1. Purpose of this document
This is a draft of the Fluw Privacy Policy for final legal review. It describes the general processing of personal data when using Fluw websites, the client portal, internal services, and web products.
The Operator processes data only to the extent needed for a specific purpose, selected feature, or legal obligation. The actual data set depends on the fields, materials, integrations, and communication methods used by the user.
Until final legal approval, this draft is not a final legal opinion and does not change the actual registration, payment, or client-portal flow.
2. Operator and contact
The data controller is Individual Entrepreneur Stanislav Olegovich Tungulov. Send requests about personal-data processing, correction, or deletion to the work contact below.
Owner: Individual Entrepreneur Stanislav Olegovich Tungulov
Tax ID: 212001851916
Registered address: 19 Chernyshevskogo Street, Cheboksary, Russia
Phone: +79969498308
Email: fluw@tungulov.space
3. Data that may be processed
Depending on the scenario, Fluw may receive information entered during registration, support requests, or project creation, such as a name, email address, account details, and the contents of a message.
When working on a project, a user may provide materials, text, images, catalog data, settings, and other information needed for the selected feature. The user is responsible for having a lawful basis to provide data about other people and for the contents of uploaded materials.
The service may also process technical information needed to operate and protect the service, such as request data, operation time, project identifiers, and diagnostic information. The exact set depends on the environment and the request.
Payment data is handled through the actual payment flow and may be entered on a payment provider's page. Fluw does not claim to be a payment operator or to meet a security standard unless that fact is separately confirmed.
4. Purposes and legal grounds
Data is used for registration and sign-in, account and project operation, selected features, support requests, tariff and billing status, and protection of the service from abuse and failures.
Additional purposes, including informational messages, apply only where there is appropriate consent, a contract, a legal obligation, or another lawful basis. A user may request withdrawal of consent or restriction of processing where applicable.
Automatically created code, text, or design must be reviewed by the user before publication. Project data should not be used for a purpose that a user could not reasonably infer from the selected feature and service documents.
5. Disclosures and integrations
Some features may use infrastructure, authentication, payment, support, or connected-integration providers. Disclosures are limited to the data needed for the operation and permitted by the project's settings.
External providers control their own terms and availability. Fluw does not promise uninterrupted integrations, unchanged provider terms, or that no data is transferred when a user connects an external source.
This draft does not publish an unverified list of subprocessors, data geography, or special certifications. Questions about an actual provider, data category, or integration can be sent to the Operator's contact.
6. Retention, deletion, and security
Data is retained for as long as needed for the stated purpose, contract performance, protection of the Operator's or user's rights, or legal obligations. This policy does not set one fixed period for every data type.
Requests to correct, delete, or restrict processing are considered in light of the processing ground, mandatory retention duties, project state, and technical constraints. Removing data from one interface should not be understood as a promise of immediate removal from every log, backup, or provider system.
The Operator applies organisational and technical measures proportionate to the risks of the relevant processing. No method of transmission or storage guarantees absolute security; users should protect access details and not share them with third parties.
Questions about the actual project-deletion process, logs, backups, or provider access should be asked separately. This page does not confirm characteristics that are not supported by verified documentation.
7. User rights and requests
A user may request information about the processing of their personal data, correction of inaccurate data, deletion or restriction of processing, and withdrawal of consent where processing is based on consent and withdrawal is permitted.
A request must contain enough information to identify the requester and the subject of the request. The Operator may ask for additional information to verify authority and may refuse or limit a request where the law permits. Responses are handled under applicable law and its time limits.
Use fluw@tungulov.space for requests. Do not include passwords, integration keys, payment details, or other secrets in an email.
8. Cookies and technical tools
The site may use necessary technical cookies and other browser storage for interface operation, navigation, and session protection. The exact set depends on the environment and enabled features.
This draft does not assert a specific analytics stack, advertising cookies, or third-party trackers. If optional tools are enabled in an environment, their purpose and available settings should be described in the relevant interface or separate notice.
9. Changes to this policy
A new version is published on this page with a revision date. For material changes, the Operator considers applicable law and, where required, notifies users by an available method.
The current version is available at fluw.ru/privacy for the Russian locale and fluw.space/privacy for the English locale. Questions about a particular version or the actual service behaviour can be sent to the Operator.