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Privacy Policy

Last updated: 31 March 2026

1. Data Controller

Company: ConsulenteCrediti Srl

VAT Number: IT06139990870

Tax Code: 06139990870

Registered Address: Via Ravanzusa N. 13, 95030 Tremestieri Etneo (CT), Italy

Contact Person: Alessandro Grasso

Email: [email protected]

PEC: [email protected]

SDI Code: SKUaY6

2. Introduction

ConsulenteCrediti Srl ("we", "us", "our") operates the FlowCRM platform (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service, in compliance with the EU General Data Protection Regulation (GDPR) — Regulation (EU) 2016/679 — and the Italian Legislative Decree No. 196/2003 (Privacy Code), as amended by Legislative Decree No. 101/2018.

By accessing or using FlowCRM, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

3. Data We Collect

3.1 Data You Provide Directly

  • Account registration data: name, email address, company name
  • Billing information: name, address, VAT number (processed via Stripe — we do not store card data)
  • Contact data you upload to the CRM: names, email addresses, phone numbers of your customers
  • Email campaign content and templates you create
  • Communications with our support team

3.2 Data Collected Automatically

  • Log data: IP address, browser type, pages visited, time and date of visits
  • Device information: hardware model, operating system, unique device identifiers
  • Usage data: features used, actions taken within the platform
  • Cookies and similar tracking technologies (see Cookie Policy)

4. Legal Basis for Processing (GDPR Art. 6)

PurposeLegal Basis
Providing the ServiceContract performance (Art. 6(1)(b))
Billing and invoicingLegal obligation (Art. 6(1)(c))
Security and fraud preventionLegitimate interest (Art. 6(1)(f))
Marketing communicationsConsent (Art. 6(1)(a))
Analytics and improvementLegitimate interest (Art. 6(1)(f))

5. Data Retention

We retain your personal data for as long as necessary to provide the Service and comply with our legal obligations:

  • Account data: retained for the duration of the contract plus 10 years (Italian civil law obligations)
  • Billing records: 10 years as required by Italian tax law (D.P.R. 633/1972)
  • Log data: 12 months
  • Marketing data: until consent is withdrawn
  • CRM contact data: as long as your account is active; deleted within 30 days of account termination

6. Data Sharing and Third Parties

We do not sell your personal data. We may share data with the following categories of processors, all bound by GDPR-compliant Data Processing Agreements (DPA):

  • IONOS SE (hosting infrastructure) — EU-based servers
  • Amazon Web Services (SES) (email delivery) — Standard Contractual Clauses in place
  • Stripe Inc. (payment processing) — PCI DSS Level 1 certified
  • Meta Platforms Inc. (WhatsApp Business API) — Standard Contractual Clauses in place

7. Your Rights Under GDPR

Under GDPR Articles 15–22, you have the following rights:

Right of Access (Art. 15)

Obtain a copy of your personal data we hold

Right to Rectification (Art. 16)

Correct inaccurate or incomplete data

Right to Erasure (Art. 17)

Request deletion of your data ('right to be forgotten')

Right to Restriction (Art. 18)

Limit how we process your data

Right to Portability (Art. 20)

Receive your data in a machine-readable format

Right to Object (Art. 21)

Object to processing based on legitimate interest

To exercise your rights, contact us at [email protected] or [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

8. Security Measures

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, in accordance with GDPR Article 32. These include: TLS/HTTPS encryption in transit, AES-256 encryption at rest, access control and role-based permissions, regular security audits, and incident response procedures. In the event of a data breach likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay.

9. International Data Transfers

Some of our third-party processors (e.g., Amazon SES, Stripe, Meta) may process data outside the European Economic Area (EEA). In such cases, we ensure adequate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission under GDPR Article 46(2)(c), or adequacy decisions where applicable.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or by posting a prominent notice on the Service. The "Last updated" date at the top of this page indicates when the policy was last revised. Your continued use of the Service after changes become effective constitutes your acceptance of the revised policy.

Contact Us

For any privacy-related questions or to exercise your rights:

ConsulenteCrediti Srl

Via Ravanzusa N. 13, 95030 Tremestieri Etneo (CT), Italy

Email: [email protected]

PEC: [email protected]