Last updated: December 27, 2025.
Site owner (Operator): Individual Entrepreneur Stanislav Olegovich Tungulov (Russian taxpayer ID / INN 212001851916).
Site: https://fluw.space
This Personal Data Processing Policy (the “Policy”) applies to all information the Operator may obtain about the User while they use the Operator’s website, services, programs, and products (the “Service”).
1.1. This Policy is drawn up in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (the “Law”) and sets out the procedure for processing personal data and the security measures taken by the Operator.
1.2. The Operator’s most important goal and a precondition for carrying out its activities is respecting the rights and freedoms of individuals when processing their personal data, including protecting the right to privacy and personal and family confidentiality.
1.3. By using the Service, the User agrees to this Policy and to the terms of processing of the User’s personal data.
1.4. If the User does not agree with the terms of the Policy, they must stop using the Service.
The following terms are used in this Policy:
processing personal data using computing equipment.
the temporary suspension of personal data processing (except where processing is required to clarify the personal data).
actions that make it impossible, without additional information, to determine that personal data belongs to a specific data subject.
any action (operation) or set of actions (operations) performed on personal data, whether or not using automation tools.
any information relating directly or indirectly to an identified or identifiable individual (a User).
any visitor of the website https://fluw.space.
3.1. The Operator processes the User’s personal data only if it was entered and/or submitted by the User through special forms on the Service’s website, or in the course of using the Service’s functionality.
The Operator may process the following personal data of the User:
Note: The Operator does not collect, process, or store bank card data (card number, expiration date, CVC/CVV). That data is processed directly by licensed payment providers (JSC “Tochka”, LLC “Robokassa”).
Data is collected and processed exclusively for the following purposes:
Creating and managing the User’s account, providing access to the personal dashboard.
Giving the User access to content and code generation functionality under the license public offer agreement.
Processing subscription and token purchase payments, and sending electronic receipts in accordance with Russian law.
Handling requests and tickets from Users related to use of, or errors or failures in, the Service.
Analyzing anonymized technical data and AI usage logs to train internal algorithms, fix bugs, and improve the user interface (UX).
Sending notifications about new products and services, special offers, and various events (only with the User’s consent). The User can always opt out of receiving informational messages via the “Unsubscribe” link in the email.
6.1. The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures required to fully meet the requirements of applicable personal data protection law.
6.2. Protection measures: The Operator safeguards personal data and takes every reasonable measure to prevent unauthorized access (HTTPS traffic encryption, password hashing, restricted employee access).
6.3. Retention period: Personal data is retained no longer than required by the purposes of processing, unless a longer retention period is set by federal law or by an agreement to which the User is a party.
6.4. Database localization: The collection, recording, systematization, accumulation, and storage of personal data of Russian Federation citizens is carried out using databases located within the territory of the Russian Federation.
7.1. The Operator may disclose personal data to law enforcement and investigative authorities, and to other authorized bodies, on grounds provided for by applicable Russian law.
The Service is functionally integrated with the APIs of neural network models provided by technology partners (including OpenRouter). This integration involves the exchange of technical data, namely: prompt text and generation parameters.
The Operator does not share data that could directly identify the User (such as email address, name, or phone number) with technology partners, except where the User voluntarily includes such data in the prompt text itself.
By submitting a generation request, the User consents to having the text they entered processed on the infrastructure of the Service’s technology partners.
8.1. The User can change (update, supplement) the personal information they provided, or any part of it, at any time using the editing feature in the personal dashboard.
The User can withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to fluw@tungulov.space with the subject “Withdrawal of consent to personal data processing”.
8.3. If inaccuracies are found in the personal data, the User can correct them on their own by sending the Operator a notice by email with the subject “Personal data correction”.
8.4. When an account is deleted, the Operator stops processing the personal data and destroys it within 30 days, except for data the Operator is legally required to keep (accounting and tax records).
9.1. The website collects and processes anonymized visitor data (including cookies) using web analytics services (Yandex Metrika and/or others).
9.2. Technical cookies are also necessary for authorization to work correctly and to save interface settings.
9.3. The User can disable cookies in their browser settings, but the Operator warns that this may cause the Service to malfunction.
10.1. The Operator does not process biometric personal data (information that describes a person’s physiological and biological characteristics that can be used to establish their identity).
10.2. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health, or intimate life.
10.3. The Service is not intended for use by persons under the age of 18. The Operator does not knowingly collect data about minors.
11.1. The User can get any clarification on questions about the processing of their personal data by contacting the Operator by email at fluw@tungulov.space.
11.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
11.3. The current version of the Policy is freely available online at https://fluw.space/privacy.