Privacy Policy and Personal Data Protection

1. General Provisions

This Privacy Policy (the “Policy”) describes how we collect, use, store, and protect the personal data of users of the TrueFlow website and service (the “Service”), operated by the data controller — TrueFlow (the “we”, “us”, or “Controller”).

By using the Service, you confirm that you have read this Policy. If you do not agree with its terms, please do not provide personal data and discontinue use of the Service.

This Policy has been prepared taking into account the requirements of EU Regulation 2016/679 (GDPR) to the extent applicable to our users, the Law of Ukraine “On Personal Data Protection”, as well as the requirements of platforms and regulators, including Meta Platforms, Inc., regarding transparency of data processing when integrating with Meta products (Facebook, Instagram, etc.) and undergoing application reviews (App Review).

2. Data Controller and Contact Information

Data Controller: TrueFlow.

Data Protection Contact: електронна пошта trueflowsupport@gmail.com. You can also use this channel to exercise your rights described in Section 9.

3. What Data We Process

Depending on how you interact with the Service, we may process the following categories of data:

• Identification and contact data: name, phone number, Telegram identifier, or other contact details that you voluntarily provide in website forms or during registration / the trial period.
• Account data: login, email address, and technical session identifiers, if provided by the Service functionality.
• Technical and analytics data: IP address, browser and device type, interface language, visit time, referral pages, referrer, and diagnostic logs — for security, service stability, and improving the Service.
• Data related to integrations (including Meta): if you connect Meta advertising accounts, CRM systems, or other sources, aggregated or detailed advertising, conversion, spending, and other metrics may be processed through the Service in accordance with the integration settings and the policies of the respective platforms. Such data is processed based on the permissions you grant (OAuth, access tokens) and the terms of Meta and other providers.

We do not knowingly collect data from children under 16. If you believe we have received such data, please contact us using the address above.

4. Purposes and Legal Bases for Processing

We process personal data for the following purposes:

• Providing access to the Service, processing requests and feedback — performance of a contract or steps taken prior to entering into a contract; in certain cases — consent.
• Communication regarding demos, the trial period, and support — legitimate interest (responding to requests) or consent.
• Network security, prevention of abuse, and compliance with legal requirements — legitimate interest and/or legal obligation.
• Website visit analytics (in anonymized or aggregated form where possible) — legitimate interest or consent, depending on the technologies used (see the section on cookies).

5. Cookies and Similar Technologies

The website may use cookies and similar technologies to ensure page functionality, save settings, and analyze visits. You can manage cookies in your browser settings. Disabling certain cookies may limit the functionality of the Service.

6. Sharing Data with Third Parties

We may share data with:

• IT infrastructure providers (hosting, CDN, email) — only to the extent necessary to provide the Service, under data processing agreements where required.
• Meta and related products — when you independently connect Meta accounts or other integrations: data sharing is governed by your agreements with Meta and your advertising account settings. We recommend reviewing Meta’s data policy: Meta Privacy Policy.
• As required by law — to government authorities in legally established cases.

We do not sell your personal data to third parties for commercial purposes.

7. International Data Transfers

Data may be processed on servers outside your country (including in the EU, United States, or other jurisdictions) when necessary for the operation of the Service or integrations. In such cases, we implement safeguards in accordance with applicable law, including standard contractual clauses, adequacy decisions, and other appropriate measures.

8. Data Retention Period

Personal data is retained no longer than necessary for the purposes described in this Policy or to fulfill legal obligations, such as accounting requirements. After the retention period expires, the data is deleted or anonymized.

9. Your Rights

You have the right to access your personal data, correct it, request its deletion (“right to be forgotten”), restrict processing, data portability where applicable, object to processing based on legitimate interest, and withdraw consent where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

To exercise your rights, contact trueflowsupport@gmail.com. You also have the right to lodge a complaint with the data protection supervisory authority in your country of residence or location.

10. Security

We implement organizational and technical measures to protect personal data from unauthorized access, loss, or alteration. No method of transmitting data over the Internet is completely secure; we continuously improve our practices in accordance with industry standards.

11. Changes to this Policy

We may update this Policy from time to time. The current version is always available on this page. We may provide additional notice of material changes, for example through the Service or by email, where required by law.

12. Contact Information

Questions regarding this Policy and the processing of personal data: trueflowsupport@gmail.com