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Privacy Policy

Last updated: February 10, 2026

1. Data Controller

The data controller for personal data is:

2. Data Collected

We collect the following data through our contact form:

  • First name
  • Email address
  • Phone number (optional)
  • Company/sector information
  • Project description and voluntarily provided information

We also collect technical data through cookies (with your consent), including pages visited, browser type, and approximate location. See section 7 for details.

3. Purpose and Legal Basis of Processing

The data collected is processed for the following purposes and legal bases (GDPR Article 6):

  • Responding to your contact and quote requests — Legal basis: performance of pre-contractual measures (Art. 6(1)(b))
  • Providing information about our services — Legal basis: legitimate interest (Art. 6(1)(f))
  • Managing our business relationship — Legal basis: performance of a contract (Art. 6(1)(b))
  • Website analytics (Google Analytics) — Legal basis: consent (Art. 6(1)(a)), collected via our cookie banner

4. Data Retention

Your personal data is retained for a maximum period of 3 years from your last contact with SmartFlow LLC. Analytics data collected via Google Analytics is retained for 14 months. Cookie consent preferences are stored for 12 months.

5. Data Recipients and Sub-processors

Your data may be shared with the following categories of recipients:

  • Hetzner Online GmbH (Germany) — Web hosting
  • Google LLC (USA) — Google Analytics (with your consent only)
  • Cloudflare Inc. (USA) — CDN, DNS, and security services

We do not sell or rent your personal data to third parties.

6. International Data Transfers

SmartFlow LLC is a US-based company. When you submit data through our website, your information may be transferred to and processed in the United States.

For transfers from the EU/EEA to the US, we rely on:

  • The EU-US Data Privacy Framework for certified sub-processors (Google, Cloudflare)
  • Standard Contractual Clauses (SCCs) approved by the European Commission for other transfers

You can request a copy of the applicable safeguards by contacting us at [email protected].

7. Cookies and Tracking

Our website uses a cookie consent management platform (Tarteaucitron.js) that allows you to accept or refuse cookies before they are placed.

Essential cookies: Cookie consent preferences (tarteaucitron) — no consent required.

Analytics cookies (require consent): Google Analytics (G-PJ9R6N0SYC) — used to understand how visitors interact with our website. These cookies are only loaded after you give your explicit consent via the cookie banner.

You can modify your cookie preferences at any time by clicking on the cookie settings link at the bottom of any page, or by adding #cookies to the URL.

8. Your Rights

In accordance with the GDPR (Articles 15-22) and applicable regulations, you have the following rights:

  • Right of access (Art. 15) — obtain a copy of your personal data
  • Right to rectification (Art. 16) — correct inaccurate data
  • Right to erasure (Art. 17) — request deletion of your data
  • Right to restriction (Art. 18) — limit the processing of your data
  • Right to data portability (Art. 20) — receive your data in a structured format
  • Right to object (Art. 21) — object to processing based on legitimate interest
  • Right to withdraw consent (Art. 7) — withdraw consent at any time without affecting the lawfulness of prior processing

To exercise these rights, contact us at: [email protected]. We will respond within 30 days.

Right to lodge a complaint: If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. For residents of France, this is the CNIL (Commission Nationale de l’Informatique et des Libertés) — www.cnil.fr.

9. California Residents (CCPA/CalOPPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Online Privacy Protection Act (CalOPPA):

  • Right to know what personal information is collected
  • Right to request deletion of your personal information
  • Right to opt-out of the sale of personal information — we do not sell personal information
  • Right to non-discrimination for exercising your privacy rights

To exercise these rights, contact us at [email protected].

10. Security

SmartFlow LLC implements appropriate technical and organizational measures to protect your personal data, including: SSL/TLS encryption (HTTPS), HTTP security headers (HSTS, X-Frame-Options, X-Content-Type-Options), access controls, and regular security reviews.

11. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.