Privacy Policy

1. Introduction

Welcome to Presenze. This Privacy Policy explains how FlowNordics ApS ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our mobile application (available on the Apple App Store) and web application (collectively, the "Service").

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws. By using Presenze, you agree to the collection and use of information in accordance with this policy.

2. Data Controller

The data controller responsible for your personal information is:

3. Information We Collect

3.1 Information You Provide

• Account Information: Name, email address, password, and profile information
• Content Data: Videos, scripts, captions, and other content you create or upload
• Payment Information: Billing details processed securely through Stripe (we do not store full credit card numbers)
• Communications: Messages you send to our support team

3.2 Automatically Collected Information

• Usage Data: Features used, time spent, interactions, and preferences
• Device Information: Device type, operating system, unique device identifiers, IP address
• Log Data: Access times, pages viewed, app crashes, and system activity
• Location Data: General location based on IP address (not precise geolocation)

3.3 Cookies and Tracking Technologies

Our web application uses cookies and similar tracking technologies to enhance your experience, analyze usage, and provide personalized content. You can control cookie preferences through your browser settings.

4. How We Use Your Information

We use your personal information for the following purposes:

• Service Delivery: To provide, maintain, and improve Presenze features
• AI Processing: To generate scripts, analyze trends, and provide AI-powered features using OpenAI, Google Gemini, and Anthropic
• Content Management: To store, process, and deliver your content and enable teleprompting and scheduling
• Payment Processing: To process credit purchases and manage your account balance
• Communication: To send service updates, respond to inquiries, and provide customer support
• Analytics: To understand usage patterns and improve our Service
• Security: To detect, prevent, and address fraud, abuse, and security issues
• Legal Compliance: To comply with legal obligations and enforce our Terms of Service

5. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

• Consent: You have given explicit consent for specific processing activities (e.g., marketing communications)
• Contract Performance: Processing is necessary to provide the Service you've requested
• Legal Obligation: Processing is required to comply with legal requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., fraud prevention, service improvement) while respecting your rights

6. Third-Party Services and Data Sharing

We share your information with trusted third-party service providers who assist us in operating our Service:

6.1 AI Service Providers

• OpenAI: For AI-powered script generation and content analysis
• Google Gemini: For AI-powered features and natural language processing
• Anthropic: For AI-powered content creation and analysis

These providers process your content data to deliver AI features. They have their own privacy policies and data protection measures.

6.2 Payment Processing

• Stripe: For secure payment processing and credit card transactions. Stripe is PCI-DSS compliant and handles all payment data securely.

6.3 Analytics and Performance

We use analytics services to understand how users interact with our Service and to improve performance and user experience.

6.4 Other Disclosures

We may disclose your information:

• To comply with legal obligations, court orders, or government requests
• To protect our rights, property, or safety, or that of our users
• In connection with a merger, acquisition, or sale of assets (with notice to you)
• With your explicit consent for other purposes

7. International Data Transfers

Your information may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our AI service providers operate. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions for certain countries
• Service providers' compliance with data protection frameworks

8. Data Retention

We retain your personal information for as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy:

• Account Data: Retained while your account is active and for 90 days after account deletion
• Content Data: Retained until you delete it or close your account
• Payment Records: Retained for 7 years for accounting and tax purposes
• Usage Data: Aggregated and anonymized data may be retained indefinitely for analytics

9. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data we hold
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restriction: Request limitation of processing in certain circumstances
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with your local data protection authority

To exercise any of these rights, please contact us at info@flownordics.com. We will respond to your request within 30 days.

10. Security Measures

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption of data in transit (TLS/SSL) and at rest
• Regular security assessments and updates
• Access controls and authentication mechanisms
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

11. Mobile App Permissions

Our iOS app may request the following permissions:

• Camera: To record videos for content creation
• Microphone: To record audio for videos and teleprompting
• Photo Library: To save and access your content
• Notifications: To send reminders and updates about scheduled content

You can manage these permissions in your device settings at any time. Denying permissions may limit certain features.

12. Cookies and Tracking (Web App)

Our web application uses cookies and similar technologies:

• Essential Cookies: Required for the Service to function (e.g., authentication, security)
• Analytics Cookies: Help us understand usage patterns and improve the Service
• Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings. Note that disabling certain cookies may affect functionality.

13. Children's Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at info@flownordics.com, and we will delete such information.

Users between 13 and 18 years old should have parental or guardian consent before using our Service.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by:

• Posting the updated policy on this page with a new "Last updated" date
• Sending an email notification to your registered email address
• Displaying an in-app notification

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

15. Contact Us

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

For GDPR-related inquiries or to exercise your rights, please use the email address above with "GDPR Request" in the subject line.

16. Supervisory Authority

If you are located in the EEA and have concerns about our data processing practices, you have the right to lodge a complaint with your local data protection authority. In Denmark, the supervisory authority is: