Privacy Policy

• A business’s own account data (people who sign up for and administer Flowly): Flowly is the data controller.
• End customers’ data, meaning people who message, comment or leave details with a business and whose conversations that business manages in Flowly: Flowly processes the data on the business’s behalf and under its instructions. The business is the controller and Flowly is the processor.
• Each business gets its own dedicated system and data, separate from every other business.

(a) Information you give us

Account details (name, email, hashed password), contact details, demo or trial requests, and messages you send to our support team.

(b) Information from connected platforms

When a business connects a channel, we receive data through the platform’s official APIs and under the permissions the business grants. We request only the permissions needed for the features the business uses.

(c) Information collected automatically

IP address, browser and device information, system logs, cookies and local storage (for example, to remember your language preference).

(d) Content businesses enter

Customer records, deals, notes, tags and other data that a business enters or creates in Flowly.

We process data only for the purposes below, each based on a legal basis recognised by law.

For data we receive from Meta, Zalo, TikTok and other platforms, we commit that we:

• never sell personal data;
• do not use platform data for advertising, profiling or building user profiles outside the service;
• do not share it with data brokers;
• do not use customer conversation content to train AI models for third parties;
• use data only for the features the user or business has authorised;
• comply with the Meta Platform Terms and Developer Policies, the Zalo platform terms, and the TikTok Developer Terms of Service and Developer Guidelines;
• delete data when access is revoked, as described in Data deletion requests.

We share data only in the following cases:

• With the business you are interacting with, because that business is the controller of the conversation.
• With vetted service providers (cloud hosting, email delivery, AI model providers), under contract and processing data only on our instructions.
• With the platforms themselves (Meta, Zalo, TikTok) when we deliver messages and carry out actions a business requests.
• With competent authorities when the law requires it.
• In a merger, acquisition or restructuring, with prior notice, and the data stays protected under this policy.

Storage location: servers in a data centre in Singapore.

Security measures: encryption in transit and at rest, role-based access control with least privilege, access logging, and a separate system instance for each business.

International transfers: Flowly’s servers are located in Singapore, so personal data is stored and processed outside Vietnam. These transfers follow the cross-border transfer requirements of Law 91/2025/QH15, including the required impact assessment dossier, contracts with our infrastructure provider and the safeguards described above. The same applies when any other service provider of ours processes data abroad.

Data breaches: if a personal data breach occurs, we notify the competent authority (the specialised personal data protection agency under the Ministry of Public Security) within 72 hours as the law requires, and we notify affected parties.

Under Law 91/2025/QH15, you have the right to:

• be informed about how your personal data is processed;
• consent or refuse to consent to processing;
• withdraw your consent;
• access your data and receive a copy;
• rectify your data;
• delete your data;
• restrict processing;
• object to processing;
• complain, report, and bring a claim for damages as provided by law.

How to exercise them: send a request to privacy@flowly.123giaiphap.com, saying which right you want to exercise and giving us enough information to verify your identity. We respond within the time limit set by law, normally no later than 72 hours after receiving a valid request.

If you are an end customer of a business that uses Flowly, you can contact that business directly or contact us, and we will coordinate with the business to handle your request.

You can ask us to delete the data Flowly holds, including data received from Facebook, Instagram, Zalo and TikTok. This section works on its own as our Data Deletion Instructions.

1. 1
   Email your request

   Email privacy@flowly.123giaiphap.com with the subject “Data deletion request”. Include the account, Page, OA, or platform user ID you want removed.

2. 2
   Revoke access on the platform

   • Facebook: Settings & privacy → Settings → Business integrations (or Apps and websites) → remove Flowly.
   • Instagram: Settings → Website permissions (or Apps and websites) → remove Flowly.
   • Zalo: unfollow or block the OA; to revoke app access, go to Settings (Cài đặt) → Privacy (Quyền riêng tư) → Apps (Ứng dụng) → Remove (Gỡ).
   • TikTok: Settings and privacy → Security → Manage app permissions → remove Flowly.

   Menu names and paths may vary by app version.

3. 3
   We confirm and delete

   We confirm we received your request within 72 hours, complete the deletion within 30 days, and send you a confirmation when it is done.

When Meta, TikTok or Zalo notifies us of a deauthorisation or a user’s deletion request, we delete the related data within the same timeframe.

We use essential cookies so the website and platform work, and the browser’s local storage to remember your language preference.

You can view, block or delete cookies and local storage in your browser settings. Analytics tools are used only if enabled, and then only with your consent.

Our service is for businesses and is not directed to children under 16. Processing the data of anyone under 16 requires the consent of a parent or guardian. If we learn that we hold data of a child under 16 without guardian consent, we will delete it.

We may update this policy. For material changes we will give notice on this page and by email to business users. Current effective date: 28 October 2026; last updated: 28 October 2026.

Users of Meta (Facebook, Messenger, Instagram), Zalo and TikTok, and anyone with a question about personal data, can reach us directly through the channels below. Questions about the contract and use of the service are covered in our Terms of Service.