Privacy Policy

The controller of the personal data described in this policy is General Computing Solutions, the company that provides FlowSmartly, with its principal place of business at 132 Lincoln St, Pittsfield, MA 01201, USA. This policy covers FlowSmartly (“FlowSmartly”, “we”, “us”, “our”), and describes how we handle information when you visit our website, use our platform, attend our events, or communicate with us.

We are the controller for the data we collect in our own right: website visitors, prospects, event attendees, and the account, billing and support records of the people who administer a FlowSmartly workspace. Where a customer uploads their own contacts, leads or message recipients into the platform, that customer is the controller and we act as their processor — our GDPR & Data Protection page explains how those requests are handled.

Privacy questions and requests: privacy@flowsmartly.com, or write to us at the address above. There is one privacy team and it answers both.

We collect information in three ways:

We use the information we collect to:

If you are in the European Economic Area, the United Kingdom or Switzerland, we must have a legal basis for every purpose we process your data for. These are ours, purpose by purpose:

Where we rely on consent, you can withdraw it at any time and it is no harder to withdraw than it was to give. Withdrawing consent does not affect processing that already happened while the consent was valid.

We do not sell personal information for money, and we have never done so. We share information in these limited circumstances:

One case deserves naming plainly: if you allow the Marketing category on this website, limited online identifiers reach advertising partners so that we can tell which campaign earned a signup. California law calls that “sharing”. It is off until you turn it on, and section 8 explains how to turn it back off.

We keep personal information only as long as it is needed for the purpose it was collected for. In practice that means:

Where a legal hold, an investigation or an active dispute requires it, we keep the specific records involved until the matter closes. When a period ends, the data is securely deleted or irreversibly anonymized.

Depending on where you live, you may have the right to access, correct, delete, restrict, object to, or port your personal information, and to withdraw consent where we rely on it. California residents have the additional rights set out in section 8.

To exercise a right, email privacy@flowsmartly.com or use the contact form on this site. We will confirm who you are — usually by asking you to reply from the address we already hold, or to confirm details of the account — and we only ask for what is needed to be sure we are not handing your data to someone else. You may also use an authorized agent, provided we can verify their permission to act for you.

We answer within one month for GDPR requests and within 45 days for California requests. Where a request is genuinely complex we may extend once — by two further months under GDPR, or by a further 45 days in California — and we will tell you why before the original deadline passes. Requests are free unless they are manifestly unfounded or excessive.

This section is for California residents and describes our practices under the CCPA as amended by the CPRA. In the preceding twelve months we collected the following categories of personal information, from you, from your device as you use the site, from our customers, and from the partner and public sources described in section 2:

We disclose these categories to service providers and contractors for the business purposes described in section 5, and we retain them for the periods in section 6.

Your rights, and what each one means here:

We use administrative, technical, and physical safeguards to protect your information. While we strive to use commercially reasonable measures, no method of transmission or storage is 100% secure.

Our services are not directed to children under 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected such information, we will delete it.

FlowSmartly is based in the United States, and some of the subprocessors that deliver parts of the service operate elsewhere. Personal data originating in the EEA, the United Kingdom or Switzerland is therefore transferred outside those regions.

For those transfers we rely on the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914), on the UK International Data Transfer Addendum for transfers from the United Kingdom, and on the Swiss addendum recognized by the Federal Data Protection and Information Commissioner. We assess the destination country where the transfer calls for it, and we apply supplementary measures — encryption in transit and at rest, strict access control, and a commitment to challenge overbroad government requests — where they are needed to keep the protection equivalent.

A copy of the clauses we use is available on request from privacy@flowsmartly.com.

We may update this policy from time to time. We will post the updated policy and update the “Last updated” date above. Material changes will be communicated where required by law.

For questions about this Privacy Policy or our privacy practices, reach out to us: