Legal

Privacy Policy

Last updated: January 29, 2025

1. Introduction

Flowly ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service.

2. Information We Collect

Account Information: When you create an account, we collect your email address and display name. If you sign up with Google, we receive your basic profile information.

Usage Data: We collect information about how you interact with our service, including server deployments, connection configurations, and API usage statistics.

Technical Data: We collect IP addresses, device information, browser type, and access timestamps for security and analytics purposes. IP addresses are retained for 90 days.

Payment Information: If you subscribe to a paid plan, payment processing is handled by Stripe. We do not store your credit card details.

3. AI Processing & Third-Party Providers

Your messages sent to AI assistants are processed by third-party AI providers. By using the Service, you acknowledge:

  • Messages are sent to AI providers (OpenRouter) for generating responses
  • AI providers may retain data according to their own privacy policies
  • We do not have access to conversation content stored on your VPS
  • AI processing is necessary to provide the core functionality of the Service

We use OpenRouter as our AI provider, which routes requests to various AI models. Please review OpenRouter's privacy policy for details on their data handling practices.

4. Your Conversations

Conversations with your AI assistant through messaging platforms (Telegram, WhatsApp, Gmail) are stored on your own VPS server, not on our central infrastructure. We do not have access to these conversations. However, if you use the built-in chat feature in our dashboard (Server Details > Chat), those conversations are stored in our database to provide the chat functionality. We do not access or analyze dashboard chat content except for troubleshooting at your request.

5. How We Use Your Information

  • To provide and maintain our service
  • To process your transactions
  • To send you service-related communications
  • To respond to your inquiries and support requests
  • To improve our service and develop new features
  • To detect and prevent fraud, abuse, and security incidents
  • To comply with legal obligations

6. Data Sharing & Disclosure

We may share your information in the following circumstances:

Service Providers: We use third-party services (Hetzner, Firebase, Stripe) to operate our platform. These providers only access data necessary for their services.

Legal Requirements: We may disclose information when required by law, court order, or government request.

Safety & Emergencies: We may share information to prevent harm, protect safety, or respond to emergencies.

Business Transfers: In case of merger, acquisition, or sale of assets, your information may be transferred to the new entity.

7. Law Enforcement Requests

We respond to valid legal requests from law enforcement agencies, including:

  • Court orders and subpoenas
  • Search warrants
  • Emergency disclosure requests (when there is imminent risk to life)
  • National security letters (where applicable)

We will notify you of legal requests unless prohibited by law. We may challenge requests we believe are overbroad or unlawful.

8. International Data Transfers

Your data may be transferred to and processed in countries outside your residence, including the European Union, United States, and other jurisdictions where our service providers operate. We implement appropriate safeguards including Standard Contractual Clauses for EU data transfers.

9. Data Security

We implement appropriate technical and organizational security measures to protect your personal information:

  • All data is encrypted in transit using TLS 1.3
  • Data at rest is encrypted using AES-256 encryption
  • Access controls and authentication requirements
  • Regular security audits and vulnerability assessments

10. Data Retention

We retain your account information for as long as your account is active. When you delete your account, we will delete your personal information within 30 days, except where we are required to retain it for legal purposes or to resolve disputes.

11. Your Rights

Depending on your location, you may have the following rights under GDPR, CCPA, or other privacy laws:

  • Access your personal data
  • Correct inaccurate data
  • Request deletion of your data
  • Export your data in a portable format
  • Opt-out of marketing communications
  • Object to certain processing activities
  • Lodge a complaint with a supervisory authority

To exercise these rights, contact us at privacy@nocetic.com.

12. Children's Privacy

Our Service is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If we discover that we have collected information from a minor, we will delete it immediately.

13. Cookies & Tracking

We use essential cookies to maintain your session and preferences. We do not use tracking or advertising cookies. Our analytics are privacy-focused and do not track individual users across sites.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. For significant changes, we will also send an email notification.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

  • Email: privacy@nocetic.com
  • Website: https://useflowlyapp.com/contact