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flōw — Privacy Policy

Effective date: July 25, 2026

Welcome to flōw. This Privacy Policy explains what personal data we collect, how we use it, and the choices you have. It applies to the flōw mobile app (iOS and Android) and to meetonflow.com.

The data controller for personal data processed through flōw is Flow-Entertainment ("we", "us", "our"), a sole proprietorship of Frank Jeuring, registered office Loperstraat 147, 7891 JS Klazienaveen, the Netherlands, KvK 91360811, VAT NL004885355B38. Data protection contact: privacy@flow-entertainment.com.

1. Information We Collect

• Profile information: name, age, gender, photos, and biography
• Approximate and precise location, where you grant permission
• Identity and age-verification data, processed via our verification partner
• Facial biometric data (ID photo and a live selfie), processed by our verification partner during identity and age verification (see Section 3)
• In-app communications (messages, meet requests)
• Device information, app usage, and diagnostic data
• Purchase and subscription data (for Premium features)
• Advertising identifiers (see Section 6, Advertising)

2. How We Use Your Information

• To create and display your profile to other users
• To facilitate matches, meet requests, and in-app messaging
• To verify your age and identity and maintain platform safety
• To send push notifications you've enabled
• To process Premium subscription purchases
• To serve and measure advertising (see Section 6)
• To automatically screen uploaded photos for explicit, violent, or otherwise prohibited content
• To detect fraud, abuse, and violations of our Terms of Service

3. Identity & Age Verification

We use Didit, our third-party identity-verification provider, to confirm you meet our minimum age requirement and that you are a real person. This process involves facial biometric data: Didit scans your government-issued ID document and captures a live selfie, performs a liveness check, and compares your selfie against the photo on your ID using facial-recognition technology.

Facial biometrics are a special category of personal data under Article 9 GDPR, so we process them only on the basis of your explicit consent, which you give on the verification screen before the check begins. You can withdraw this consent at any time (see Section 11, Your Rights). Your identity document and biometric data are processed directly by Didit and are not stored on our servers — we receive only the pass/fail outcome and your confirmed age. We also use platform-level age-assurance signals (Apple Declared Age Range, Google Play Age Signals) as a supplementary check.

4. Content Moderation

Every photo you upload — profile photos, story images, and photos you send in chat — is automatically screened by an AI content-moderation system (Anthropic's Claude), our third-party moderation provider. The screening runs immediately after upload and before the photo becomes visible to anyone else, and checks each image against our safety categories, including: child sexual abuse material or any apparent minor in a sexual context; non-consensual or explicit sexual content; graphic violence or gore; hate symbols; and other content prohibited by our Community Guidelines. Any image that matches the child-safety category is blocked and handled under our zero-tolerance minor-safety process. Photos that fail this check are deleted immediately and never appear on your profile. Claude receives only the image itself — never your name, email address, or other account details.

These screening and identity-verification steps are automated. Because an automated decision can occasionally be wrong, you have the right to a human review: if a photo is rejected or your verification fails and you believe this was a mistake, you can contest it by contacting our support team, and a person on our team will review the decision.

When you report another user, our app automatically attaches a snapshot of the reported content to your report — for example, their profile (name, age, bio, spotlight answer, photos) or, for a chat report, the recent messages in that conversation. This snapshot is captured on your own device at the moment you submit the report, and is visible only to our moderation team for the purpose of reviewing your report — never to other users, and not retrievable by you afterwards. Chat messages are end-to-end encrypted in transit and at rest; we cannot and do not decrypt other users' conversations in bulk or on demand. The only message content our moderation team ever sees is what a user has chosen to include in a report, or what you send directly in an in-app support conversation with our team.

5. Automated Decision-Making & Artificial Intelligence

flōw uses automated systems and AI in a few clearly defined places: (a) automatic AI screening of every uploaded photo, as described in Section 4; (b) identity and age verification, including the facial-biometric checks described in Section 3; (c) an optional AI writing assistant that can draft or improve your profile bio at your request; and (d) automated anti-fraud and abuse detection that helps us spot fake accounts and Terms violations.

Some of these steps can restrict your account — for example, a rejected photo or a failed verification. Where a decision is made solely by automated means and significantly affects you, you have the right to obtain human review: contact support@flow-entertainment.com and a person on our team will re-examine the decision.

We do not use emotion-recognition technology, and we do not use AI profiling to rank or match users based on inferred personal characteristics. The AI bio assistant is optional and generates text only when you ask it to.

6. Advertising

flōw shows advertising to free-tier users through Google AdMob, which may use mediation to serve ads from other ad networks, including Meta Audience Network. These partners may collect and use the following to select and measure ads:

• Advertising identifiers (Android Advertising ID / Apple IDFA)
• Coarse or precise device and usage data
• Ad interaction data (impressions, clicks)

On iOS, we request App Tracking Transparency (ATT) permission before any tracking-enabled ad request is made. If you decline, we serve non-personalized ads instead. Premium subscribers do not see ads.

Partner	Purpose	Privacy Policy
Google AdMob	Ad serving & mediation	policies.google.com/privacy
Meta Audience Network	Ad mediation partner	facebook.com/privacy/policy

7. Location Data

• We use your location to show you nearby profiles and, if you choose, to share it during a planned meetup
• Your exact location is never shared with other users
• The Live Map displays only an approximate location

8. Purchases & Subscriptions

Premium purchases are processed through the Apple App Store or Google Play, and managed in-app via RevenueCat, our subscription-management provider. RevenueCat receives purchase and entitlement data necessary to validate and manage your subscription.

9. Data Sharing

• We never sell your personal data
• Data is shared only with service providers who process it on our behalf (identity verification, content moderation, advertising, subscription management, cloud hosting)
• We may disclose data where required by law or to protect user safety

10. Data Retention

We retain your data while your account is active. After account deletion, your data is permanently deleted within 30 days, except where retention is required by law.

11. Your Rights

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data
• Object to certain processing, including personalized advertising
• Obtain human review of decisions made solely by automated means (see Section 5)
• Withdraw your consent to biometric identity verification at any time

12. Security

We use encryption and other technical safeguards to protect your data. Passwords are never stored in readable form.

13. Age Requirement

flōw is intended for adults only. We do not knowingly collect data from anyone under our minimum age requirement, and we enforce age verification at signup and through ongoing platform-level age-assurance checks.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to users in-app.