Privacy Policy
Effective as of 2026-03-31
This privacy policy applies to the Flow app (hereby referred to as "Application") for mobile devices that was created by Flow (hereby referred to as "Service Provider") as a Free service with optional paid subscriptions. This service is intended for use "AS IS".
Data Controller Information
The data controller responsible for your personal information is:
- Name: Boris Bugor (trading as Flow)
- Address: 29A Falcon Road, SW11 2PH, London, UK
- ICO Registration Number: ZC081819
- Email: support@getflow.life
Information Collection and Use
The Application collects information when you download and use it. This information may include:
- Your device's Internet Protocol address (e.g. IP address)
- The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
- The time spent on the Application
- The operating system you use on your mobile device
The Application collects coarse location data for analytics purposes. This data is not used to track your precise location.
The Service Provider may use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.
For a better experience, while using the Application, the Service Provider may require you to provide us with certain personally identifiable information, including but not limited to device identifier and user ID. The information that the Service Provider requests will be retained by them and used as described in this privacy policy.
CloudKit and iCloud Sync
The Application uses Apple's CloudKit service to synchronise your data (events, locations, images, and profile) across your devices signed into the same iCloud account. This data is stored in your private iCloud container and is not accessible by the Service Provider. Apple's iCloud terms and privacy policy govern this data storage.
Third Party Access
Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.
Please note that the Application utilises third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:
- Firebase Crashlytics — Crash reporting and diagnostics
- Amplitude — Analytics (coarse location, device ID, product interaction)
- RevenueCat — Subscription and purchase history management
The Service Provider may disclose User Provided and Automatically Collected Information:
- as required by law, such as to comply with a subpoena, or similar legal process;
- when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- with their trusted services providers who work on their behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
What Data Is Collected
Based on the Application's privacy report, the following data is collected:
| Category | Data Type | Purpose | Linked to You |
|---|---|---|---|
| Location | Coarse Location | Analytics | Yes |
| Identifiers | User ID | App Functionality | Yes |
| Identifiers | Device ID | Analytics | Yes |
| Purchase History | Purchase History | App Functionality | No |
| Usage Data | Product Interaction | Analytics | Yes |
| Diagnostics | Crash Data | App Functionality | No |
| Diagnostics | Other Diagnostic Data | App Functionality & Analytics | No |
None of the collected data is used for tracking purposes.
Opt-Out Rights
You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
Data Retention Policy
The Application does not operate its own servers or backend storage. Data is handled as follows:
- Local Device Storage: Your events, profile, and images are stored locally on your device using SQLite and synchronised via Apple's CloudKit. You can delete this data at any time within the app settings or by uninstalling the Application.
- Third-Party Service Providers: Data processed by third-party services (Firebase Crashlytics, Amplitude, RevenueCat) is retained according to their respective privacy policies and data retention periods. We do not control the retention periods of these third-party services.
- Data Deletion: You can delete all your data at any time from the app settings. Data held by third-party service providers is subject to their respective deletion policies.
Children's Privacy
The Application is rated 4+ on the App Store and is suitable for all ages. The Application does not knowingly collect personally identifiable information from children. All data is stored locally on the user's device and synchronised via Apple's iCloud, which is managed by the child's parent or guardian through Apple's Family Sharing and Screen Time controls.
If you are a parent or guardian and you believe your child has provided personal information through a third-party service used by the Application, please contact the Service Provider at support@getflow.life so that they will be able to take the necessary actions.
Security
The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information the Service Provider processes and maintains. All data synchronised via CloudKit is encrypted in transit and at rest using Apple's encryption standards.
Legal Basis for Processing (UK GDPR)
We process your personal data based on the following legal grounds:
| Data Type | Purpose | Legal Basis |
|---|---|---|
| User ID | Authentication & app functionality | Contract — necessary to provide the service |
| Device ID & analytics | App improvement & performance monitoring | Legitimate interest — improving our service |
| Coarse location | Analytics | Legitimate interest — improving our service |
| Purchase history | Subscription management | Contract — necessary to process payments |
| Crash & diagnostic data | App stability & bug fixing | Legitimate interest — maintaining service quality |
International Data Transfers
Your personal data may be transferred to and processed in countries outside the United Kingdom and European Economic Area (EEA), including the United States. These transfers are made to the following third-party service providers:
- Firebase Crashlytics / Google (United States): Provides crash reporting and diagnostics
- Amplitude (United States): Provides analytics services
- RevenueCat (United States): Manages subscriptions and payments
We ensure that these transfers are protected by appropriate safeguards, including Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO) and European Commission. Each provider has committed to GDPR-compliant data processing through their Data Processing Agreements.
Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you
- Right to Rectification: Request correction of inaccurate personal data
- Right to Erasure: Request deletion of your personal data (also known as the "right to be forgotten")
- Right to Restrict Processing: Request that we limit how we use your data
- Right to Data Portability: Request a copy of your data in a machine-readable format to transfer to another service
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time
To exercise any of these rights, please contact us at support@getflow.life with proof of your identity. We will respond within 30 days.
Right to Lodge a Complaint: If you believe we have not handled your data properly, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or call 0303 123 1113.
Changes
This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
Your Consent
By using the Application, you are consenting to the processing of your information as set forth in this Privacy Policy now and as amended by us.
Contact Us
If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at support@getflow.life.