Legal

These Terms of Service (the "Terms") are a binding agreement between you and Flows, a sole-trader business based in England and Wales ("Flows", "we", "us", "our") and govern your access to and use of the Flows platform, dashboard, APIs, Concierge, and related software and services (together, the "Service").

By installing the Flows app, creating an account, or otherwise accessing or using the Service, you agree to be bound by these Terms and by our Privacy Policy and Acceptable Use Policy, which are incorporated by reference. If you do not agree, you must not use the Service.

The Service is offered for business use only. By accepting these Terms you confirm that you are at least 18 years old, that you are using the Service in the course of a trade, business, craft, or profession, and that — where you accept on behalf of a company or other organisation — you have authority to bind that organisation. References to "you" mean both you personally and any organisation you represent.

• Member — a business that installs or registers for the Service to run the Concierge on its site or store and, optionally, sell through it.
• Subscriber — a visitor or customer of a Member's site who chats with the Member's Concierge, joins a waitlist, or purchases a Member's paid product.
• Connected Site — a Wix, WordPress, Shopify, or other website or store that a Member connects to the Service.
• Inputs — the Concierge instructions and settings, brand settings, fonts, product data, data tables, and other material a Member supplies to or configures in the Service.
• AI Output — chat replies, text, images, summaries, recommendations, email copy, and other material the Service generates using artificial intelligence, including in response to Inputs.
• Content — Inputs and AI Output together, plus any other material a Member publishes, stores, or transmits through the Service.
• Billing Rail — the channel through which your Flows subscription is billed: Stripe (web / default), Wix App Billing (Wix App Market installs), or Shopify App Billing (Shopify App Store installs).
• Store Checkout — checkout on a Member's connected Wix or Shopify store (or another supported storefront), where the store platform is the payment host.
• Stripe Connect — the Stripe Connect integration through which a Member can charge Subscribers on the Stripe commerce path, as described in the Member Commerce & Payments section.
• Platform Fee — the percentage application fee Flows charges on transactions a Member processes through Stripe Connect only (not on Store Checkout), described in the Member Commerce & Payments section.

Flows is a software tool that puts an AI chat on a Member's website or store and, optionally, helps the Member sell through it. The Service currently includes:

• Concierge. An AI chat assistant that Members can enable on their site for Subscribers to ask questions, discover products, and (where enabled) preview products via image features.
• Commerce and monetisation. Subscriber subscriptions, product and order analytics, restock/waitlist automation, and Member payments via Stripe Connect and/or the Member's connected store checkout (for example Shopify or Wix), as available for their install.

Flows is a tool, not a publisher. The Member is the publisher and the editorial controller of all Content it generates, hosts, or distributes through the Service, and is responsible for that Content as set out in these Terms. We may add, change, suspend, or remove features of the Service at any time; where a change is material and adverse we will give reasonable notice.

You can create a Flows account by registering on the web through our identity provider (Clerk) — including email and password (with verification) or a supported single sign-on provider such as Google or X — or by installing the Flows app from a supported marketplace (including the Wix App Market or the Shopify App Store). You are responsible for the accuracy of the information you provide and for keeping it up to date.

You are responsible for all activity under your account and for keeping your credentials and connected-account access secure. You must notify us promptly at hi@flowcrews.com if you suspect unauthorised use. One individual or organisation should operate one account; you must not share an account in a way that circumvents tier limits or the Acceptable Use Policy.

We may refuse registration, or suspend or close an account, where required by law, where a connected platform (such as Wix, Shopify, Clerk, or Stripe) requires it, or where we reasonably believe these Terms or the Acceptable Use Policy have been breached.

You must use the Service lawfully and only for legitimate business purposes. You must not use the Service — and must not configure, prompt, or direct any AI feature (including the Concierge and its instructions) — to produce, publish, store, transmit, or facilitate any of the following:

• illegal activity, goods, or services;
• child sexual abuse material (zero tolerance; we report it to the relevant authorities), or other adult or sexual content involving minors;
• hate, harassment, incitement to violence, terrorism, or their facilitation;
• weapons, explosives, or controlled substances outside the bounds of applicable licensing;
• regulated financial services, lending, debt relief, or gambling without the required authorisation;
• misleading, deceptive, or fraudulent content, including AI-driven impersonation, fake reviews, and fake testimonials;
• defamatory content, or content that infringes another person's intellectual property, privacy, or other rights — including prompts that target copyrighted works, and uploads of third-party photographs without consent;
• biometric data of any third party uploaded without that person's informed consent;
• scraping or harvesting of personal data, including any misuse of data accessed through a connected platform's APIs ("user-of-user" data);
• unlawful, unsolicited, or non-consented marketing, or any use of automated messaging features (including restock/waitlist emails) to recipients for whom you do not hold a lawful basis to contact;
• health, legal, or financial advice presented without the professional review applicable law requires;
• attempts to prompt-inject, jailbreak, reverse-engineer, or train a competing AI system on the Service or its AI Output.

This list mirrors the acceptable-use rules of our payment and AI providers (including Stripe's Restricted Businesses list and the usage policies of our AI providers), which apply to you in addition to these Terms. We may remove Content, disable features, suspend automated agents, or suspend or close your account — with or without notice depending on severity — if we reasonably believe this section has been breached.

The Service uses artificial intelligence to generate text, images, and other material. AI Output is generated probabilistically and may be inaccurate, incomplete, out of date, or not unique. You must not rely on AI Output as a sole source of truth.

You are the editorial controller. You are responsible for the instructions and data the Concierge answers from, and for ensuring what it tells your Subscribers is accurate, lawful, non-infringing, and appropriate for your audience. This is particularly important for content on health, finance, law, or other matters of public interest, and for compliance with the EU AI Act's transparency duties.

No warranty of results. We do not warrant any particular traffic, conversion, revenue, or other outcome from AI Output or from the Service.

Ownership and intellectual-property rights. As between you and Flows, you own your Inputs and, to the extent such rights are capable of subsisting and of being assigned, we assign to you all rights we may have in the AI Output generated for you. However, AI Output may not attract copyright or other intellectual-property protection in every jurisdiction, and we cannot and do not warrant that AI Output is original, non-infringing, or owned by you. You are responsible for clearing rights in any material you supply and for checking that AI Output is suitable for your intended use.

Concierge instructions. Where you use instructions or other configuration to influence AI Output, you do so at your own risk and you accept sole responsibility for the resulting AI Output, including under the indemnity in the Indemnification section.

We do not train foundation models on your Content. We use AI providers under terms that, for the products we enable, are not intended for provider training on your Content; see the Privacy Policy for current providers. We do not warrant every third-party policy beyond those contractual terms.

When you connect a site or store (Wix, WordPress, Shopify, or another supported platform), you authorise Flows to access and use the data and APIs needed to provide the Service — for example your site identity and URL, content collections, media library, product catalogue, and the authentication tokens required to sync on your behalf. We use that access only to operate the Service for you, in line with the connected platform's developer terms.

Your relationship with each connected platform is governed by that platform's own terms, and your use of the Service does not change them. You are responsible for holding the rights and permissions necessary to connect a site and to let us process its data. Where a connected platform's rules conflict with a use you request, the platform's rules prevail and we may decline that use. You can disconnect a site at any time, which revokes our access going forward.

We do not use data accessed through a connected platform's APIs to build our own contact database, for our own marketing, or to train AI models, and we do not sell it.

The Service is offered on a free tier and on paid subscription tiers. Current tiers, their limits (such as the Concierge credit included), and their prices are shown on our pricing page and in the dashboard. Paid tiers are billed in advance on a recurring basis (monthly unless stated otherwise) through the Billing Rail that applies to your install — typically Stripe for web accounts, Wix App Billing for Wix App Market installs, or Shopify App Billing for Shopify App Store installs — and renew automatically until cancelled under that rail's rules.

• Cancellation. You can cancel at any time from the dashboard control for your rail (for example the Stripe Customer Portal, Wix App Billing management, or in-app Shopify subscription management). Cancellation takes effect at the end of the current billing period where the rail allows; you keep paid features until then. Refunds are covered below.
• Upgrades and downgrades. Upgrades take effect immediately and may be charged on a pro-rata basis. Downgrades take effect at the end of the current period, and usage limits and feature access adjust to the new tier — which may reduce the number of connected sites or the Concierge credit available to you.
• Taxes. Fees are exclusive of VAT and other taxes, which we will add where applicable.
• Failed payments. If a payment fails we may retry it, downgrade your account, or suspend paid features until the balance is settled.
• Price changes. We may change subscription prices on at least 30 days' notice; changes take effect at your next renewal and continued use after that constitutes acceptance.

Concierge credit

The Concierge runs on prepaid credit, held in US dollars for each connected site. Each conversation uses credit according to the AI processing it needs. Your dashboard shows each site's balance, what it has used, and every payment in and out. Credit comes from:

• Free monthly credit. Each site whose domain you have verified receives free credit every calendar month (currently $10), once per domain. It is available from the first conversation of the month and expires at the end of it.
• Plan credit. Concierge plans (such as Lite, Pro and Scale) and some paid tiers include credit each billing period. It does not roll over into the next period.
• Added funds. One-off payments you make for a site, from $10 to $1,000 each. Added funds do not expire while your account and the site remain on the Service.

Free and plan credit is used before added funds. Credit has no cash value and cannot be transferred between sites or accounts. When a site's credit runs out, its Concierge stops answering until more credit is available — we do not extend credit or a grace period. A site that runs on your own AI key (below) keeps answering, and only the features credit pays for stop. If a payment that added credit is refunded or disputed, we remove that credit, and a site's balance can then fall below zero; a negative balance is taken from the next credit the site receives.

Automatic top-up. Automatic top-up is off unless you turn it on for a site. When it is on, you authorise us to charge your saved card, without asking you each time, whenever that site's balance falls below the amount you set. Each charge is the top-up amount you chose or, if the balance is further below your threshold, one charge that brings it back to your threshold plus that amount. Automatic top-ups never exceed the monthly limit you set. You can change the amounts, the limit, or turn automatic top-up off at any time in the dashboard; turning it off stops all future automatic charges. If a charge fails, automatic top-up stops until you add funds yourself, and we tell you by email. Your card details are held by our payment processor, Stripe, not by us.

Refunds of credit. Added funds and automatic top-ups are non-refundable, including any unused balance when you cancel, remove a site, or close your account — except for billing errors and your statutory rights, as described below. Where Wix or Shopify bills you, Concierge credit bought through them follows their billing, refund, and dispute rules as well as these Terms.

Changes to usage rates. We may change how much credit Concierge activity uses on at least 30 days' notice. The change applies to activity after it takes effect; credit you have already bought keeps its dollar value.

Your own AI key. You may connect an API key for your own account with a supported AI provider (currently Anthropic, OpenAI, xAI and Google), choose the model it runs on from those we support, and choose which of your sites run on it. For those sites, the Concierge's replies are processed by that provider under your account with them: the provider bills you directly, its terms and usage policies apply to you, and you are responsible for those charges and for keeping that account in good standing. Replies on your key do not use credit; credit still pays for features that run on our own providers, such as image generation and virtual try-on. The daily cap you set counts our estimate of what your sites' replies cost on your key; the provider's own bill is what you owe them. If the provider refuses your key or your account with them runs out of credit, the Concierge on those sites stops answering until the key works again or you switch those sites back to credit — we do not switch them for you. We store your key encrypted, show only its last four characters, and use it only to run the Concierge on the sites you choose; you can replace or remove it at any time, and should also revoke it with the provider if you believe it has been exposed. We are not responsible for the provider's service, availability or charges.

Starting immediately and the 14-day cancellation right. Paid subscriptions begin as soon as your first payment is taken. If you are a consumer, you would ordinarily have 14 days to cancel a distance contract for a refund under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013. By subscribing, you expressly ask us to start the Service straight away and acknowledge that, once it has started, you lose that 14-day right to cancel for a refund. We confirm this in your subscription confirmation email. The same applies to Concierge credit: when you add funds, or an automatic top-up is charged, you ask us to make that credit available straight away. This does not affect your other statutory rights, described below.

Refunds. Paid subscriptions are non-refundable. Except where the law requires otherwise, we do not give refunds or credits for partial billing periods, unused time, downgrades, or because you changed your mind or stopped using the Service.

• Cancel anytime. Cancelling stops the next renewal; you keep access until the end of the period you have already paid for, and we do not refund the remainder of it.
• Billing errors. If you were charged in error — for example a duplicate or clearly accidental charge — contact us and we will refund it.
• Your statutory rights. Nothing in this policy limits rights you cannot waive under applicable consumer law, including the UK Consumer Rights Act 2015. If the Service is faulty, materially not as described, or not provided, you may be entitled to a remedy regardless of the above.
• Goodwill. Any refund we give outside these cases is at our sole discretion and creates no obligation or precedent.
• Chargebacks. Please contact us before disputing a charge with your bank — most issues are quicker to resolve directly. Chargebacks raised without contacting us first, or that we reasonably consider abusive, may lead to suspension or termination of your account. Where Wix or Shopify bills you for the app subscription, their billing, refund, and dispute rules apply in addition to these Terms.

This section covers what you pay for the Flows Service on your Billing Rail. Payments you collect from your own Subscribers or store customers are covered by the Member Commerce & Payments section.

If you choose to sell — through Subscriber subscriptions, product sales, or similar — you do so using the commerce path available for your install. That may be Stripe Connect and/or Store Checkout on a connected Wix or Shopify store (or another supported storefront).

Stripe Connect path

Where you connect a Stripe account through Stripe Connect, payments from your Subscribers may be processed as direct charges on your connected Stripe account. On that path, you are the merchant of record for those charges. You, not Flows, are responsible to your Subscribers and to the authorities for: pricing and product descriptions; VAT, sales tax, and other taxes; fulfilment; refunds, cancellations, and chargebacks; and compliance with consumer-protection, distance-selling, and subscription-disclosure laws. Where you sell recurring subscriptions, you must tell each Subscriber, before the first charge, that charges will recur and how to cancel — as Stripe's terms require. You must accept the applicable Stripe service agreement and comply with it and with Stripe's Restricted Businesses rules. Stripe's own terms and privacy policy apply to your use of Stripe.

Platform Fee (Stripe Connect only). Flows charges an application fee of 2% (or such other percentage as we show in the dashboard at onboarding) on each transaction you process through Stripe Connect. This is collected automatically by Stripe at the time of the transaction and is in addition to Stripe's own processing fees. Refunds reduce the Platform Fee proportionately. We will give notice before increasing the Platform Fee. This Platform Fee does not apply to Store Checkout transactions on Wix or Shopify unless we state otherwise in writing.

Store Checkout path (Wix / Shopify)

Where products or subscriptions are sold through your connected Wix or Shopify store checkout, the store platform hosts payment and typically you (and/or that platform under its terms) are the merchant of record. Flows does not process card numbers for those checkouts, does not hold your store payouts, and does not take the Stripe Connect Platform Fee on those sales. You must comply with the store platform's merchant, acceptable-use, and tax rules, and you remain responsible for fulfilment, refunds, and consumer-law compliance for what you sell.

Flows is a platform provider only. We are not party to the contract between you and your Subscribers or store customers, and we are not responsible for your tax position, disputes, or fulfilment. Some jurisdictions restrict platform application fees; where that applies, Stripe Connect monetisation features may be limited or unavailable.

The Service itself — including the Flows platform, software, source code, models, pipelines, templates, designs, the "Flows" and "FlowCrews" names and logos, and all related intellectual-property rights — belongs to Flows or its licensors. These Terms grant you a limited, non-exclusive, non-transferable, revocable right to use the Service for your internal business purposes for as long as your account is in good standing. Nothing in these Terms transfers any ownership of the Service to you.

You must not copy, modify, distribute, sell, sub-licence, reverse-engineer, or create derivative works of the Service or any part of it, except to the extent that restriction is prohibited by law, and you must not use the Service or its AI Output to build or train a competing product or model.

Ownership of Inputs and AI Output is addressed in the AI-Generated Content section. Feedback you send us about the Service may be used by us without restriction or obligation to you.

You retain ownership of your Content (subject to the limits on AI Output described in the AI-Generated Content section). To operate the Service, you grant Flows a worldwide, non-exclusive, royalty-free licence to host, store, reproduce, process, adapt, transmit, and display your Content, and to share it with the subprocessors listed in our Privacy Policy, strictly for the purpose of providing, securing, and improving the Service for you. This licence ends when you delete the relevant Content or close your account, except for: (a) copies retained in routine backups for a limited period; (b) records we must keep by law (such as financial records); and (c) aggregated or anonymised data that can no longer identify you.

We do not sell your Content and we do not use it for our own marketing. We do not train foundation models on your Content. We use AI providers under terms that, for the products we enable, are not intended for provider training on your Content; see the Privacy Policy for current providers. You are responsible for ensuring you have all rights necessary to grant this licence and to publish your Content.

Our handling of personal data is described in the Privacy Policy, which forms part of these Terms. In short: for data about Members we act as a data controller; for personal data of your Subscribers that we process to provide the Service, we generally act as your processor, and in some features (such as the Concierge, newsletters, and image features) we may act as a joint controller with you.

Where we act as your processor, our Data Processing Agreement governs that processing, including the Standard Contractual Clauses and UK Addendum for international transfers. You are responsible, as controller of your Subscribers' data, for having a lawful basis to collect it, for your own privacy notices and cookie consent on your site, and for honouring your Subscribers' rights and consent choices — including before you direct any automated messaging (such as restock or waitlist emails) at them.

You may stop using the Service and delete your account at any time from the dashboard. We may suspend or terminate your access — in whole or in part, and with notice where reasonably practicable — if: you materially breach these Terms or the Acceptable Use Policy; you fail to pay; a connected platform (such as Wix, Shopify, Clerk, or Stripe) suspends or removes the integration; we are required to by law or a regulator; or there is a security risk or risk of harm.

On termination, your right to use the Service ends and we may delete your Content and switch off your Concierge. We delete or anonymise personal data in line with the retention periods in the Privacy Policy — generally within 90 days, except for financial and audit records we are required to keep for longer. Where you have active Subscriber subscriptions, we will, where practicable, allow them to run to the end of their current paid period; you remain the merchant of record for them and are responsible for handling them on wind-down.

Sections that by their nature should survive termination — including the Intellectual Property, Disclaimers, Limitation of Liability, Indemnification, and Governing Law sections — continue to apply after termination.

The Service is provided "as is" and "as available". To the fullest extent permitted by law, we exclude all implied warranties, conditions, and terms — including any implied terms of satisfactory quality, fitness for a particular purpose, and non-infringement.

We do not warrant that the Service will be uninterrupted, error-free, or secure, that defects will be corrected, or that AI Output will be accurate, complete, original, non-infringing, or fit for your purpose. We do not warrant any traffic, revenue, or other commercial result. The Service depends on third-party providers (including Wix, Shopify, Clerk, Stripe, our AI providers, and our hosting and email providers), and we are not responsible for their acts, omissions, or outages.

Nothing in these Terms excludes or limits any liability that cannot be excluded or limited by law, including liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

Subject to the Disclaimers section and to the extent permitted by law:

• We are not liable for any indirect, special, incidental, consequential, or punitive loss, or for loss of profits, revenue, goodwill, data, or anticipated savings, however arising.
• Our total aggregate liability arising out of or in connection with these Terms and the Service, whether in contract, tort (including negligence), or otherwise, is limited to the greater of (a) the total fees you paid us for the Service in the 12 months before the event giving rise to the claim, and (b) £100.

Because you are the merchant of record and the editorial controller, we are not liable for claims arising from your Content, your products, your dealings with your Subscribers, your tax or consumer-law compliance, or AI Output you publish, customise, or distribute. These limits do not apply to liability that cannot be limited by law, as described in the Disclaimers section, nor to your obligations under the Indemnification section.

You agree to indemnify and hold harmless Flows and its officers, employees, and contractors against all claims, damages, losses, liabilities, and reasonable costs (including legal fees) arising out of or in connection with:

• your Content, including any chat reply, image, or other AI Output you publish, customise, or distribute, and any claim that it is unlawful, infringing, defamatory, or misleading;
• your use of Concierge instructions or other configuration that influences AI Output;
• your products, services, and dealings with your Subscribers, including refunds, chargebacks, taxes, and consumer-law obligations as merchant of record;
• your breach of these Terms, the Acceptable Use Policy, a connected platform's terms, or applicable law (including data-protection and marketing law); and
• your collection or use of any third party's personal data or biometric data without a lawful basis or required consent.

We will notify you of any claim to which this section applies, let you control the defence (provided any settlement that affects us has our consent, not to be unreasonably withheld), and reasonably cooperate at your expense.

We are not liable for any failure or delay in performing our obligations caused by events beyond our reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, epidemics, strikes, failures of utilities or the internet, outages or changes by third-party providers (including Wix, Shopify, Clerk, Stripe, and our AI, hosting, and email providers), and acts of government or regulators. While such an event continues, our affected obligations are suspended; if it continues for an extended period, either party may terminate the affected part of the Service on notice.

These Terms and any dispute arising out of or in connection with them (including non-contractual disputes) are governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction. Where you use the Service as a consumer under mandatory local law, that does not deprive you of the protection of provisions that cannot be derogated from by agreement under the law of your country of residence.

Before starting court proceedings, we both agree to try in good faith to resolve any dispute informally — first by raising it in writing to hi@flowcrews.com and allowing 30 days for discussion, and then, if unresolved, by considering mediation. This does not prevent either party from seeking urgent injunctive relief.

We may update these Terms from time to time. The current version and effective date appear at the top of this page. For material changes we will give reasonable notice — for example by email and by posting the updated Terms — and the change takes effect on the date stated in that notice. If you do not agree to a material change, you may stop using the Service and close your account before it takes effect; continued use after that date constitutes acceptance where permitted by law.

These Terms, together with the Privacy Policy, Acceptable Use Policy, and Data Processing Agreement (where it applies), are the entire agreement between us about the Service. If any provision is found unenforceable, the rest remain in effect. Our failure to enforce a provision is not a waiver. You may not assign these Terms without our consent; we may assign them to an affiliate or in connection with a merger, acquisition, or sale of assets. There are no third-party beneficiaries except where expressly stated.

Questions or legal notices:

• Email: hi@flowcrews.com
• Post: a postal address is available on request via email
• Operated by: Flows (a sole trader), England and Wales

This Privacy Policy explains how Flows ("Flows", "we", "us", "our") collects, uses, shares, and protects personal data when you use our services, websites, and applications (together, the "Service").

The data controller is Flows, a sole-trader business based in England and Wales. You can reach us at hi@flowcrews.com for any question about this Policy or about your personal data, and a postal address is available on request.

Two relationships exist under this Policy and we distinguish them throughout:

• Members — operators who hold a Flows account and use the Service to generate content, connect a site or store, and run the Concierge. Members may sign up on the web (via our identity provider, Clerk) or through a connected marketplace (including the Wix App Market and the Shopify App Store). For data about Members we are the data controller.
• Subscribers — visitors and customers of a Member's site who chat with the Member's Concierge. For data about Subscribers that the Member has collected through their connected platform (for example Wix or Shopify), we generally act as a processor on the Member's behalf. For data Subscribers create directly through Concierge chat, image upload, or newsletter sign-up, we may act as a joint controller with the Member. Where we do, you can contact either us or the Member about your rights; we will cooperate with the Member to handle requests, and you may always write to hi@flowcrews.com as a contact point for our part of the processing.

We are established in the United Kingdom and may offer the Service to people in the European Economic Area. At our current scale our processing of EEA personal data is occasional and limited, so we rely on the exemption in Article 27(2) of the EU GDPR and have not appointed an EU Representative. We keep this under review and will appoint one if our EEA processing becomes regular or large-scale.

You can contact us directly at hi@flowcrews.com regarding any matter concerning our processing of your personal data, and you may lodge a complaint with a supervisory authority.

We collect the following categories of personal data:

From Members

• Identity and account data — your name, email address, business name, and identifiers for the connected sites or stores you operate (for example site URL, shop domain, Wix instance id, or Shopify shop id). Depending on how you join Flows, this comes from our identity provider Clerk when you register or sign in on the web (including email/password and social sign-in with Google or X, where enabled); from the Wix App Market or Shopify Admin when you install the embedded app; and from the email address and profile you maintain in the dashboard.
• Authentication tokens — session and identity tokens issued or verified via Clerk (and, where you use an embedded app, session material from Wix or Shopify); OAuth and refresh tokens for the sites and accounts you connect (such as Wix or Shopify Admin/API access); HMAC-signed Flows dashboard API tokens; and JWTs for Subscriber and API calls. Stored encrypted where applicable and used only to operate the Service for you.
• AI provider keys — API keys you connect so your sites' Concierge runs on your own AI provider account. Stored only in encrypted form (encrypted with Amazon Web Services Key Management Service), shown only by their last four characters, and used only to run the Concierge on the sites you choose. We also keep a record of when keys were added, replaced or removed and which sites were switched onto them.
• Business details — the details you give us so the Concierge can speak for your site, such as your site's name and your business's name. We use these to run the Concierge, not for our own marketing.
• Configuration and content data — Concierge setup choices and instructions, brand and typography settings, uploaded fonts, the chat designs you save, the data tables you add, and the products and product copy you sync from a connected store (Wix, Shopify, WordPress, or another supported platform).
• Usage, billing, and analytics data — features used, Concierge history, and an AI usage log (such as request counts, tokens consumed, and cost) we keep to enforce tier limits and bill accurately. Collected to operate, meter, debug, and improve the Service.
• Payment metadata — your subscription status and tier; identifiers from the billing rail you use (for example Stripe customer id and Connected Account id on the Stripe rail, Shopify app subscription ids on the Shopify rail, or Wix App Billing plan/instance ids on the Wix rail). Card and payment-instrument details are handled by the payment platform (Stripe, Shopify, or Wix) — we never see or store full card numbers.
• Technical data — IP address, user agent, Vercel edge request logs, time zone, browser language.

Your customers' data we process for you

When you enable commerce features, we process personal data about your Subscribers and customers on your behalf, as your processor — for example customer name, email, phone, and shipping address on orders, subscription and order records, and abandoned-cart and lifetime-value analytics we generate to help you understand your sales. You are the controller of this data; see Lawful Basis and the Subscriber categories below.

From Subscribers

• Identity — your email address (used as the login identifier), and commerce identifiers where you have purchased on a Member's site (for example a Stripe customer id on the Stripe rail, or a Shopify customer/subscription id where that rail applies).
• Concierge data — messages you send to the Concierge chat, your text selections sent for explanation, optional reactions and feedback.
• Image data — photos you upload to the Concierge (for example for a virtual try-on or to ask a question about an image). Image data is special-category biometric data in some circumstances — see the Biometric Information section below.
• One-time-password (OTP) data — a short-lived hashed code we send to your email to verify your identity, retained for at most 10 minutes.
• Technical data — IP address (stored only in hashed, one-way form: for audit, and to return an unsigned-in Concierge conversation only to the connection that started it), user agent, country and region inferred from your IP by our hosting provider (used to apply jurisdiction-specific protections such as Illinois BIPA).
• Payment metadata — only if you have bought a paid Subscriber product on a Member's site. Card details are handled by the checkout platform the Member uses (for example Stripe Connect or Shopify) — we do not store full card numbers.

We process personal data on the following lawful bases under UK GDPR Article 6 (and Article 9 where special-category data is involved):

• Performance of a contract (Art 6(1)(b)) — to operate the Service for Members under our Terms of Service, and to deliver Subscriber-facing features (sign-in, Concierge replies, paid subscriptions) under the contract created when a Subscriber signs in to a Member's site.
• Legitimate interests (Art 6(1)(f)) — for service security, fraud prevention, abuse detection, aggregate analytics to improve the Service, and transactional communications with Members. We have weighed our interests against your rights and consider them not to override them; you can object at any time.
• Consent (Art 6(1)(a) and, where we collect it for biometric image features, Art 9(2)(a)) — for biometric processing of images you upload to the Concierge where our product requires consent (see Biometric Information), for optional newsletter sign-up, and for any non-essential cookies. You can withdraw consent at any time without affecting the lawfulness of earlier processing.
• Contract / legitimate interests for image features outside consent gates — where image features are offered without a biometric consent gate (for example outside Illinois BIPA regions we currently gate), we process the image you voluntarily attach to deliver that feature for you, not to identify you against a database.
• Legal obligation (Art 6(1)(c)) — to retain financial records under HMRC and EU OSS rules, to respond to lawful access requests, and to keep an erasure audit log under Art 5(2) accountability.

We use the data we collect to:

• Run the Concierge — answer Subscriber questions, search your site's pages, products, and the data tables you open to it, and provide image features where enabled.
• Show order history — when a Subscriber signs in to the Concierge, display their own orders from the connected store, looked up by their verified email, together with delivery tracking, so they can check status without leaving the page. We retrieve this from the store only to show it back to that same Subscriber.
• Sync your catalogue — keep the products from a connected store up to date for the Concierge.
• Operate billing — pass payment information to the billing or checkout rail in use (Stripe Connect, Shopify Checkout, Wix eCommerce, or Member SaaS billing rails as applicable), record subscription status, and produce commerce analytics for you (such as revenue, order, abandoned-cart, and lifetime-value insights).
• Send notifications on your behalf — where you enable it, automatically email your Subscribers when a product they asked about becomes available (restock / waitlist notifications). You are responsible for holding a lawful basis to contact those Subscribers.
• Authenticate Members and Subscribers — issue and verify short-lived tokens, send sign-in codes, prevent session hijacking.
• Improve the Service — debug, monitor performance, investigate errors, measure aggregate usage. We do not train AI models on your content.
• Comply with law — respond to lawful requests, retain financial records, maintain an audit trail of erasure events.
• Send essential service messages — sign-in codes, account-change confirmations, deletion confirmations, security notices.

We never sell personal data, and we do not "share" personal data for cross-context behavioural advertising under CCPA/CPRA. We do not train any AI foundation model on Member or Subscriber content.

The Concierge offers features that may process an image you voluntarily upload — for example a virtual try-on of a product, or a question about an image. When we run these features the image is sent to xAI's Grok image model, which extracts visual features (which may include facial geometry) to produce the requested overlay or answer.

We do not use this data to identify you, we do not match it against any database, we do not sell, lease, trade, or otherwise profit from it, and we never use it to train any AI model. An image you attach only to ask a one-off question is discarded once your result is returned. A photo you save for reuse in virtual try-on (your “Your photos” gallery in Settings) is kept securely so you don’t have to upload it again — you can view or delete it anytime in Settings, and it is destroyed when you delete it or close your account (biometric media is not held for the general post-deletion residual period described for other account data).

If you are in Illinois (BIPA)

The Illinois Biometric Information Privacy Act (740 ILCS 14, "BIPA") treats scans of face or hand geometry as biometric identifiers regardless of whether they are used for identification. Under Section 15:

• Written release. Before we process any image you upload through a biometric feature, we will ask for your written consent through a clear in-product prompt. If you decline, you can still use the Concierge for text-only conversations — image features are disabled.
• Retention and destruction policy. We retain biometric identifiers only as long as needed for the purpose you provided them. An image you attach for a one-off request is sent to the AI model that runs that site’s chat (xAI, or on a site that runs on its owner’s own AI key, that key’s provider: Anthropic, OpenAI, xAI or Google), the response is returned, and the image is discarded within seconds. Photos you save for reuse in virtual try-on (your “Your photos” list, up to three at a time), and any try-on result images you save to your Gallery, are kept until you delete them or close your account. In every case we permanently destroy all biometric identifiers when the purpose has been satisfied or within three years of your last interaction with the Service, whichever occurs first.
• No sale, lease, trade, or profit. We will not sell, lease, trade, or otherwise profit from your biometric identifiers.
• Limited disclosure. We will not disclose your biometric identifiers to any third party other than the model processor described above (xAI, or the provider of the site owner’s own AI key) unless you consent or a court order compels us, in accordance with Section 15(d).
• Security. We protect biometric identifiers using the reasonable standard of care within our industry and in the same manner we protect other confidential and sensitive information.
• Withdrawal. Where consent was required and granted, you can withdraw it from the Concierge Settings panel (Privacy → Withdraw consent) when that control is shown for your region, or by emailing hi@flowcrews.com. Withdrawing consent disables image features going forward; it does not affect the lawfulness of processing before withdrawal.

If you are in another regulated jurisdiction

Texas (CUBI), Washington (HB 1493 / MHMDA), and Colorado (HB 24-1130) impose comparable rules for biometric data. We are extending the same consent-first product gates to those jurisdictions as our geo-gating supports them; until a region is gated in-product, image features may still be available with the general disclosures in this Policy. Outside consent-gated US regions, we process images you voluntarily attach solely to deliver the feature you requested (for example a try-on or an answer about the image), not to identify you against a database. Where UK/EU special-category rules apply to a particular use, we will obtain the consent or other lawful basis the product requires before that use.

We use trusted third-party service providers ("subprocessors") to deliver the Service. Each processes personal data only as needed for the roles below and under written contractual terms that protect that data. Depending on how you join Flows — web account, Wix App Market, or Shopify App Store — identity and billing may involve Clerk, Wix, and/or Shopify as described in the table.

The table above is our current, dated subprocessor list for the Service (see version and last-updated date at the top of this Policy). The same list is the reference for the Data Processing Agreement subprocessor clause. We commit to notifying Members at least 30 days before adding or replacing a material subprocessor, giving Members the right to object and terminate for that change where required by our DPA or applicable law.

Where a Member sells to their own customers through Stripe Connect, Shopify Checkout, or Wix eCommerce, the Member is typically the merchant of record for those customer payments. Flows still processes related order and subscription metadata as described in Data We Collect.

Many of our subprocessors are based in the United States or process data there. We rely on the following transfer mechanisms, in this order of preference:

• EU-US Data Privacy Framework (and UK Extension / Swiss-US DPF) for providers that are self-certified under the Framework — for example Vercel, Stripe, Cloudflare, Google, and Anthropic, and other listed providers to the extent they maintain an active certification. Members and Subscribers can verify any provider's current status at dataprivacyframework.gov. We keep certifications under review when we engage or change a US provider (including Clerk, Shopify, and platform partners such as Wix).
• Standard Contractual Clauses (EU Commission Implementing Decision 2021/914) plus the UK International Data Transfer Addendum (ICO IDTA v.B.1.0) for providers or processing legs not covered by an active adequacy decision or DPF certification — including, where applicable, xAI and other US AI or infrastructure providers for the US leg. For Swiss data subjects the SCCs apply with the FDPIC interpretive amendments.

You can request a copy of the safeguards in place for any specific transfer by writing to hi@flowcrews.com.

We hold data only as long as we need it:

We use a minimal set of strictly-necessary cookies and tokens to deliver the Service. We do not use advertising cookies and we do not embed third-party trackers.

When the Concierge is embedded on a Member's site, the host site's cookie banner and consent tools take precedence for that site. We design the widget to avoid non-essential advertising cookies of our own.

We self-host the fonts used in the Concierge widget where practicable. The marketing site and dashboard may load fonts from Google Fonts; that is a separate browser request governed by Google's terms.

Under UK GDPR (and EU GDPR) you have the right to:

• Access the personal data we hold about you (Art 15).
• Rectify inaccurate or incomplete data (Art 16).
• Erase your personal data, subject to limited exceptions for retained financial records (Art 17).
• Restrict processing in certain circumstances (Art 18).
• Portability — receive your data in a structured, machine-readable format (Art 20).
• Object to processing based on legitimate interests (Art 21).
• Withdraw consent at any time, where processing is based on consent (Art 7).
• Complain to your supervisory authority. In the UK that is the Information Commissioner's Office at ico.org.uk/make-a-complaint. In the EU it is your national data-protection authority.
• Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Art 22) — see the Automated Decision-Making section below.

Some rights apply with extra strength in particular jurisdictions — for example California (CCPA/CPRA) rights to know, delete, correct, limit use of sensitive PI, and opt-out of sale/sharing. We treat all such requests as if you had those rights, regardless of where you live.

The fastest routes:

• Subscribers — open the Concierge, open Settings (the cog), then Profile for account controls such as Delete Account and photo management. Where biometric consent was required for your region, Privacy controls include withdraw consent. For a full data export, email hi@flowcrews.com from the address on your Subscriber account (we will verify identity before releasing data).
• Members — open your profile / account menu in the Flows dashboard for Export My Data or Delete Account.
• Any other request — email hi@flowcrews.com with a description of the right you want to exercise.

We respond within one month of receiving a verified request, extendable by up to two further months for complex or numerous requests; we will tell you within that first month if an extension is necessary. We may ask for proof of identity before acting on a request that arrives via email, to make sure we are sending personal data to the right person. The first request is free; we may charge a reasonable fee for requests that are manifestly unfounded, excessive, or repetitive.

The Service is intended for business use and is not directed to children. Member accounts are for people aged 18 or over (or the age of majority in their jurisdiction). We do not knowingly collect personal data from anyone under 18 for a Member account. If a Member operates a site whose audience may include minors, the Member is responsible for age-verification and parental-consent requirements under applicable law.

If you believe we have collected personal data from a person under 18, please contact hi@flowcrews.com and we will delete it within 30 days.

The Service uses AI to generate text and images, to respond in the Concierge, and to surface product recommendations. These are not fully automated decisions that produce legal or similarly significant effects on you — Concierge responses are informational rather than determinative.

In line with the EU AI Act (Reg 2024/1689):

• The Concierge identifies itself as AI on first interaction. (Art 50(1).)
• Generated images may carry provenance metadata only where the model provider attaches it; we do not currently guarantee C2PA or similar marking on every image. (Art 50(2) where applicable.)

If we use automated checks to flag suspected fraud, abuse, or policy breach against your Member or Subscriber account, you have the right to request human review of that decision by emailing hi@flowcrews.com.

When you connect your Flows account to an AI app such as ChatGPT, the app sends us the requests you make through it (for example “change my chat’s greeting” or “add a delivery FAQ table”) and we return the result to that app. We receive only what the AI app sends with each request and your Flows account identity from sign-in. We do not receive your other conversations. The AI app’s own handling of your conversations is covered by its provider’s privacy policy.

We use technical and organisational measures appropriate to the risk, including:

• Encryption in transit (TLS 1.2+) and at rest for databases and object storage.
• Clerk-managed Member sessions; HMAC-signed dashboard API tokens after IdP exchange; short-lived JWT subscriber tokens; OTP codes hashed with SHA-256.
• Postgres Row-Level Security for per-tenant data isolation; principle-of-least-privilege role grants.
• Secrets stored in Vercel encrypted environment variables, never in source control; rotation on suspected compromise.
• Hashed (not raw) IP storage for audit fields.
• Multi-region backup of the primary database; point-in-time recovery up to 7 days.
• Vulnerability monitoring on third-party dependencies and periodic dependency upgrades.

If we become aware of a personal-data breach likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours per Article 33, and we will notify you without undue delay where the breach is likely to result in a high risk per Article 34.

We may update this Policy from time to time. The current version and effective date appear at the top of this page. Material changes — for example a new processor, a new processing purpose, or a change to retention — will be posted here and, for Members, we will give reasonable notice (for example by email) where practicable. Continued use of the Service after the effective date of a change constitutes acceptance where permitted by law; where a change requires fresh consent, we will ask for it before that processing continues.

Older versions of this Policy remain available on request. Where a change requires fresh consent, prior consent collected under an earlier version remains valid only for the activities permitted under that earlier version.

For any question about this Privacy Policy or your personal data:

• Email: hi@flowcrews.com
• Post: a postal address is available on request via email

You also have the right to complain to a supervisory authority. In the UK that is the Information Commissioner's Office. In the EEA you can complain to your national data-protection authority. We would, however, appreciate the chance to address your concern first.

This Acceptable Use Policy (the "AUP") forms part of, and is incorporated by reference into, the Terms of Service. It sets out what you may not do with the Service. Capitalised terms have the meaning given in the Terms.

This AUP applies to your use of the Service, to everything you generate, publish, store, or transmit through it, and to how you configure and direct its AI features — including the Concierge's instructions. You are also responsible for ensuring your Subscribers' use of features you enable (such as the Concierge) does not breach this AUP, to the extent you can reasonably control it.

Our payment and AI providers impose their own acceptable-use rules — including Stripe's Restricted Businesses list and the usage policies of our AI providers — and those apply to you in addition to this AUP. Where they are stricter, the stricter rule governs.

You must not use the Service to create, publish, store, transmit, promote, or facilitate:

• anything illegal under any law that applies to you or your audience;
• child sexual abuse material (we operate a zero-tolerance rule and report it to the relevant authorities), or any sexual content involving minors;
• adult or pornographic content, where prohibited by a connected platform or payment provider;
• hate speech, harassment, bullying, or content that incites or threatens violence;
• terrorist content, or content that promotes or facilitates terrorism or violent extremism;
• weapons, explosives, or controlled or dangerous substances outside the bounds of applicable licensing;
• regulated financial services, lending, debt-relief, gambling, or lotteries without the authorisation the law requires;
• misleading, deceptive, or fraudulent content — including fake reviews, fake testimonials, undisclosed paid endorsements, deepfakes, and AI-driven impersonation of a real person or organisation;
• defamatory or knowingly false statements about a person or business;
• content that infringes another person's intellectual property, privacy, publicity, or other rights, including prompts that target a specific copyrighted work in order to reproduce it;
• health, legal, financial, or other professional advice presented without the review or disclaimers that applicable law requires;
• malware, or content designed to disrupt, damage, or gain unauthorised access to any system or data.

Where you sell products through the Service or a connected payment or store rail — including Stripe Connect, Shopify Checkout, or Wix eCommerce — you must comply with the restricted, prohibited, and acceptable-use rules of that rail, including Stripe's Restricted Businesses list where Stripe is used, and the corresponding merchant and partner policies of Shopify or Wix where those platforms host checkout or billing. Categories that are commonly prohibited or restricted include (without limitation) adult content, gambling, debt relief, certain financial and legal services, marijuana and CBD, pharmaceuticals and nutraceuticals, non-fiat currency, and unfair, deceptive, or abusive practices.

You are responsible for confirming that your business and products are permitted before you transact, and for any change in your business that brings it within a restricted category.

When using the Service's AI features, you must not:

• attempt to prompt-inject, jailbreak, or otherwise circumvent the safety, content, or rate controls of the Service or its AI providers;
• use the Service or its AI Output to develop or train a competing AI model or product;
• reverse-engineer, scrape, or systematically extract the Service, its models, or its outputs;
• present AI Output as human-authored where a law (such as the EU AI Act) or a platform requires it to be disclosed as AI-generated, or remove provenance metadata from generated images.

Outputs generated in response to your Concierge instructions are your responsibility, and you indemnify us for them under the Terms.

If you use any messaging feature of the Service — including automatic restock or waitlist notifications to your Subscribers — you are responsible for holding a lawful basis to contact each recipient and for complying with marketing and anti-spam law, including UK PECR, the EU ePrivacy rules, and the US CAN-SPAM Act. You must not:

• send unsolicited marketing to people who have not consented or for whom no soft opt-in applies;
• direct an automated agent to spam, harass, deceive, or impersonate;
• send commercial email without a functioning unsubscribe mechanism and a valid postal address;
• build or use a contact database from personal data obtained via a connected platform's APIs or Admin/Storefront access for your own marketing lists or to sell to others (platform developer and data-use rules also apply).

We may suspend any automated messaging feature where we reasonably believe it is being used in breach of this section.

You must not use the Service to:

• scrape or harvest personal data, or collect personal data without a lawful basis and the notices the law requires;
• upload or process another person's photograph, face, or other biometric data without that person's informed consent;
• process special-category or sensitive personal data in a way that breaches data-protection law or the Privacy Policy;
• misuse data accessed through a connected platform's APIs for any purpose other than operating your own site through the Service.

As controller of your Subscribers' personal data, you are responsible for your own privacy notice, your cookie consent, and honouring your Subscribers' rights and consent choices.

You must not:

• probe, scan, or test the vulnerability of the Service, or breach or circumvent any security or authentication measure, except under a written authorisation from us;
• access, tamper with, or use another Member's or Subscriber's account, data, or content without authorisation;
• interfere with or disrupt the Service, its infrastructure, or other users — including through denial-of-service, excessive automated requests, or circumvention of rate limits or tier allowances;
• introduce malware or use the Service to deliver it.

If you discover a security vulnerability, please report it responsibly to hi@flowcrews.com and give us a reasonable opportunity to address it before disclosure.

If we reasonably believe this AUP has been breached, we may — depending on the severity and with notice where practicable — remove or disable Content, disable or suspend a feature or automated agent, suspend or close the account, disable commerce features, cooperate with a connected platform's billing or account holds, withhold or reverse payouts where Stripe Connect rules allow, and report the matter to the relevant authorities. For serious or repeated breaches, or where required by law or a connected platform, we may act without prior notice.

We do not routinely monitor Content, and we are not responsible for it — you remain responsible as publisher and editorial controller. To report a breach of this AUP, contact hi@flowcrews.com.

This Data Processing Agreement (the "DPA") forms part of the Terms of Service between Flows, a sole-trader business based in England and Wales ("Flows", the processor) and the Member (the "Controller") and applies where Flows processes personal data on the Controller's behalf in providing the Service.

In this DPA, "personal data", "processing", "controller", "processor", "data subject", and "supervisory authority" have the meanings given in the UK GDPR and the EU GDPR (together, "Data Protection Law"). Where Flows determines the purposes and means of processing — for example Member account identity (including via Clerk), security, and Service improvement — it acts as a controller in its own right, as described in the Privacy Policy, and that processing is outside this DPA. This DPA does not apply to Member account data for which Flows is controller.

For features where Flows and the Member may act as joint controllers (for example certain Concierge chat, image upload, or newsletter flows described in the Privacy Policy), the parties will cooperate as set out there. A separate Article 26 arrangement may apply to those features; this DPA continues to govern pure processor processing of Controller personal data.

Flows will:

• process personal data only on the Controller's documented instructions (including those given through the Service and the Terms), unless required to do otherwise by law, in which case it will inform the Controller unless the law forbids it;
• ensure that people authorised to process the data are bound by an appropriate duty of confidentiality;
• implement the technical and organisational security measures described in the Security section of the Privacy Policy, appropriate to the risk under Article 32;
• respect the conditions on engaging subprocessors set out below;
• taking account of the nature of the processing, assist the Controller by appropriate measures to respond to data subjects exercising their rights;
• assist the Controller in complying with its obligations under Articles 32–36 (security, breach notification, and data protection impact assessments), taking account of the information available to Flows;
• at the Controller's choice, delete or return the personal data at the end of the provision of the Service, as described in the Termination section; and
• make available the information necessary to demonstrate compliance with Article 28 and allow for audits as described below.

The Controller gives Flows general authorisation to engage subprocessors to the extent they process Controller personal data under this DPA, as listed in the Third-Party Processors table of the Privacy Policy (as updated from time to time). Providers used solely for Flows' own Member-controller activities (for example Member web identity via Clerk) are not subprocessors of the Controller under this DPA. Flows imposes data-protection obligations on each authorised subprocessor that are no less protective than those in this DPA, and remains liable to the Controller for a subprocessor's performance.

Flows will give the Controller at least 30 days' notice before adding or replacing a subprocessor. The Controller may object on reasonable data-protection grounds within that period; if the parties cannot resolve the objection, the Controller may terminate the affected part of the Service.

Where processing involves a transfer of personal data outside the UK or EEA, the parties incorporate the appropriate transfer mechanism by reference: the EU Standard Contractual Clauses (Commission Implementing Decision 2021/914) — Module Two where the Controller is controller and Flows is processor, and Module Three where Flows and a subprocessor are processors of the Controller; the ICO International Data Transfer Addendum (Version B.1.0) for UK transfers; and the EU SCCs with FDPIC amendments for Swiss transfers. Where the data importer is self-certified under the EU-US Data Privacy Framework (and its UK Extension / Swiss-US DPF) and the transfer is within that certification, the certification is the primary mechanism and the SCCs apply as a fallback.

Further detail on the transfer mechanism for each subprocessor is in the International Data Transfers section of the Privacy Policy.

If Flows receives a request from a data subject relating to the Controller's personal data, it will, unless legally required to respond, refer the request to the Controller and assist the Controller in responding. Several rights can be exercised directly in-product, as described in the Privacy Policy.

Flows will notify the Controller without undue delay after becoming aware of a personal-data breach affecting the Controller's data, with the information the Controller reasonably needs to meet its own notification obligations under Articles 33 and 34. Flows' own regulator notification obligations are described in the Privacy Policy.

Flows will make available to the Controller, on request, information reasonably necessary to demonstrate compliance with this DPA — including, where available, current security certifications or third-party audit reports (such as SOC 2 or ISO 27001), which the parties agree may satisfy an audit request.

Where such reports are insufficient, the Controller may conduct or mandate an audit no more than once per year, on at least 60 days' notice, during business hours, under confidentiality, at the Controller's cost, and without accessing any other customer's data or compromising the security of the Service.

On the end of the provision of the Service, Flows will, at the Controller's choice, delete or return the Controller's personal data and delete existing copies, unless Data Protection Law (or another law that applies to Flows) requires it to keep the data. Where data is retained on that basis — for example financial records required for tax purposes — Flows will continue to protect it and process it only as the retention purpose requires, in line with the retention periods set out in the Privacy Policy.

Each party's liability under this DPA is subject to the limitations and exclusions in the Limitation of Liability section of the Terms. If there is a conflict between this DPA and the rest of the Terms on the subject of personal-data processing, this DPA prevails; where the incorporated Standard Contractual Clauses conflict with this DPA, the Clauses prevail to the extent of the transfer they govern.

A signed counterpart of this DPA is available to Controllers on request at hi@flowcrews.com.

This policy explains every cookie and similar technology set when you visit flowcrews.com and its subdomains, what each one does, and the choice you have over them. It supplements the Privacy Policy, which explains our wider handling of personal data.

We keep the list short on purpose. There is no analytics suite dropping dozens of trackers here: our page analytics are cookieless, and the only non-essential cookies we use exist to measure whether our own advertising works.

These make the Service work — signing in, staying signed in, preventing payment fraud, and remembering your cookie choice itself. They do not require consent and cannot be switched off, because the Service does not function without them.

• Authentication (Clerk) — session cookies (for example __session, __client_uat) that keep you signed in to the dashboard. Set only on the app, not the marketing site. Lifetime: session to 7 days.
• Payments (Stripe) — fraud-prevention cookies (for example __stripe_mid, __stripe_sid) set when a checkout or billing page loads. Lifetime: 30 minutes to 1 year.
• Your cookie choice — fc_consent remembers whether you accepted or rejected advertising cookies, so we do not ask on every page. Lifetime: 6 months, then we ask again.
• Concierge conversation — browser storage (not a cookie) on sites where the Concierge chat is embedded. fl_concierge_session_… holds a random conversation id so your chat carries on from page to page, and fl_concierge_rid_… holds the reference that lets the assistant continue that same conversation. Neither contains personal details. Lifetime: until you start a new chat or clear your browser data; the continuation reference is dropped after 55 minutes.

These are set only after you press Accept on the cookie banner. Reject and none of them are set — the site behaves identically either way.

• Meta Pixel — _fbp and _fbc, set by Meta (Facebook/Instagram) code on our pages. They tell us, in aggregate, whether our ads on Meta platforms bring visitors here and whether those visits lead to sign-ups. Lifetime: 90 days.
• First-touch attribution — fc_attr, our own first-party cookie. It stores the campaign details from the link you arrived on (UTM parameters and click ID) so a later sign-up can be credited to the right ad. It is set once, never overwritten, and never shared beyond the measurement described here. Lifetime: 90 days.

If you accept and later sign up, we also send Meta a server-side "registration" event that includes your email address in hashed (one-way encoded) form, solely so Meta can match the sign-up to the ad click. We never send your raw email address, and none of this happens if you rejected cookies.

For clarity, on our own site we do not use:

• third-party analytics cookies — our page statistics are collected without cookies and without identifying you;
• advertising networks other than Meta;
• cross-site tracking, data brokers, or sale of personal data in any form.

Websites our Members build with the Service may set their own cookies under their own policies — the Member is responsible for those, as described in the Terms of Service.

The banner offers Accept and Reject as equals, and you can change your choice at any time via the Cookies link in the footer of any marketing page — the banner reopens and your new choice applies from the next page you load.

You can also clear or block cookies in your browser settings at any time, including the strictly necessary ones (though signing in will stop working without them). Rejecting or clearing advertising cookies never limits what the Service does.

Questions about this policy or our use of cookies: hi@flowcrews.com. For how we handle personal data more broadly — including your rights of access and erasure — see the Privacy Policy.

We want everyone to be able to use Flows, including people who rely on screen readers, keyboard navigation, captions, or other assistive technologies. Accessibility is something we build toward as the product develops, and we treat barriers as bugs to be fixed.

We aim to meet the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA — the benchmark referenced by UK and EU accessibility law (EN 301 549). In practice that means we work toward semantic structure, keyboard operability, sufficient colour contrast, resizable text, visible focus, and a light and dark theme you can choose between.

Flows is an early-stage service and we have not yet completed a full independent accessibility audit, so some areas may not fully meet WCAG 2.1 AA yet. We are improving this continuously and prioritise fixes for anything that prevents someone from using a core feature.

If you have any difficulty using part of the Service, or you need information in a different format, please email hi@flowcrews.com with a short description and, if you can, the page or feature involved. We will reply as soon as we can, help you get what you need in the meantime, and use your report to fix the underlying issue.

Some parts of the experience are operated by third parties whose accessibility we do not control — for example Clerk (or other IdP) sign-in pages, Wix or Shopify admin and embedded app shells, a Member's own website, embedded storefronts, and checkout or billing pages hosted by Stripe, Shopify, Wix, or another payment platform. Where you hit a barrier on something we don't control, contact us anyway and we will do our best to help you reach an accessible route.