سياسة الخصوصية

PRIVACY POLICY This Privacy Policy explains how Flow VIN Tune processes your personal data. It is written to meet the information requirements of Article 13 of the General Data Protection Regulation (GDPR), and it applies to your use of the Service described in our Terms of Service. Please also read the Terms of Service, the Tuning Disclaimer, and the AI Disclosure. 1. WHO WE ARE AND HOW TO CONTACT US The controller of your personal data is Flow VIN Tune, part of the Flow.VIN ecosystem ("Flow VIN Tune", "we", "us", "our"). We provide an AI-assisted, human-approved ECU tuning service: you upload your vehicle's original ECU file, the system proposes a Stage 1 or Stage 1+ calibration delta on recognised ECU families, and a human tuner reviews and approves every file before it can be downloaded. You can contact us about this Privacy Policy, or to exercise any of your rights, through the support options in your account, which you will find in the account menu and on your order pages. We have not appointed a Data Protection Officer; please use the support options in your account for any privacy matter. Our hosting, computing, and database processing take place in the European Union, in the Google Cloud region europe-west4 (the Netherlands). Some providers who help us run the Service are located outside the European Economic Area; see section 5. 2. WHAT WE PROCESS We process the following categories of personal data, which you provide directly or which are generated as you use the Service: - Account and sign-in data: your email address, display name, locale, and a unique account identifier (and, if you use Google sign-in, the identifier Google provides to confirm it is you). You can sign in with an email address and password or with Google sign-in; we require email verification. - Vehicle and order details: the make, model, year, and engine of your vehicle, and the intended use and jurisdiction you tell us, recorded for each order. - Your vehicle identification number (VIN): WE DO NOT KEEP YOUR RAW VIN; we store only a one-way SHA-256 hash of it. - Uploaded ECU files: the original ECU file you upload (the "Original File"), together with the working, approved, or rejected file versions produced during tuning. The approved file we make available to you is the "Delivered File". - Payment references: the transaction identifiers, amount, currency, and status we receive from our payment provider. WE NEVER STORE YOUR CARD NUMBERS; payment card details are handled by our payment provider, not by us. - Consent records: a tamper-evident record of each consent you give, captured at the pre-submission and pre-download checkpoints, including your user and order identifiers, the version and content hash of the exact legal text shown, the locale shown, a timestamp, and your IP address and device metadata. - Audit events: an immutable record of the state changes during your orders, kept so the history of each order can be reconstructed. - Support messages: the content of the support requests you send us, which may contain personal data you choose to include. - Transactional email data: the recipient address and message content used to send you account, order, and receipt emails. If you do not provide the data needed to perform the Service, in particular your account details, vehicle and order details, and the Original File, we cannot provide the Service to you. Providing it is a requirement of entering into and performing our contract with you. 3. WHY WE PROCESS YOUR DATA, AND OUR LEGAL BASES We process your personal data for the purposes below, stating the legal basis for each under Article 6(1) GDPR. - To create and operate your account, authenticate you, and manage roles and any organisation membership. Legal basis: performance of our contract with you (Article 6(1)(b)); and our legitimate interest in account security (Article 6(1)(f)). - To capture your vehicle and order details, process your uploaded Original File, generate a candidate calibration delta, have a human tuner review and approve files, deliver the Delivered File, and support reverting your vehicle to its original calibration. Legal basis: performance of our contract (Article 6(1)(b)). - To keep the Service secure, maintain file integrity through hashing, prevent fraud and abuse, and defend legal claims. Legal basis: our legitimate interests in security, data integrity, fraud prevention, and legal defensibility (Article 6(1)(f)). - To take payment for the Service and handle refunds and disputes. Legal basis: performance of our contract with you (Article 6(1)(b)); and our legitimate interest in managing fraud and payment disputes (Article 6(1)(f)). - To respond to your support requests and send transactional emails about your account and orders. Legal basis: performance of our contract with you (Article 6(1)(b)); and our legitimate interest in supporting and securing the Service (Article 6(1)(f)). - To record your consent at each checkpoint and to maintain an immutable consent and audit trail. Legal basis: your consent at the point you accept the relevant legal text (Article 6(1)(a)); compliance with a legal obligation, where the law requires us to retain these records (Article 6(1)(c)); and our legitimate interests in legal defensibility and in keeping a tamper-evident record of consent and state changes (Article 6(1)(f)). Where we rely on consent (Article 6(1)(a)), you may withdraw it at any time; this does not affect processing carried out before withdrawal, nor does it erase records we are permitted or required to keep as evidence (see sections 7 and 8). Where we rely on a legitimate interest (Article 6(1)(f)), you may object on grounds relating to your situation (see section 8). 4. WHO RECEIVES YOUR DATA We do not sell your personal data. We share it only with the service providers (processors and sub-processors) who help us operate the Service, and only as needed for the purposes above: - Google Cloud: hosting, computing, and database services, in the European Union, in the region europe-west4 (the Netherlands). - Firebase Authentication (a Google service): sign-in and identity, including Google sign-in. - Stripe: payment processing. We never store your card numbers; Stripe handles your card details. - Resend: delivery of transactional and receipt emails. - Anthropic: an advisory AI provider that produces a plain-language risk explanation. Anthropic receives ONLY analysis scores and metadata. ANTHROPIC NEVER RECEIVES YOUR ECU FILE CONTENTS OR RAW PERSONAL DATA. Your raw VIN is never sent to it. We may also disclose personal data where legally required, or to establish, exercise, or defend claims. 5. INTERNATIONAL TRANSFERS Our core hosting and processing take place in the European Union (europe-west4, the Netherlands). Some of the providers listed in section 4 may process personal data outside the European Economic Area. Where they do, we use providers that offer recognised transfer safeguards, such as the European Commission's Standard Contractual Clauses, so that your data continues to receive an appropriate level of protection. You can ask us which providers process data outside the EEA and what safeguards apply. 6. HOW WE PROTECT YOUR DATA We apply technical and organisational measures to protect your personal data, including: - encryption of data in transit and at rest; - least-privilege access that is logged; - default-deny, row-level security in our database, so each record is accessible only to those entitled to it; - write-once (WORM) storage for the Original File and the Delivered File, so those files cannot be altered or overwritten; - an immutable, tamper-evident audit trail of state changes; and - SHA-256 hashing to verify file integrity and to store your VIN as a one-way hash. 7. HOW LONG WE KEEP YOUR DATA We keep personal data only for as long as we need it. The criteria we use to decide how long are: how long your account is active; how long we need it to provide and support the Service and to handle reverts to stock; to take payment and manage refunds, disputes, and fraud; and how long we are required or permitted to keep it to meet our legal obligations and to establish, exercise, or defend legal claims. We keep our immutable consent and audit records, and the records that evidence the work performed on each order, for as long as that evidence may be needed. These form the legal record of your orders and of the consent you gave. 8. YOUR RIGHTS Under the GDPR you have the following rights in relation to your personal data (Articles 15 to 22). To exercise any of them, contact us through the support options in your account. We fulfil these requests with the help of an administrator; we do not offer self-service tools for every right. - Access (Article 15): you can ask for a copy of the personal data we hold about you. - Rectification (Article 16): you can ask us to correct inaccurate or incomplete data. - Erasure (Article 17): you can ask us to delete your personal data. When we act on an erasure request we anonymise the personal data in your account and order records. Certain immutable records are retained where Article 17(3) permits or requires it, namely the Delivered File for your orders and the consent and audit trail that evidence them; these are kept as the legal record and as evidence for claims. - Restriction (Article 18) and objection (Article 21): you have the right to ask us to restrict our processing, and to object to processing we carry out on the basis of our legitimate interests. These rights exist in law and you may exercise them by contacting us; we do not provide an automated, self-service tool for them. - Portability (Article 20): you can ask to receive the personal data you provided in a structured, commonly used, machine-readable format. Exercising these rights is free of charge in the ordinary case, and we respond within the GDPR's time limits. 9. COMPLAINTS If you believe we have not handled your personal data lawfully, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU or EEA country where you live or work or where you believe the issue arose. We would, however, appreciate the chance to address your concern first. 10. COOKIES AND TRACKING We use a single, strictly-necessary session cookie to keep you signed in. WE DO NOT USE ADVERTISING COOKIES, AND WE DO NOT USE ANALYTICS OR OTHER TRACKING TECHNOLOGIES IN THE SERVICE. Because the session cookie is strictly necessary to provide the Service you ask for, it does not require your consent. 11. AUTOMATED DECISION-MAKING We do not make decisions about you that are based solely on automated processing and produce legal effects concerning you or similarly significantly affect you (Article 22). The AI is advisory: it proposes a candidate calibration delta on recognised ECU families. A qualified human tuner independently reviews each proposal, has full authority to modify or reject it, and must explicitly approve a file before it can be downloaded. The AI proposes; a human decides. Through the support options in your account you can ask for a person to review a matter, express your view, and contest an outcome. The AI Disclosure explains this further. 12. CHILDREN The Service is directed at adults and is not intended for children. We do not knowingly process the personal data of children. If you believe a child has provided us with personal data, please contact us through the support options in your account so we can address it. 13. CHANGES TO THIS NOTICE We may update this Privacy Policy from time to time. Each version is identified by a version reference and a content hash, and earlier versions are preserved; we do not silently edit a published notice. Where a change materially affects how we process your personal data, we will bring it to your attention. The version in force at the relevant time is the one that applies to you. The English-language version of this Privacy Policy is the binding version. Where a translation is provided for your convenience, the English version prevails in the event of any difference.