Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

If you have any questions about how we handle your personal data, please contact us at Support@insight-flowai.com.

2. What Data We Collect

We collect and process the following categories of personal data:

3. Lawful Basis for Processing

Under Article 6 of the UK GDPR and EU GDPR, we process your personal data on the following lawful bases:

4. How We Use Your Data

We use the personal data we collect for the following purposes:

• Providing the Services: Storing and syncing your trading data, generating analytics and performance metrics, and delivering the core App functionality.
• AI-Powered Analysis: Processing your trading data through AI models to provide trade analysis, pattern recognition, and coaching suggestions (only with your explicit consent).
• Subscription Management: Verifying your subscription status, managing entitlements, and enforcing usage limits per your subscription tier.
• App Improvement: Analysing usage patterns to improve features, fix bugs, and optimise performance.
• Customer Support: Responding to your inquiries, resolving issues, and providing assistance.
• Security: Detecting, preventing, and addressing fraud, abuse, unauthorised access, and security incidents.
• Legal Compliance: Complying with applicable laws, regulations, and legal processes, and maintaining records as required by law.
• Communications: Sending essential service-related notifications (e.g., policy changes, security alerts). Marketing communications are only sent with your explicit consent.

5. Data Sharing and Third Parties

We do not sell your personal data. We share data with third parties only as necessary to provide the Services:

All third-party service providers are bound by Data Processing Agreements (DPAs) that ensure they process your data only on our instructions and in compliance with applicable data protection laws.

Additional Disclosure Circumstances

We may also disclose your personal data:

• Legal requirements: When required by law, court order, subpoena, or government investigation.
• Safety and protection: To protect the rights, safety, and property of our users or the public.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity. We will notify you of any such change in ownership or control.

6. International Data Transfers

Your personal data may be transferred outside the United Kingdom and European Economic Area (EEA). We ensure all international transfers are protected by appropriate safeguards:

• Supabase: Our primary database is hosted in the EU region, keeping your data within the EEA for day-to-day operations.
• Google (US): Transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission, supplemented by the UK International Data Transfer Addendum (IDTA) where applicable.
• Sentry: Configured to use EU data hosting, minimising international transfers.
• OpenAI: Transfers are governed by SCCs and our Data Processing Agreement.

Where data is transferred to countries that have received an adequacy decision from the UK Secretary of State or the European Commission, no additional safeguards are required.

You may request a copy of the safeguards we have in place by contacting Support@insight-flowai.com.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

After the retention period expires, data is securely deleted or irreversibly anonymised.

8. Your Rights

Under the UK GDPR and EU GDPR, you have the following rights regarding your personal data:

8.1 Right of Access (Article 15)

You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data. You can access all your trading data directly through the App at any time.

8.2 Right to Rectification (Article 16)

You have the right to request correction of inaccurate personal data. You can update your profile information and edit trade records directly in the App.

8.3 Right to Erasure (Article 17)

You have the right to request deletion of your personal data. You can delete your account through the App at Settings → Delete Account, and we will erase your data within 30 days, except where retention is required by law (e.g., consent records, billing records).

8.4 Right to Restriction of Processing (Article 18)

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

8.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format. You can export your trading data at any time using the App's export functionality.

8.6 Right to Object (Article 21)

You have the right to object to processing based on legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

8.7 Rights Related to Automated Decision-Making (Article 22)

We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you. Our AI features provide informational analysis only and do not make automated decisions about you.

8.8 Right to Withdraw Consent

Where processing is based on consent (AI analysis, marketing communications), you may withdraw your consent at any time through the App settings. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

How to Exercise Your Rights

You can exercise most of these rights directly through the App. For any requests you cannot fulfil through the App, or for any questions about your rights, contact us at Support@insight-flowai.com.

We will respond to your request within one month of receipt. If your request is complex or we receive a high volume of requests, we may extend this by a further two months, and we will inform you of any extension within the first month.

There is no fee for exercising your rights. However, if a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse the request.

9. Right to Complain

If you are not satisfied with how we handle your personal data or respond to your requests, you have the right to lodge a complaint with a supervisory authority:

We encourage you to contact us first at Support@insight-flowai.com so we can try to resolve your concern directly.

10. Children's Privacy

The App is not directed at and is not intended for use by children under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at Support@insight-flowai.com and we will take steps to delete such information promptly.

11. Cookies and Tracking Technologies

The App is a mobile application and does not use cookies.

We may use the following technologies on your device:

• Local Storage: To store App preferences and cached data locally on your device. This data does not leave your device.
• Push Notification Tokens: To deliver notifications you have opted into. You can manage notification permissions through your device settings.
• Analytics SDKs: To collect anonymised usage data for App improvement, processed on the basis of legitimate interest.

12. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected, the sources of collection, the purposes of processing, and the third parties with whom we share data.
• Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.
• Do Not Sell or Share: We do not sell or share personal information as defined by the CCPA/CPRA.
• Limit Use of Sensitive Personal Information: We only use sensitive personal information for purposes permitted under the CCPA/CPRA.

To exercise your CCPA/CPRA rights, contact us at Support@insight-flowai.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes:

• We will update the version number and effective date at the top of this policy.
• For material changes that affect your rights, we will notify you through an in-app notification.
• Material changes will require your re-acceptance before you can continue using the App.
• We will retain previous versions of this policy for your reference.

The effective date at the top of this policy indicates when the current version took effect.

14. Financial Disclaimer

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For data protection specific inquiries, please include "Data Protection" in the subject line of your email.