Flowvi.be Flowvi.be

Privacy Policy - Flowvi.be app

Effective date: 22 October 2025

Controller: Headbright Group (KBO 0675712193)

Registered office: Brusselsesteenweg 166G, 9090 Merelbeke-Melle, Belgium

Contact: contact+privacy@flowvi.be

1) Scope

This Policy explains how we process personal data when you use the Flowvi.be mobile application and related support channels. It is governed by Belgian law and the EU General Data Protection Regulation (GDPR).

2) Data we collect

  • User inputs: in-app settings.

  • Music metadata (temporary): limited identifiers (e.g., song title, album, artist) used to match items in your library. Deleted automatically from our servers within 30 days.

  • Device/diagnostics: non-identifying technical data (e.g., device model, OS version, app version, basic performance and crash logs).

  • Third-party integrations: if you connect Apple Music or other music services, we receive the minimum permissions/tokens needed to discover songs in your library and generate and publish playlists.

  • Support communications: messages you send to our support inboxes.

On-device storage and iCloud

Most user settings and playlist preferences are stored on your device. If you enable iCloud sync in your Apple settings, those on-device items may be synced to your iCloud account. iCloud is provided by Apple under Apple’s terms and policies; Apple acts as an independent controller for that processing. You can enable/disable iCloud sync and manage iCloud content in your device/iCloud settings. We do not access or control your iCloud content.

3) Purposes of processing

  • Generate and customize playlists.

  • Provide and operate third-party music integrations you choose.

  • Maintain safety, security, and performance (including debugging and preventing abuse).

  • Provide support and comply with legal obligations.

We do not sell personal data and do not use your data to train generalized AI models.

4) Legal bases

  • Performance of a contract: to deliver the app and requested features.

  • Legitimate interests: app security, diagnostics, and improvement (balanced against your rights).

  • Consent: when you connect third-party music services or where consent is otherwise required. You may withdraw consent at any time via app or device settings or by contacting us.

5) Retention

  • Music metadata cache: up to 30 days.

  • Diagnostics/usage data: up to 24 months, unless longer is required for security or legal reasons.

  • Support records: up to 36 months after case closure.

  • Integration tokens/permissions: while the integration remains connected or until revoked.

We keep data only as long as needed for the stated purposes, then delete or irreversibly anonymize it.

6) Data location (EU-only)

All Flowvi.be infrastructure is hosted within the European Union. We do not transfer your personal data outside the EU.

Note: If you enable iCloud, Apple’s processing (including storage locations and international transfers) is governed by Apple’s terms and privacy policy, which are outside our control.

7) Sharing and recipients

  • Processors (sub-processors): EU-based service providers under data-processing agreements and confidentiality.

  • Third-party music services: when you connect them, they act as separate controllers under their own policies.

  • Legal/compliance: where required by law or to protect rights/safety.

8) Your rights (EU)

You can request access, rectification, erasure, restriction, portability, and objection. Where we rely on consent, you can withdraw consent at any time. We aim to respond within 10 business days or no later than established GDPR timelines.

You may lodge a complaint with the Gegevensbeschermingsautoriteit (GBA/APD) in Belgium or your local authority.

9) Security

We apply proportionate technical and organizational measures (e.g., access controls, encryption in transit, least-privilege practices). No system is perfectly secure, but we work to prevent, detect, and respond to incidents.

10) Children

The app is not directed to children. To use the app you must be at least 13 years old, or older where national law sets a higher age for digital consent.

11) Changes

We may update this Policy. We will display the updated effective date in-app.

12) Contact

  • Privacy requests: contact+privacy@flowvi.be

  • Postal: Headbright Group, Brusselsesteenweg 166G, 9090 Merelbeke-Melle, Belgium