Privacy Policy

Privacy Policy

Last updated: 18 September 2026

Flow 52 (“we”, “us”, “our”) is a trading name of StreamshareDM OÜ. We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, why we collect it, and how we use it.

1. Who We Are

Flow 52 is a cash flow planning tool for seasonal businesses and for individuals and households whose income changes through the year. Our website is flow52.com and our application is at app.flow52.com.

The data controller responsible for your personal data under UK GDPR and EU GDPR is:

  • Company: StreamshareDM OÜ, a private limited company registered in Estonia
  • Registry code: 17039398
  • Registered address: Ruunaoja tn 3, Lasnamäe district, 11415 Tallinn, Harju county, Estonia
  • Privacy contact: team@flow52.com

2. Information We Collect

Information you provide directly

  • Account information: name, email address, password
  • Financial information you enter: the income, costs and bills you enter to build your cash flow plan. This may be about your business, your household, or both.
  • Payment information: billing details processed securely by Stripe (we never see or store your card number)
  • Free resource sign-ups: your email address (and name, if given) when you request a free resource such as the 3 Step Blueprint
  • Walkthrough bookings: your name, email address and chosen time when you book a walkthrough call
  • Communications: any emails or messages you send us

Information collected automatically

  • Usage data: pages visited, features used, time spent in the app
  • Technical data: IP address, browser type and version, operating system, referring URLs
  • Email activity: whether our emails are opened and which links are clicked
  • Cookies: see our Cookie Policy (UK) or Cookie Policy (EU) for full details

3. How We Use Your Information

We use your information to:

  • Provide and operate the Flow 52 service
  • Process your subscription and payments
  • Send you service-related emails (account confirmations, password resets, receipts, important notices)
  • Send you the free resources you request, and follow-up emails about them
  • Send you marketing emails only if you have opted in — you can unsubscribe at any time
  • Measure how our website and advertising perform (only with your cookie consent)
  • Improve the product based on how it is used
  • Comply with legal obligations
  • Respond to your enquiries and support requests

4. Legal Basis for Processing (UK & EU Users)

Under UK GDPR and EU GDPR, we process your personal data on the following legal bases:

  • Contract: processing necessary to provide the service you have subscribed to, or a walkthrough you have booked
  • Legitimate interests: improving our product, fraud prevention, security
  • Consent: free resource sign-ups, marketing emails, analytics and advertising cookies (you can withdraw consent at any time)
  • Legal obligation: where required by law (e.g. tax records)

5. Who We Share Your Information With

We do not sell your personal data. We share data only with trusted service providers that we need to run Flow 52:

  • DigitalOcean — website and app hosting (servers in London, UK)
  • Stripe — payment processing (Stripe Privacy Policy)
  • Brevo (France) — website and account emails, such as password resets
  • Sender.net (Lithuania) — free resource sign-ups and marketing emails
  • Namecheap (USA) — our business email accounts and domain name
  • Google Analytics — website and app analytics (only with your consent)
  • Google Fonts — website fonts (your browser connects to Google, which receives your IP address)
  • Meta (Facebook) Pixel — measuring our advertising (only with your consent)
  • Bunny.net (Slovenia) — video hosting
  • Calendly (USA) — booking walkthrough calls
  • Anthropic (Claude, USA) — AI assistant we use to maintain the website and app. It may see personal data while fixing a problem. It does not use our data to train its AI models.
  • OpenAI (ChatGPT, USA) — AI assistant we use to maintain the website and app. It may see personal data while fixing a problem. It does not use our data to train its AI models.
  • Dropbox and Google Drive — secure backups of our website and app data

We require all service providers to protect your personal data and to use it only on our instructions and in accordance with the law. We may also disclose information where the law requires it.

6. International Transfers

Some of our service providers are based in, or store data in, the USA. Where your data is transferred outside the UK or the European Economic Area (EEA), we rely on one of these safeguards:

  • the EU-US Data Privacy Framework and its UK Extension, where the provider is certified; or
  • Standard Contractual Clauses approved by the European Commission, with the UK International Data Transfer Addendum.

Transfers between the UK and the EEA are covered by adequacy decisions. You can ask us for more information about these safeguards at team@flow52.com.

7. Data Retention

  • Accounts: for as long as your account is active. If you close your account, we will delete or anonymise your data within 30 days, unless we are required to keep it for legal or financial reasons (typically 7 years for financial records).
  • Free resource sign-ups and marketing emails: until you unsubscribe.
  • Backups: overwritten on a rolling basis.

If you unsubscribe or ask us not to contact you, we keep your email address on a do-not-contact list so that we don’t email you again.

8. Your Rights

Under UK GDPR and EU GDPR, you have the following rights:

  • Right of access — request a copy of the personal data we hold about you
  • Right to rectification — ask us to correct inaccurate or incomplete data
  • Right to erasure — ask us to delete your personal data (“right to be forgotten”)
  • Right to restrict processing — ask us to limit how we use your data
  • Right to data portability — receive your data in a structured, machine-readable format
  • Right to object — object to processing based on legitimate interests, and to direct marketing at any time
  • Rights related to automated decision-making — we do not make automated decisions that have a legal or significant effect on you

To stop receiving emails from us, click the unsubscribe link in any email or reply asking us to stop. To exercise any of your other rights, email us at team@flow52.com. We will respond within one month. You also have the right to lodge a complaint with a supervisory authority:

9. Cookies

We use cookies and similar technologies. Visitors from the UK and EU are shown a cookie consent banner and can manage their preferences at any time. For full details, see our Cookie Policy (UK) or Cookie Policy (EU).

10. Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Payments are encrypted via Stripe and we use secure HTTPS connections throughout the site and app.

11. Children

Flow 52 is intended for adults aged 18 and over. It is not directed at children, and we do not knowingly collect data from anyone under 18.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes by email. The “Last updated” date at the top of this page will always reflect the current version.