Table of contents
1. Data controller
The data controller is Napfény Zamata Kft. (hereinafter: "Provider"), operating the websites and services available under the flowwe.eu domain and its subdomains, under the brand name FLOWWE.
- Registered name: Napfény Zamata Kft.
- Registered address: 1182 Budapest, Hímesháza utca 24., Hungary
- Tax ID: 1255810-2-42
- Contact email: info@flowwe.eu
- Website: flowwe.eu
The Provider ensures that all data processing activities comply with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).
2. Data collected
2.1. Data submitted via forms
On our lead-generation pages (e.g. quote request forms), we may collect the following data:
- Name
- Email address
- Phone number
- Website URL
Upon form submission, the data is processed through the AffiAgent system and synchronized to the FLOWWE API (CRM synchronization). Legal basis: consent (GDPR Article 6(1)(a)).
2.2. AI Audit service (web audit, email audit)
When using the free AI audit tools, the user provides the URL of the website to be analyzed. The system forwards this URL to the AI Audit API, which performs a technical analysis. The analysis results are stored temporarily (24-hour cache). Legal basis: legitimate interest (GDPR Article 6(1)(f)) — data processing necessary for providing the service.
2.3. Automatically collected data
During website visits, we may automatically collect the following data:
- IP address (anonymized in Google Analytics)
- Browser type and version
- Device type (desktop / mobile / tablet)
- Operating system
- Visit time, page views, session duration
- Referring URL (where the visitor came from)
4. Google Consent Mode v2
The website uses the Google Consent Mode v2 standard, which allows Google services to respect the user's consent decisions.
How it works
When the page loads, Google tags run in restricted mode by default (no cookies are stored and full measurement data is not sent until consent is granted):
- analytics_storage — analytics cookie storage (default: denied)
- ad_storage — advertising cookie storage (default: denied)
- ad_user_data — user data forwarding for advertising (default: denied)
- ad_personalization — personalized ad display (default: denied)
The consent process
A cookie banner is displayed to the visitor. If the user accepts, the above parameters are set to granted, and Google tags operate with full functionality. If the user declines, the parameters remain denied — Google then uses modeled data for conversion estimation but does not store identifying cookies.
5. Data sharing with third parties
The Provider may share data with the following third parties, exclusively for the stated purposes:
5.1. Google LLC (United States)
- Google Analytics 4 — website usage statistics
- Google Ads — ad conversion tracking and remarketing
- Google Tag Manager — tag management infrastructure
- YouTube Data API — video publishing and channel management (see Section 6)
Legal basis for data transfer: user consent (cookie banner acceptance) and Google's privacy policy. For data transfers outside the EU, Google applies Standard Contractual Clauses (SCCs) approved by the European Commission.
5.2. Meta Platforms, Inc. (United States)
- Facebook/Meta Pixel — ad conversion tracking, audience building
Legal basis for data transfer: user consent. Meta's privacy policy: facebook.com/privacy/policy.
5.3. FLOWWE API (CRM)
Data submitted via forms is processed by FLOWWE's internal API, operated by the Provider. This data is not shared with third parties; processing and storage occurs within the EU.
6. YouTube API services
FLOWWE uses YouTube API Services to enable businesses to manage and publish video content to their connected YouTube channels from within the FLOWWE platform.
6.1. Data accessed
When a user connects their YouTube account, the application may access:
- YouTube channel information (channel name, ID)
- Ability to upload videos to the connected channel
- Read-only access to channel data (video list, statistics)
6.2. How data is used
YouTube account data is used exclusively to:
- Display the connected channel name within the FLOWWE dashboard
- Upload video content scheduled by the user to their YouTube channel
- Show upload status and basic video statistics
FLOWWE does not share YouTube data with any third party. OAuth tokens are stored securely and used only to perform the actions described above.
6.3. Revoking access
Users can disconnect their YouTube account at any time through the FLOWWE social accounts settings. Upon disconnection, all stored OAuth tokens and channel data are deleted from our systems.
Users can also revoke FLOWWE's access directly through Google Account Permissions.
FLOWWE's use of YouTube API data is subject to the Google Privacy Policy.
7. User rights
Under the GDPR, every user is entitled to the following rights:
- Right of access — you may inquire about what personal data we process and request a copy.
- Right to rectification — you may request correction of inaccurate or incomplete data.
- Right to erasure ("right to be forgotten") — you may request deletion of your personal data when the legal basis for processing has ceased.
- Right to restriction of processing — you may request suspension of processing in certain cases.
- Right to data portability — you may request your data in a structured, machine-readable format.
- Right to object — you may object to processing based on legitimate interest at any time.
- Withdrawal of consent — you may withdraw consent-based processing at any time. Withdrawal does not affect the lawfulness of prior processing.
Modifying cookie consent: delete your browser cookies, and the cookie banner will reappear on your next visit.
If you believe your data processing rights have been violated, you may file a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):
- Website: naih.hu
- Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary
- Phone: +36 1 391 1400
- Email: ugyfelszolgalat@naih.hu
8. Contact
For privacy-related questions or requests, please contact us at:
- Email: info@flowwe.eu
- Website: flowwe.eu
We respond to inquiries within 30 days.
9. Changes
The Provider reserves the right to modify this policy. In case of changes, the updated policy will appear at flowwe.eu/privacy-policy/ with a revised date. We will notify users of significant changes on our website.
We recommend reviewing this policy regularly.