---
title: Privacy Policy
slug: privacy
description: How Flowvi.be handles your data - EU-only hosting, no data sales, and your GDPR rights explained.
date: 2025-11-25 00:00:00
content_type: legal
---

# Privacy Policy

**Effective date:** 25 January 2026

**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 to generate your playlists. Data is 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 have full control over your data. You can ask us for a copy, to correct it, or to delete it Just email us at contact+privacy@flowvi.be.

You may also 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