Avenue of the Americas, Suite 54B, New York, New York 10019, Attn: Privacy.

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PERSONAL INFORMATION WE GATHER ABOUT YOU

Flowt gathers the following information (collectively, “Personal Information”):

Registration Information. Registration for Services may require that you supply Flowt with Personal Information, including the following: name, a unique e-mail address, telephone number, billing address, business contact, title, and taxpayer identification number. We may require you to provide us with additional information to confirm verification and identification.

Transaction Information: When you use our Services to make payments, we collect information about the transaction, as well as other information associated with the transaction such as the date of the transaction, description of the transaction, invoice number, the payment amounts, and information regarding the recipient of the payment, including without limitation, the name and address, business contact, and bank account numbers to facilitate payments by check or wire transfer.

Other information: We may collect additional information from or about you when you communicate with us or contact our customer support team.

Social Media. When you share or recommend any Company content to your Facebook, Instagram, Twitter, TikTok, LinkedIn, or other social media profile, that action is governed by the privacy policy of the applicable social media platform. In addition, the Company may collect Personal Information via social media platforms in connection with marketing campaigns.

Device Information. We may collect non-personal information about the computer, mobile device or other devices you use to access Services or the Website, such as IP address, unique device identifiers, browser type, browser language and other transactional information. We do not collect geolocation information, although we reserve the right to do so in the future.

Cookies, Beacons, Local Storage and Other Similar Technologies. In providing the Services and the Website, we may use “cookies,” Web beacons, HTML5 local storage and other similar technologies to manage access to and use of the Services and the Website, recognize you and provide personalization, as well as to help us understand where our visitors are going and how much time they spend there. You may not be able to access certain aspects of the Services, including portions of the Website, if your computer does not accept cookies from us.

IP Addresses. Flowt may log Internet Protocol (IP) addresses, or the location of your computer on the Internet, for systems administration and troubleshooting purposes. We use this information in an aggregate fashion to track access to our websites and mobile applications.

Log Files and Your Reading History. Flowt may automatically log certain usage information about your use of the Services, including a reading history of the pages you view on the Website. We may use this information to provide you with customized recommendations on the Website based on your viewing history. We also use log files in the aggregate to analyze the usage of our Website and mobile applications.

Information Collected by Third Parties Using Technology. Some of the services included in the Services, including on the Website, are delivered or served by third-party companies that may place or recognize cookies, Web beacons or other technology to track certain non-personal information about our website users. We do not have access to, nor control over service providers’ use of cookies or other tracking technologies or how they may be used. Your access to our Website should not be affected if you do not accept cookies served by third parties.

Credit Card and Debit Card Information. Flowt does not collect and/or store credit/debit card information. When you use our Services to make a payment using a credit or debit card, your payment information will be collected by Stripe, our third-party payment processor, and any successor payment processor, and not by us. Our payment processor may store payment card information to facilitate scheduled and future payments for your convenience.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Flowt obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you – Personal Information that you input into the Website or any mobile app maintained by us, provide to us via email, over the telephone, via text message, provide to us on written forms or directly to our customer service team by telephone or chat.

• Records and copies of your correspondence (including email addresses), if you contact us through email or other correspondence.

The technologies we use for data collection may include:

• Cookies (or application cookies): A cookie is a small file placed on the browser of your computer or smartphone. You may refuse to accept browser or mobile cookies by activating the appropriate setting on your browser or smartphone. Detailed instructions on how to modify your settings are provided by your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website. If you do not accept all cookies or withdraw your consent, you may still browse the Website; however, you may not be able to use the full functionalities of the Services.

• Clear GIFs: We employ a software technology called clear gifs (aka web beacons/web bugs), that helps us better manage the content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of a sentence. We do not currently tie the information gathered by clear gifs to your Personal Information, although you agree that we may do so in the future.

• Log Files: As is true of most websites, we gather information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, administer the site, track users’ movements around the site and gather demographic information about our user base as a whole.

When you use the Website, we may receive “do not track” requests from you, whether via signals from Web browsers or other mechanisms.  At this time, we do not respond to such “do not track” requests, although we may choose to do so in the future.

We do not currently purchase any Personal Information from third parties for use in Flowt’s business, although we reserve the right to do so in the future.

We neither place ads on third parties’ websites, nor support ads on the Website, in each case that collects users’ Personal Information for purpose of customizing those ads or otherwise. Notwithstanding the foregoing, we reserve the right to do either or both in the future.

WHAT WE DO WITH YOUR PERSONAL INFORMATION

Providing the Services You Request. We use the information we gather about you to provide, improve and develop the Services. We may use your information to:

• enable your use of the Website and Services and fulfill your requests for Services, which may include sending your Personal Information to third-party payment processors; and

• deliver the information and support you request, including technical notices, security alerts, and support and administrative messages including to resolve disputes, collect fees and provide assistance for problems with our Services; and

Statistical Analysis. While we do not currently perform statistical, demographic and marketing analyses of users of the Services and the Website, we reserve the right to do so in the future in order to use this information for analysis purposes, including analysis to improve and optimize the Website and the Services.

Customizing Your Experience. We may use your Personal Information to customize certain features of the Website to provide you with an enhanced experience based on the type of device you are using to access the Website, and in certain cases, provide you with requested Services. 

E-Mail Promotions. Flowt will periodically send you promotional e-mails about Services offered by Flowt.

Legal Purposes. We may use your Personal Information to compare information for accuracy and verify it with third parties for purposes of complying with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity and financial reporting obligations to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards and by our financial partners, and may require us to report our compliance to third parties, regulators or law enforcement and to submit to third-party verification audits.

HOW WE SHARE YOUR PERSONAL INFORMATION

Flowt. Flowt will store your Personal Information in the cloud using Airtable or any successor provider and such storage system will be monitored by Flowt. Such information will be accessed only by employees and independent contractors of Flowt on an as-needed basis, each of whom will be bound by confidentiality obligations to Flowt.

Flowt Media. If you use the Services and/or the Website, we will not sell, rent, swap or authorize any third party to use your e-mail address or any Personal Information without your permission, unless otherwise specified in this Privacy Policy, provided that nothing in this Privacy Policy is intended to restrict the use of aggregated or de-identified information in any way, whether by Flowt or any of its service providers. We may sell, buy, merge or partner with other companies or businesses in the future. In such transactions, we may include your Personal Information among the transferred assets.

Customer Vendors. When utilizing the Services to make a payment to a third party, we may disclose, at your request, certain information about you and the transaction to such third party. This information is subject to change at any time and may include, but is not limited to, your business name, address, phone number, the invoice number and details from any such invoice submitted by such third party to you.

Service Providers. We provide access to and share your information with our payment processor and other third parties who may perform services on our behalf, including, without limitation, billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, auditing, fraud prevention, and legal services. We provide these companies only with the information they need to perform their services. These service providers are restricted from using this data in any way other than to provide services for Flowt and the Services, and they may not share, resell or use the data for their own direct marketing purposes. Although we do not currently do so, in the future we may share your Personal Information with third parties for analytics purposes, including to improve and optimize the Website and the Services.

Any Personal Information we share with third parties will be subject to the privacy policies of such third parties, all of which are publicly available.

We reserve the right to disclose your opt-out information to third parties so they can suppress your name from future solicitations, in accordance with applicable laws. We may occasionally release Personal Information as required by law, for example, to comply with a court order or subpoena. For more information, see the “Compliance with Legal Process” section of this Privacy Policy below.

Notwithstanding any other provision set forth herein, we may in the future partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business.  Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share Personal Information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID.  Our partners may link the hashed or obfuscated personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information.  Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting purposes.

SECURITY

The Website has industry-standard security measures in place to protect against the loss, misuse, and alteration of the information under our control. We have implemented measures designed to secure Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, monitor your account, use strong passwords, and change your passwords frequently to help protect your information.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to, through, or by Flowt over the Internet. Any transmission of Personal Information is at your own risk.

We will keep your information for as long as it remains necessary for the operation of the Services or as required by law, which may extend beyond the termination of our relationship with you. However, even after you close your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statutes of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.

FLOWT’S E-MAIL POLICY

Account and Service-Related E-Mail. Flowt reserves the right to send you e-mails relating to your use of the Website and/or the Services. This includes invoices, payment confirmations, renewal/expiration notices, notices of payment problems, other transactional e-mails, and notifications about major changes to the Services and/or to our Privacy Policy or other Terms of Service.

Marketing E-Mail. We may send marketing-related e-mails and/or e-mails inviting you to participate in user surveys, asking for feedback on the Website and existing or prospective Services, as well as information to better understand our users. User surveys greatly help us to improve Services, and any information we obtain in such surveys will not be shared with third parties, except in aggregate form.

E-Mails From You. If you send us e-mails, you should be aware that any Personal Information disclosed in e-mails may not be secure or encrypted and thus may be available to others. We suggest that you exercise caution when deciding to disclose any Personal (or confidential) Information in e-mails. We may use your e-mail address to respond directly to your questions or comments.

E-MAIL OPT-OUT POLICY

E-Mail Promotions. If, at any time, you prefer not to receive any e-mail marketing information from us, simply follow the unsubscribe link included in such e-mails. We will comply with your request as soon as reasonably practicable and in accordance with applicable law. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

**Protection of Your Information. ** To prevent unauthorized access, maintain data accuracy and ensure the appropriate use of information, we have put in place commercially reasonable physical, technical and administrative controls to protect the information. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.

PERSONAL INFORMATION RIGHTS AND CHOICES

California Privacy Rights. The California Consumer Privacy Act of 2020 (the “CCPA”) permits natural persons who are California residents to request certain information regarding our disclosure of such residents’ personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please e-mail us at: privacy@flowtnow.com.

Pursuant to CCPA’s requirements, the following table provides a summary of (1) the categories and/or specific pieces of Personal Information that we may collect about you or your third parties payees, (2) the categories of sources for that Personal information, (3) the purposes for which we use that information, (4) the categories of third parties with whom we may disclose that information, and (5) the categories of information that we may sell or disclosure to third parties.

In addition, we may collect, use and disclose your Personal Information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

The CCPA and certain other state regulations require that individuals be provided with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights.

Access to Specific Personal Information and Data Portability Rights. You may access, update, correct or extract all Personal Information from Flowt. For both Personal Information relating to users and to the third parties about which you imputed Personal Information, you have the right to request that Flowt disclose certain Personal Information to you about our collection and use of the Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable individual request, we will disclose to you:

• The categories of Personal Information we collected about you or an individual about which you inputted Personal Information.

• The sources for the Personal Information we collected about you or an individual about whom you inputted Personal Information.

• Our business or commercial purpose for collecting that Personal Information.

• The categories of third parties with whom we share that Personal Information.

• The specific pieces of Personal Information we collected about you or an individual about which you inputted Personal Information (also called a data portability request).

Deletion Request Rights. You may request to delete all Personal Information you have input. You have the right to request that Flowt delete any Personal Information about you that you have input or that was collected and retained, subject to certain exceptions including regulatory data retention requirements. Once we receive and confirm your verifiable individual request, we will delete (and direct our service providers to delete) the Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the Personal Information is necessary for us or our third-party service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a Service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation, including, but not limited to, compliance with applicable state and federal regulations that govern the retention of Personal Information.

• Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale or Sharing of Personal Information. Subject to applicable exceptions, you may request that we stop using all or some of your information, limit our use of your information or opt out of the sale of your Personal Information, as “sale” is defined in applicable data privacy laws. Although Flowt does not sell your Personal Information, it may from time to time share your Personal Information with third parties to improve the Services and to market additional opportunities to you by these third parties. These transfers may be deemed a sale under certain data privacy laws. Accordingly, we offer the option for you to opt out of the sale of your personal information as set forth below. Please note that your decision to opt out of the sale of your Personal Information may impact the availability and quality of some of the Services provided to you.

Exercising Access, Data Portability, Deletion, and Opt-Out Rights. To exercise the access, data portability, deletion, and opt-out rights described above, please submit a verifiable request to us by email at privacy@flowtnow.com or by clicking on the Do Not Sell My Personal Information link on our website. Only you may make a verifiable request related to Personal Information that we collected from you or your users. You may make a verifiable request as the individual that the Personal Information is about (the user) or on behalf of an individual whose Personal Information you have provided to us, in such a case you must provide the verification for that individual. You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are either (i) the person about whom we collected Personal Information or (ii) an authorized representative who inputs the Personal Information.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you or an individual about whom you inputted Personal Information.

We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

Response Timing and Format. We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option and direction. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance.

Non-Discrimination. We will not discriminate against you for exercising any of your Personal Information rights. Unless permitted by applicable law and regulations, and unless the use of your Personal Information is required to maintain a business relationship with you or provide you with the Services, we will not:

• deny you Services;

• charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties;

• provide you a different level or quality of Services; or

• suggest that you may receive a different price or rate for Services or a different level or quality of Services.

Residents of Connecticut, Nevada, Colorado and/or Virginia. If you are a Connecticut, Colorado, Nevada or Virginia resident, you may take advantage of certain privacy rights, such as requesting access, correction, or deletion of your personal information. Because we may “sell” personal information or engage in “targeted advertising” as these terms are defined in Connecticut, Colorado, and Virginia laws, you may also exercise your right to opt out of such sales or targeted advertising by contacting us at privacy@flowtnow.com. You have the right to appeal a denial of your privacy rights.

OTHER INFORMATION

Compliance With Legal Process. We may disclose Personal Information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of Services or the Website; or (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

Jurisdiction. Flowt is operated from the United States.  If you are using the Services visiting the Website from outside of the United States, you agree to any processing of any Personal Information you provide to us according to this Privacy Policy.

Children’s Guidelines and COPPA Compliance. Minors and children should not use the Website or the Services. Flowt does not knowingly collect or store any personal information about children under the age of 13. If you are the parent or guardian of a child under the age of 13, and you believe that Flowt may have inadvertently collected personal information about your child, please contact Flowt immediately at privacy@flowtnow.com.

Changes to This Policy. This Privacy Policy may be amended from time to time. Any such changes will be posted on this page. This Privacy Policy was last updated and effective on [●], 2023.

Contact. If you have any questions or suggestions regarding this Privacy Policy or your rights hereunder, please contact us as follows:

By email: privacy@flowtnow.com.

By mail: Casheww Consulting, LLC, 1330 Avenue of the Americas, Suite 54B, New York, New York 10019.