Fluxion Portal privacy notice

1. Controllers and roles

The controller for shared-work content, recipient data, and work-related acknowledgements is normally the company that shared the work and is named in the shared view. It determines the purpose, data, access, and retention of the share. ProduXion Oy then provides Fluxion Portal as its processor under the customer's instructions and data processing agreement.

ProduXion Oy is the controller for Portal operational and security data, support requests, evidence of privacy choices, and optional convenience data used locally in this browser. Customer agreements may specify the roles further; the sharing company's privacy information applies together with this notice. If the share does not show that company's own privacy channel, support@fluxion.fi receives the request and forwards it to the named sharing company. Acting as this contact channel does not make ProduXion the controller for shared-work data.

2. Data, purposes, and legal bases

• Shared work: identifiers, title, status, stages, schedules, quantities, contacts, selected documents, and recipient acknowledgements or reports. The sharing company determines the legal basis, usually contract, legal obligation, or legitimate interests.
• Access security and technical logs: Google Cloud edge, load-balancer, and service logs may contain the raw IP address, request time, method, route, response status, user agent, other ordinary browser/device headers, and error data. The Portal API also processes the tracking code, pseudonymous browser binding, session, CSRF protection, and password-check result, and creates a separate HMAC digest from the IP address for rate limiting and audit evidence. The purposes are secure service delivery, abuse prevention, and incident investigation. The legal basis for ProduXion's own processing is legitimate interests under GDPR Article 6(1)(f); contract or pre-contractual steps under Article 6(1)(b) apply only where the data subject is personally a party to the contract or requests those steps. The sharing company determines the legal basis for shared-work data processed on its behalf.
• Actions and evidence: action type, target, submitted content, idempotency identifier, timestamps, status, and technical receipt. The bases are performance of the service/customer agreement and legitimate interests in evidencing agreed events.
• Support: your message, contact details, and service information needed to resolve the matter. The bases are taking requested steps, contract, and legitimate interests in customer support.
• Browser convenience data: quick works, remembered secure return, and demo access are processed only with your consent. Quick-work and demo data remain local. The random secure-return binding is sent to the first-party Portal API only to verify an existing HttpOnly session.
• Privacy choice: random receipt ID, selected category, time, notice version, method, language, and expiry. The bases are compliance with legal obligations and legitimate interests in demonstrating a compliant choice.

3. Sources

Data comes from the company sharing the work and its Fluxion v1 or v2 provider, from you when you make a choice or perform an action, and automatically from technical device and request data. Portal does not build advertising profiles or buy data from data brokers.

4. Recipients, processors, and transfers

Shared-work data and your acknowledgements are delivered to the sharing company and its chosen Fluxion v1 or v2 provider only within the permissions of the share. Authorised ProduXion personnel access data only when support, maintenance, or security requires it.

The service uses Google Cloud for infrastructure, database, secret management, load balancing, and logging. Google Cloud acts as processor for data ProduXion handles in its own controller role and as subprocessor for shared-work data handled on the customer's behalf. Production is configured for Google's EU region in Finland. If a transfer outside the EEA occurs, the applicable adequacy decision or EU Standard Contractual Clauses and supplementary safeguards are used under the applicable agreement.

Data is disclosed to authorities only where required by law. ProduXion does not sell personal data.

5. Retention

• Shared work and events: under the sharing company's policy and customer agreement; access ends no later than expiry or revocation of the share.
• Browser-session access: by default no more than 7 days, a 24-hour idle limit, or earlier share expiry. An expired session can no longer provide access.
• Access, action, expired-session, and audit records: for the customer- and environment-specific documented retention period. The period is determined from contractual audit needs, the time needed to investigate security incidents and legal claims, and data minimisation; the standard service-policy target for audit data is 12 months. ProduXion or the sharing company can provide the applicable customer-specific period.
• Google Cloud system, edge, and load-balancer logs: for the retention period configured on each production environment's Cloud Logging bucket and log route. The period starts when the entry is created; ProduXion provides the applicable number of days for that environment on request. Logs are used only for security, incident investigation, and service reliability.
• Support data: for the time needed to resolve the matter and ordinary contractual or legal claims.
• Portal uses local convenience data and the consent receipt for no more than 180 days and a remembered return binding for no more than 7 days. Because localStorage does not expire by itself while the site is closed, Portal deletes expired data on the next Portal visit. Withdrawal deletes optional data immediately.
• Language preference: up to one year from the latest choice.

6. Your rights

Depending on the circumstances, you may request access, correction, erasure, restriction, or portability and object to processing based on legitimate interests. You may withdraw optional browser-storage consent at any time through the cookie icon at the bottom left of the screen without affecting earlier lawful processing.

Send requests about shared-work content first to the company that shared the work. If its contact details are not shown in the share, you may send the request to ProduXion below for forwarding to the named sharing company. ProduXion handles requests that concern its own controller role. Identity may be verified securely before a request is fulfilled.

Privacy and cookie contact: support@fluxion.fi

You may lodge a complaint with the Finnish Data Protection Ombudsman

7. Required data and consequences

The tracking code, any share password, and technically necessary session data are required to open shared work. Required action fields are needed to send that acknowledgement or report. Optional browser storage is not required: Portal and shared work remain usable, but quick works, remembered return, and remembered demo access are unavailable.

8. Automated decisions and tracking

Portal does not make legal or similarly significant automated decisions about users and does not profile users for advertising. It currently uses no analytics, advertising, session-replay, or third-party tracking tools.

9. Security

Controls include HTTPS, HttpOnly and SameSite session cookies, browser binding, CSRF protection, short-lived service identity, least-privilege access, input validation, rate limits, and redaction of sensitive log fields. Raw share access tokens and passwords are not stored in quick-work data.

10. Contact and changes

For Portal operational data, the controller is ProduXion Oy, Business ID 3605230-4, Amerintie 1, 04320 Tuusula, Finland. Use the email address below for privacy matters.

This notice is updated when processing, providers, or law changes. A material change to optional browser storage triggers a new consent request.

Privacy and cookie contact: support@fluxion.fi