Last updated: 30/09/2026
This Privacy Policy is provided by [FULL NAME / COMPANY NAME], [sole proprietor / legal form], tax code [CODICE FISCALE], VAT No. [PARTITA IVA], with address at [ADDRESS], operating the FlowFinance platform ("FlowFinance", "we", "us"). Privacy contact: help@flowfinance.cc.
This policy applies to personal data processed through the FlowFinance platform ("the Service"), in accordance with Regulation (EU) 2016/679 ("GDPR") and applicable Italian data protection law.
As data controller, we process the personal data of our users (account, usage and billing data), as described in this policy.
As data processor, we process, on behalf of our business customers and under our Data Processing Agreement ("DPA"), the personal data contained in the documents they upload (for example invoices, balance sheets and bank statements). For that data, the customer is the controller and determines the purposes of processing. Section 10 explains how individuals can exercise their rights.
| Purpose | Legal basis (GDPR) |
|---|---|
| Creating and managing your account; providing the Service; managing your subscription and payments | Performance of a contract (Art. 6(1)(b)) |
| Processing Customer Data to generate scores and reports | Our DPA with you (Art. 28); you as controller are responsible for the legal basis of the processing |
| Security, fraud prevention, abuse detection, service improvement and analytics on our own usage data | Legitimate interests (Art. 6(1)(f)) |
| Accounting, tax and other legal obligations | Legal obligation (Art. 6(1)(c)) |
| Non-essential cookies and, where applicable, marketing communications | Consent (Art. 6(1)(a)), which you may withdraw at any time |
| Establishing, exercising or defending legal claims | Legitimate interests (Art. 6(1)(f)) |
We do not sell your personal data. We do not use Customer Data to train third-party AI models, and we do not allow our AI providers to do so with it.
The Service uses automated and AI-assisted analysis to generate payment behavior, financial health and risk scores. These outputs are provided to our business customers as informational support and are not a decision taken by us about any individual. Customers are responsible for the decisions they make and, where scores concern individuals, for ensuring human review and compliance with GDPR Art. 22 and other applicable rules.
We share personal data only with providers strictly necessary to operate the Service, acting under written agreements that impose confidentiality and data protection obligations: hosting and infrastructure (including Base44), AI processing providers, email delivery, payment processing, and professional advisers (e.g. accountants, lawyers). The current list of sub-processors is available at [URL]. We may disclose data when required by law or by a competent authority. We never share data with third parties for their own marketing purposes.
Some providers may process data outside the European Economic Area. In that case, we ensure an adequate level of protection through an adequacy decision (including the EU-US Data Privacy Framework where the provider is certified), or Standard Contractual Clauses with additional safeguards where needed. You can request a copy of the safeguards at help@flowfinance.cc.
We apply appropriate technical and organizational measures, including encryption in transit, access controls, role-based permissions, hashing of API keys (we never store them in plain text), and logging of access. In case of a personal data breach, we will notify the competent authority and the affected customers as required by GDPR.
You have the right to access, rectify, erase, restrict, object to the processing of, and receive in a portable format your personal data, and to withdraw consent at any time without affecting prior processing. To exercise these rights, write to help@flowfinance.cc. We will respond within one month.
If your data is contained in documents uploaded by one of our customers, that customer is the controller of your data: please contact them first. If you contact us, we will forward your request and assist them as required by law.
You also have the right to lodge a complaint with the Italian data protection authority, Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the authority of your place of residence or work.
The Service is intended for businesses and professionals and is not directed to anyone under 18. We do not knowingly collect data from minors.
We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies are used only with your consent.
We may update this policy. We will notify you of material changes through the Service or by email, at least [30] days before they take effect where required.
For any privacy question or request: help@flowfinance.cc, [ADDRESS].