Privacy Policy
Version: draft 0.2 · Effective date: [TO BE CONFIRMED: publication date]
This policy explains how FluxVivo processes personal data, having regard to the UK GDPR and the Data Protection Act 2018 (United Kingdom) and the EU General Data Protection Regulation (EU) 2016/679.
1. Who is responsible for your data
The controller of your account data is:
- Controller: MILSON RAMOS SILVA, sole trader in the United Kingdom, trading as FluxVivo
- Companies House number: not applicable (sole trader)
- Correspondence address: 68 Devonshire Road, Ipswich, Suffolk, IP3 8AU, United Kingdom
- Privacy contact: privacy@fluxvivo.app
- ICO (Information Commissioner's Office) registration: [TO BE CONFIRMED: registration number or exemption]
- EU representative (Art. 27 GDPR), if applicable: [TO BE CONFIRMED: name and address]
- Data Protection Officer (DPO), if appointed: [TO BE CONFIRMED: whether one exists and contact details]
2. What data we process
- Account data: email address, password (stored securely by the authentication provider and never visible to us) and login session data.
- Business data: name, sector, default currency, opening balance and chosen plan.
- Financial data you enter: income and expense entries, bills payable and receivable, descriptions, amounts, dates, categories, notes and the names of customers or suppliers you record.
- Technical data: IP address and browser information processed by the hosting and authentication providers for security and operation.
We currently do not use third-party analytics, advertising or tracking tools. Payments are prepared in test mode only with Stripe; FluxVivo does not store card details. [TO BE CONFIRMED: update when live payments are enabled]
3. Why we use the data and lawful basis
- Creating and maintaining your account and providing the service — performance of a contract (Art. 6(1)(b)).
- Security and prevention of fraud and abuse — legitimate interests (Art. 6(1)(f)).
- Complying with legal, tax and accounting obligations — legal obligation (Art. 6(1)(c)).
- Marketing communications, if any — only with consent (Art. 6(1)(a)). [TO BE CONFIRMED: whether there will be email marketing]
4. Third-party data you enter
When you record the names of customers, suppliers or other people, your business is the controller of that data and FluxVivo acts as a processor, handling it only to provide the service. [TO BE CONFIRMED: data processing agreement (DPA) to be made available to customers]
5. Service providers (sub-processors)
- Clerk, Inc. (USA) — authentication: sign-up, login, session and email verification.
- Emergent — application and database hosting. [TO BE CONFIRMED: legal entity, country and server region]
- Stripe — payments, invoices and customer portal (currently in test mode). [TO BE CONFIRMED: contracting Stripe entity, role (merchant of record or payment processor) and place of processing]
- Transactional email — [TO BE CONFIRMED: whether and which provider will be used]
6. International transfers
Some providers may process data outside the United Kingdom and the European Economic Area (for example, in the USA). In those cases transfers must be protected by recognised mechanisms such as the EU Standard Contractual Clauses, the UK Addendum/IDTA or the EU-US Data Privacy Framework and its UK Extension. [TO BE CONFIRMED: mechanism applicable to each provider]
7. Storage, security and data separation
- Each business's data is kept separate: every account can only access its own business's data.
- Connections to the application use HTTPS.
- The app installed on your phone does not keep your financial data on the device; it stays on the server.
- Server location: [TO BE CONFIRMED: country/region] · Encryption at rest: [TO BE CONFIRMED: confirm with the hosting provider] · Backups: [TO BE CONFIRMED: frequency and retention]
8. How long we keep data
We keep data while your account is active. After closure: [TO BE CONFIRMED: deletion or retention period]. Records required by law may be kept for the applicable statutory period. [TO BE CONFIRMED: applicable statutory periods]
9. Your rights
You have the right to: access; rectification; erasure; restriction; portability; objection; and to withdraw consent where consent is the lawful basis.
To exercise your rights, contact privacy@fluxvivo.app. We will respond within one month, as required by law. You can already correct your business details and delete entries and bills in the app itself. [TO BE CONFIRMED: how full account deletion will be handled]
You may also complain to a data protection authority: in the United Kingdom, the ICO (ico.org.uk); in the EU, the authority of your country of residence.
10. Cookies and local storage
- Strictly necessary cookies from the authentication provider (Clerk) to keep you signed in.
- Browser local storage for simple preferences (for example, hiding the install prompt) and for the installed app to work (icons and offline page).
- We do not use advertising or analytics cookies. If this changes, we will ask for your consent first.
11. Children
FluxVivo is intended for businesses and must not be used by anyone under 18.
12. Changes to this policy
We will tell you about material changes in the app or by email before they take effect.