Privacy Policy

Flow.Vin Ltd. ("FLOW", "Company", "we", "our", or "us") respects your privacy and is committed to protecting your personal information and driving-related data.

This Privacy Policy explains how we collect, use, process, store, and protect information when you access or use the FLOW platform, applications, websites, telemetry systems, APIs, AI systems, and related services (collectively, the "Services").

By accessing or using the Services, you consent to the practices described in this Privacy Policy.

1. Information We Collect

Depending on how you use the Services, FLOW may collect the following categories of information.

1.1 Account Information

• Name
• Email address
• Username
• Organization or team affiliation
• Login credentials
• Billing and subscription information

1.2 Driving and Telemetry Data

FLOW may collect telemetry and operational driving data, including:

• GPS location data
• Speed and acceleration
• Pedal and steering behavior
• Vehicle dynamics
• Driver performance metrics
• Driving sessions and operational event logs
• Simulator telemetry
• Vehicle sensor data
• Route and operational data
• Application usage statistics
• Dash-cam or pilot-view video recordings, where applicable and enabled
• Haptic and vibration response data, where applicable and enabled
• Steering input patterns, where applicable and enabled
• Wearable-integrated biometric indicators such as heart rate or stress signals, where applicable and enabled

1.3 Device and Technical Information

• Device type
• Operating system
• Browser information
• IP address
• Mobile identifiers
• Application version
• Crash logs and diagnostics
• Connectivity information

1.4 AI and Behavioral Data

FLOW may generate behavioral analytics and performance insights derived from telemetry and platform interaction data, including:

• Driver scoring
• Behavioral models
• Training recommendations
• Driver DNA profiles
• AI-generated operational insights
• Safety envelope models
• Real-time co-driving logic

1.5 Derived Intelligence

FLOW may generate "Driver DNA" signatures, behavioral profiles, and Safety Envelope models derived from telemetry and operational interaction data.

While users and organizations retain ownership of their raw telemetry and uploaded data, such derived mathematical models, AI-generated structures, analytics frameworks, and system improvements remain part of FLOW's proprietary technology and intellectual property.

2. How We Use Information

We may use collected information to:

• Operate and maintain the platform
• Authenticate users
• Deliver platform functionality
• Generate telemetry insights and analytics
• Improve AI and ADI system performance
• Provide customer support
• Monitor security and prevent misuse
• Process subscriptions and payments
• Improve user experience
• Conduct internal research and product development
• Comply with legal obligations

3. Legal Basis for Processing (GDPR)

Where applicable under GDPR, FLOW processes personal data based on:

• User consent
• Performance of a contract
• Legitimate business interests
• Compliance with legal obligations
• Protection of safety and security interests

4. Data Sharing and Third Parties

FLOW does not sell personal data.

We may share limited information with trusted third-party service providers solely for operating the Services, including:

• Cloud hosting providers
• Analytics providers
• Authentication services
• Payment processors
• Infrastructure and security providers

Examples may include Paddle.com, Google Cloud Platform (GCP), and Amazon Web Services (AWS).

Such providers are authorized to process information only as necessary to provide services to FLOW.

5. Organizational Accounts

If you access FLOW through an organization, academy, fleet, operator, team, employer, or government entity:

• Your organization may access and manage telemetry, operational, and performance-related data associated with your account.
• The organization is responsible for its own internal policies regarding access, monitoring, retention, and lawful processing of data.

If you are an authorized user operating under an organizational deployment, certain mission-specific or operational telemetry may be managed under organization-controlled policies and permissions.

6. Cookies and Tracking Technologies

FLOW may use cookies and similar technologies to:

• Maintain user sessions
• Authenticate accounts
• Analyze platform usage
• Improve performance and stability
• Remember preferences
• Support analytics and diagnostics

You may manage cookie settings through your browser or device settings.

7. Data Retention

We retain information only for as long as reasonably necessary for:

• Platform operation
• Legal compliance
• Security
• Dispute resolution
• Product improvement
• Organizational deployments

Retention periods may vary depending on the type of data, organizational deployment requirements, and applicable legal obligations.

8. Data Security

FLOW implements commercially reasonable technical and organizational measures designed to protect information against unauthorized access, loss, misuse, disclosure, alteration, and destruction.

However, no internet-based, cloud-based, or telemetry-based system can be guaranteed fully secure.

9. International Data Transfers

Your information may be processed and stored in countries outside your jurisdiction, including jurisdictions that may have different data protection laws than your own.

By using the Services, you consent to such transfers where permitted by applicable law.

10. Your Rights

Depending on your jurisdiction, you may have rights to:

• Access your personal data
• Correct inaccurate data
• Request deletion of data
• Restrict processing
• Object to certain processing activities
• Request data portability
• Withdraw consent where applicable

Certain advanced AI-generated analytics and behavioral intelligence features may require minimum operational or telemetry thresholds to ensure statistical validity and system reliability.

To exercise your rights, contact: support@flow-adi.com

11. California Privacy Rights (CCPA)

If you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA), including the right to:

• Know what personal information is collected
• Request deletion of personal information
• Request disclosure regarding data practices

FLOW does not sell personal information as defined under the CCPA.

12. Children's Privacy

FLOW is not intended for children below the age permitted under applicable law without appropriate parental, guardian, academy, team, or organizational consent and supervision.

Organizations using FLOW with minors are responsible for obtaining all required permissions and consents.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Continued use of the Services following updates constitutes acceptance of the revised Privacy Policy.

14. Contact

support@flow-adi.com

© 2026 Flow.Vin Ltd. All rights reserved.