Privacy Policy
1. Who we are and in what capacity we process data
Flowetica Studio SRL ("Flowetica", "we", "us"). Registered office: Strada D. Stoica, Nr. 1, Bl. H2, Sc. 2, Ap. 16, Craiova, Romania. Company registration: CUI 55179338, Nr. ORC J2026043729009. For any data-protection question, contact us at privacy@flowetica.com.
We process personal data in two distinct capacities, and your rights are exercised differently in each case:
As data controller, for data collected through our websites flowetica.com and flowetica.ro: the contact form, the online assessment, the online audit, and traffic analytics. These processing activities are described in sections 2-8.
As data processor, for the customer data of businesses that have contracted our automation services. In this case the controller is that business (for example, a salon or clinic), and we process the data solely on its behalf and according to its instructions, under GDPR Art. 28. These processing activities are described in section 9.
2. What data we collect through the website
Contact form, assessment and audit: your name, email address, phone number, company name, website address, and the information you provide about your business and its operations.
Analytics: if you accept analytics cookies, Google Analytics collects pseudonymous usage data (pages viewed, approximate location, device and browser type).
Website chat: the messages you write, when you sent them, the page you started the conversation from and, if you give it to us, your email address. We don't ask for your address up front; we ask for it only if nobody replies within a few minutes or it is outside business hours, so that we can get back to you. You can have the whole conversation without giving it.
We do not collect special categories of data through the website. The chat is not the place for health data, financial data, or documents; if you need to send us something like that, we will tell you how at that point.
3. Why we use it and legal basis
We process your contact and assessment data to respond to your request, prepare a proposal, and provide our services. Legal basis: your consent and/or steps taken at your request prior to entering a contract (GDPR Art. 6(1)(a) and (b)).
We process chat messages in order to answer what you asked. Legal basis: steps taken at your request prior to entering a contract (GDPR Art. 6(1)(b)), since you are the one who starts the conversation. If you leave us your email address, we use it strictly to get back to you about that conversation, not to add you to any list.
Analytics data is processed only on the basis of your consent (Art. 6(1)(a)), which you can withdraw at any time.
4. Who we share website data with
We rely on trusted providers acting as processors: EU-based hosting infrastructure (Hetzner, Frankfurt, Germany), our automation platform (n8n) and database (Supabase), our scheduling provider (Cal.com, if you book an audit), and Google Analytics (Google Ireland Ltd). We never sell your data and only share it where necessary to deliver our services or where required by law.
A complete list of the providers involved in all our processing activities, including those carried out on behalf of clients, is set out in section 10.
5. International transfers
Our operational infrastructure is located in the European Union. Certain providers may transfer data to servers outside the EU, including the United States. Such transfers rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework and/or Standard Contractual Clauses approved by the European Commission.
The website chat has one particularity that we prefer to state plainly. Conversations are stored in our own internal application (Business Assistant), where a person from the team replies to you. The data stays in the European Union: the database is at Supabase, in Frankfurt, and the application server is at Hetzner, in Germany. Chat messages are not sent outside the European Union.
If you would rather not use the chat, email us directly at contact@flowetica.com or use the contact form. It reaches the same people.
6. How long we keep your data
We keep contact form data for 12 months from our last contact with you. After that, we delete your name, email address, phone number and message, unless we have started working together. Google Analytics data is retained according to Google's settings (up to 14 months).
For the online assessment and audit, the periods are fixed and applied automatically. If you didn't leave us an email address, after 30 days we delete your business name, contact details, anything you typed in free-text fields, and the identifiers of your visit; only your answers and results remain, with nothing that identifies you. If you did leave us your address, after 12 months we delete your email address, name and phone number, unless we have started working together. Submissions abandoned before the first set of questions are deleted after 24 hours.
Chat conversations are kept for 12 months from the last message, then deleted. The deletion date is recorded on each conversation individually rather than left to anyone's memory, and deletion happens automatically. You can ask for earlier deletion at any time at contact@flowetica.com.
Retention periods for data processed on behalf of clients are set out in section 9.
7. Cookies
We use only necessary and, with your consent, analytics cookies. See our Cookie Policy for details. You can change or withdraw your consent at any time via the "Cookie settings" link in the footer.
8. Your rights
Under the GDPR you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, the right to data portability, and the right to withdraw consent at any time (without affecting processing carried out before withdrawal). To exercise any of these, email privacy@flowetica.com. We respond within 30 days.
If your data is processed by us on behalf of a business (section 9), you may contact that business directly or contact us: in the latter case we will forward your request to the controller and support them in resolving it. You can request deletion of your data at any time through the procedure described on the Data Deletion page.
9. Processing carried out on behalf of our clients
This section applies if you are a customer of a business that uses Flowetica's services. For this data, that business is the controller and we are the processor. We never use this data for our own purposes, for marketing, or to train artificial intelligence models.
9.1. Messages received on social media
When you send a direct message to the Facebook Page, Instagram Business account, or TikTok account of a Flowetica client, we process the content of your message, the user identifier assigned by the platform, the public name shown on your profile, and the time of the message.
We do not access or store any other information from your profile, your friends or followers list, your photos, your posts, or any other conversations.
The purpose is to allow that business to respond to you faster. The message is classified automatically, and for common questions (opening hours, address, available services) an automated reply is generated. Any message requiring human attention (complaints, medical questions, cancellation requests, or unclear situations) is forwarded to a member of the client's team without an automated reply.
All automatically generated replies are labeled as such, in accordance with Article 50 of Regulation (EU) 2024/1689 on artificial intelligence. You will always know when you are talking to an automated system rather than a person.
For message classification we use Anthropic PBC (Claude models) as a sub-processor. The message content is transmitted for processing but is not used to train models.
Messages and their associated classifications are retained for a maximum of 24 months from receipt, or until termination of the contract with our client, whichever comes first.
9.2. Appointment confirmations and instructions
If you are a customer of a business using our services, you may receive SMS messages or emails about your appointment: confirmations, forms to complete before your session, and preparation or aftercare instructions.
We process your name, phone number, email address, the booked service, the date and time of the appointment, and the delivery status of the communications sent. Delivery is handled by SMSO (SMS) and Resend (email).
These messages are transactional, they relate to the service you requested, and contain no marketing content.
9.3. Medical forms (contraindication questionnaires)
For certain services, such as laser hair removal, body contouring, or micropigmentation, the business may send you a form in which you declare conditions, treatments, or circumstances that would make the procedure inadvisable.
This information constitutes special categories of health data under GDPR Art. 9. It is processed solely on the basis of your explicit consent, given when completing the form, and strictly for the purpose of assessing the safety of the procedure.
Answers to medical forms are stored in the client's application, in the EU, and are visible only inside the application after sign-in. Internal staff notifications are being moved into the application itself; until then we treat messaging channels as a place that must not carry the contents of a medical form. Access to the data is restricted.
Completed forms are retained for the duration of your relationship with the business, plus any period required by legal obligations applicable to it.
9.4. Commercial communications
If you have given consent to receive commercial communications, you may receive re-engagement messages, offers, or review requests from that business.
These messages are sent only where your consent exists, in accordance with Romanian Law no. 506/2004. The system automatically blocks delivery in its absence. Every such message contains an unsubscribe link, and withdrawal of consent takes effect immediately and permanently.
9.5. The Flowetica Business Assistant application and notifications to the business's staff
The application your business works in, and where notifications for employees and contractors arrive, is Flowetica Business Assistant (business.flowetica.com). Its data stays in the European Union: the database is at Supabase, in Frankfurt, and the server is at Hetzner, in Germany. Until all operational notifications have moved fully into the application, some still go out through Telegram; we treat it as a channel that must not carry the contents of a medical form.
The AI assistant in the application sends the business users' questions and aggregated figures about the business to Anthropic PBC (USA) so that it can answer. If you use voice, the recording of the question is transcribed, and the answer is read aloud, through OpenAI (USA). The basis for the transfer to the USA is the providers' EU–US Data Privacy Framework certification and the Standard Contractual Clauses in their data processing agreements. Neither of them uses our data to train models; OpenAI keeps requests for at most 30 days, to prevent abuse.
Health data from client records does not pass through the AI assistant. We ask users not to type or dictate health data in their questions.
10. List of providers involved in processing
| Provider | Role | Data location |
|---|---|---|
| Hetzner | application hosting | EU (Germany) |
| Supabase | operational database | EU (Frankfurt) |
| n8n | automation platform | EU |
| Anthropic PBC | automated message classification; the AI assistant in Business Assistant (users' questions and aggregated business figures) | USA, Data Privacy Framework and Standard Contractual Clauses |
| OpenAI | transcription of dictated questions and reading answers aloud for the AI assistant in Business Assistant (only if voice is used; requests kept for at most 30 days, to prevent abuse) | USA, Data Privacy Framework and Standard Contractual Clauses |
| Meta Platforms | receiving and sending Facebook and Instagram messages | USA, Standard Contractual Clauses |
| TikTok | receiving and sending TikTok messages | as per provider's policy |
| SMSO | SMS delivery | Romania |
| Resend | email delivery | EU/USA, Standard Contractual Clauses |
| Telegram | operational notifications to the business's staff | as per provider's policy, outside the EU |
| Cal.com | audit scheduling via the website | EU/USA |
| Google Ireland Ltd | website traffic analytics | EU/USA, Data Privacy Framework |
We do not add a new provider without prior notice to our client, who has the right to object on reasoned grounds.
11. Right to lodge a complaint
If you believe your data-protection rights have been breached, you can lodge a complaint with the Romanian supervisory authority (the Romanian data protection authority): Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest; www.dataprotection.ro.
12. Updates
Last updated: October 2026. We will notify active clients of any material changes to this policy.
This policy is kept up to date as our services evolve. For any question, contact privacy@flowetica.com.
