Privacy Policy
Last updated: 09/22/25
1. Introduction
Welcome, and thank you for your trust in Reflow (“we,” “our,” “us”).
We understand the importance of protecting personal data in the digital age, and we are committed to managing your data transparently, securely, and in full compliance with applicable laws and regulations.
This Privacy Policy describes how we collect, process, use, share, and protect personal information that you provide or that we collect through our website, the sales funnel for the Reset Your Flow digital bundle, the checkout process via Funnelish, and related email or marketing communications.
By using our services, you agree that your data will be processed in accordance with this Privacy Policy.
2. Data Controller
The data controller is Reflow [or your legal company name], headquartered at [insert full address] (EU Member State).
For any questions regarding this Privacy Policy or to exercise your rights under data protection law, you can contact us via the email address listed in the “Contact” section.
3. Types of Data Collected
a) Data Provided Directly by the User
When you purchase our digital bundle or subscribe to our newsletter, we may collect:
First and last name
Email address
Billing address (if applicable)
Information necessary to deliver the service
b) Data Collected Automatically
While browsing our site (hosted through Funnelish) and interacting with the funnel, we may automatically collect:
IP address
Device type, browser, and operating system
Access times and duration of visits
Pages viewed
Cookies or similar tracking technologies
c) Data from Third Parties
In some cases, data may come from partners or third-party services (e.g., payment processors such as Stripe or PayPal, or analytics tools integrated with the funnel).
d) Sensitive Data
We do not intentionally collect “sensitive” data such as racial origin, religious beliefs, sexual orientation, or health data, unless you voluntarily provide it and give explicit consent.
4. Purpose and Legal Basis for Processing
We process your data for the following purposes:
Service delivery (providing access to the digital bundle) — legal basis: performance of a contract or pre-contractual request.
Marketing communications such as newsletters and updates — legal basis: explicit consent, revocable at any time.
Platform management, security, and fraud prevention — legal basis: legitimate interest in maintaining platform integrity and protecting users.
Statistical analysis and service improvement — legal basis: legitimate interest in optimizing user experience.
5. Data Processing and Retention
Your data is processed electronically and stored using secure systems, with appropriate technical and organizational measures (access controls, logs, backups, encryption where applicable) to ensure confidentiality, integrity, and availability.
Retention periods include:
Purchase data (for legal/tax purposes): retained for the period required by law (e.g., 10 years).
Newsletter or contact data: retained until consent is withdrawn.
System logs and security data: retained for a reasonable period (e.g., 24 months) for security purposes.
6. Sharing Data with Third Parties
To provide our services, we may share data with:
Payment processors (e.g., Stripe, PayPal) to process transactions.
Hosting providers (e.g., Funnelish).
Email marketing and automation services (for sending newsletters).
Analytics and tracking tools (in anonymous or pseudonymized form).
In all cases, data will be processed in accordance with this policy and with agreements ensuring compliance with the GDPR.
7. International Data Transfers
If your data is transferred outside the European Economic Area (EEA), we will apply appropriate safeguards such as Standard Contractual Clauses or adequacy decisions to ensure GDPR compliance.
By using our services, you consent to the transfer, processing, and storage of your data in one or more countries outside your country of residence.
8. Your Rights
You have the right to:
Access your personal data.
Request rectification or completion of inaccurate or incomplete data.
Request deletion (“right to be forgotten”) in applicable cases.
Restrict processing under certain conditions.
Obtain data portability where applicable.
Object to processing for legitimate reasons.
Withdraw consent at any time, without affecting the lawfulness of prior processing.
To exercise your rights, please contact us at the email provided in the “Contact” section. We will respond within 30 days unless the request is complex.
9. Cookies and Tracking Tools
We use cookies and similar technologies to enhance your experience, analyze traffic, and personalize communications.
The types of cookies we use include:
Essential cookies: required for website operation.
Preference cookies: remember your choices (e.g., language, layout).
Analytics and marketing cookies: help us understand user behavior and send relevant communications (in anonymous or pseudonymized form).
You can manage cookie preferences via the on-site cookie banner or through your browser settings.
10. Data Security
We maintain appropriate technical and organizational security measures, including system updates, firewalls, encryption, regular backups, and restricted access to authorized personnel.
While we take strong precautions, no system is completely immune to errors or unauthorized access. In case of a personal data breach, we will notify you as required by law.
11. Minors
Our services are not intended for users under 16 years of age (or the age required in your country).
We do not knowingly collect data from minors without parental or guardian consent.
If we learn that we have inadvertently collected such data, we will promptly delete it.
12. Policy Updates
We may update this Privacy Policy to reflect legislative, business, or technological changes.
In the event of material changes, we will notify you via email or through a notice on our website.
The “last updated” date at the top will always indicate the latest version.
13. Links to Other Websites
Our site may contain links to external websites or platforms not operated by us.
We are not responsible for their privacy practices.
We recommend reviewing their privacy policies before submitting any personal data.
14. Legal References
This Privacy Policy is drafted in accordance with:
Regulation (EU) 2016/679 — General Data Protection Regulation (GDPR)
The ePrivacy Directive (2002/58/EC) and subsequent updates
Cookie Policy
1. What Are Cookies?
Cookies are small text files placed on your device when you visit a website. They store information used to improve performance, provide functionality, and analyze how visitors interact with the site.
2. How We Use Cookies
Reflow uses cookies to:
Enable essential site and checkout functionality.
Remember your language and user preferences.
Analyze site usage to improve performance.
Provide personalized marketing and promotions (where consented).
3. Types of Cookies We Use
Essential Cookies: Necessary for core website operations (e.g., checkout, login, security).
Performance Cookies: Track anonymous usage data to help improve user experience.
Functional Cookies: Store user preferences like language or display settings.
Marketing Cookies: Used for advertising and retargeting based on browsing activity.
4. Managing Cookie Preferences
When you visit our site, a cookie banner will appear allowing you to accept or customize cookie settings.
You can also block or delete cookies through your browser settings at any time.
Please note that disabling certain cookies may affect website functionality.
5. Third-Party Cookies
Some cookies are set by third-party services such as Google Analytics, Facebook Pixel, Stripe, or PayPal.
These third parties have their own privacy policies and may use cookies for their independent purposes.
6. Updates to This Cookie Policy
We may update this Cookie Policy periodically to reflect changes in law or technology.
Please check this page regularly for updates. Continued use of our site implies acceptance of the most recent version.