FlowNurture ('we', 'our', or 'us') is committed to protecting your personal data. This Privacy Policy explains what data we collect, how we use it, and your rights regarding it. By using FlowNurture's website and services, you agree to the practices described in this policy.
1.Information We Collect
We collect information in the following ways:
Information you provide directly
- Account registration details: name, email address, company name
- Payment and billing information (processed by our payment provider — we do not store card numbers)
- Content you upload or create in the platform: contact lists, email templates, workflows, landing pages
- Communications you send to us via support or contact forms
Information collected automatically
- Usage data: pages visited, features used, actions taken within the product
- Device and browser information: IP address, browser type, operating system
- Cookies and similar tracking technologies (see our Cookie Policy)
- Email engagement data: opens, clicks, and unsubscribes for emails sent through the platform
2.How We Use Your Information
We use your personal data to:
- Provide, maintain, and improve the FlowNurture platform
- Process payments and manage your subscription
- Send transactional emails: account confirmations, password resets, billing notifications
- Respond to support requests and communications
- Send product updates and marketing communications (you may opt out at any time)
- Detect and prevent fraud, abuse, and security incidents
- Comply with legal obligations
- Analyse aggregate usage patterns to improve product features
We do not sell your personal data to third parties.
3.How We Share Your Information
We may share your data with:
- Service providers: hosting, payment processing, email delivery, and analytics providers who process data on our behalf under data processing agreements
- Professional advisors: legal, accounting, and auditing firms, subject to confidentiality obligations
- Law enforcement or regulators: where required by law or to protect our legal rights
- Acquirers: in the event of a merger, acquisition, or sale of assets, subject to equivalent privacy protections
We require all third parties to handle your data in accordance with applicable data protection law.
4.Data Retention
We retain your personal data for as long as your account is active or as needed to provide our services. Following account deletion, we retain data for a period sufficient to comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods are:
- Account data: retained for the duration of your subscription plus 2 years following termination
- Billing records: retained for 6 years in accordance with applicable financial regulations
- Support communications: retained for 2 years
- Contact data you upload: deleted within 30 days of account termination or deletion request
5.Your Rights
Depending on your location, you may have the following rights regarding your personal data:
- Access: request a copy of the personal data we hold about you
- Rectification: request correction of inaccurate or incomplete data
- Erasure: request deletion of your personal data, subject to legal retention requirements
- Restriction: request that we limit how we process your data in certain circumstances
- Portability: receive your data in a structured, machine-readable format
- Objection: object to processing of your data based on legitimate interests
- Withdraw consent: where processing is based on consent, you may withdraw it at any time
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
7.International Data Transfers
FlowNurture is based in New Brunswick, Canada. Your personal information may be transferred to, stored, or processed in countries outside of your home jurisdiction, including the United States and the European Economic Area (EEA).
Safeguards and Transfer Mechanisms
To ensure your data receives a level of protection comparable to Canadian and European standards, we employ the following mechanisms:
- Privacy Impact Assessments (PIAs): we conduct assessments for all transfers of personal information outside of Canada (or Quebec, as applicable) to evaluate the legal framework of the recipient jurisdiction
- Standard Contractual Clauses (SCCs): we utilize the European Commission’s approved SCCs for data transferred to jurisdictions without an adequacy decision
- Data Processing Agreements (DPAs): we sign formal contracts with all third-party service providers that strictly limit their use of your data and mandate robust security measures
- Adequacy Decisions: we prioritize service providers located in regions recognized by the European Commission or the Office of the Privacy Commissioner of Canada as providing adequate protection
Please note that while data is outside of Canada, it may be subject to the laws of the foreign jurisdiction, including access requests by local courts, law enforcement, or national security authorities.
8.Security
We implement technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:
- Encryption of data in transit (TLS) and at rest
- Access controls and authentication requirements
- Regular security assessments
- Incident response procedures
No method of transmission or storage is 100% secure. If you believe your data has been compromised, please contact us immediately at [email protected].
Breach Notification
In accordance with Canadian law, we will notify you and the Office of the Privacy Commissioner of Canada (and the Commission d'accès à l'information du Québec, if applicable) as soon as feasible if we become aware of a security breach that creates a real risk of significant harm to you.
9.Children's Privacy
FlowNurture's services are not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us and we will delete it promptly.
10.Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or by prominent notice in the product at least 30 days before the changes take effect. Continued use of the service after the effective date constitutes acceptance of the updated policy.
11.Contact and Data Controller
The data controller for your personal data is:
Divine Integrated Services Inc.
1 Germain Street
Saint John, NB, E2L 4V1
Canada
Privacy Officer
We have appointed a Privacy Officer to oversee our compliance with this policy and applicable privacy laws (including PIPEDA and Quebec's Law 25). If you have questions about our privacy practices, or wish to exercise your rights, please contact our Privacy Officer at:
Email: [email protected]
Mail: Attn: Privacy Officer, 1 Germain Street, Saint John, NB, E2L 4V1
If you have unresolved concerns about our handling of your data, you have the right to lodge a complaint with your local data protection authority.
Questions about this policy?
Contact us at [email protected] or visit our contact page.