1. Data Controller

Websfarm Ltd (UK) acts as the main Data Controller for FlowSphere. Partners OSItalia S.r.l. and Digenio Ltd may act as Joint Controllers for integrated systems and technical infrastructure.

Contact: hello@flowthesphere.com

2. Data We Collect

• Identity Data: name, company, email, phone number.
• Usage Data: IP address, browser type, pages visited, session duration.
• Form Data: messages, consent choices, marketing preferences.
• Technical Data: cookies, device identifiers, CRM identifiers.

3. Purpose of Processing

• Provide and improve our services.
• Analyze performance and user behavior.
• Respond to inquiries and provide support.
• Send updates, marketing communications, or system notifications (with consent).
• Ensure legal compliance and prevent misuse.

4. Legal Basis for Processing

• Consent (for marketing and cookies).
• Contract performance (to deliver our service).
• Legitimate interest (to maintain and secure the platform).
• Legal obligations (to comply with applicable laws).

5. Data Sharing

We may share data with:

• Our technical partners (OSItalia S.r.l., Digenio Ltd).
• Cloud service providers, analytics, or CRM systems.
• Legal authorities if required by law.

We do not sell personal data.

6. Data Retention

Data is retained only as long as necessary for the purpose collected, or as required by law. You may request deletion at any time.

7. Data Rights

You have the right to:

• Access your data.
• Request correction or deletion.
• Withdraw consent.
• Request data portability.
• File a complaint with the ICO (UK) or Garante Privacy (Italy).

Requests can be made to hello@flowthesphere.com.

8. Security

We use encryption (SSL), access control, and regular audits to protect your data.

9. International Transfers

Data may be transferred between the UK and EU. Such transfers are protected under GDPR adequacy decisions and standard contractual clauses.

10. Updates

We may update this policy. The date of the latest version will always be displayed.

Last updated: October 2025