1. Who We Are
FlowSale ("we", "us", "our") is a South African software-as-a-service business providing a Point of Sale application for Android devices.
We act as the Responsible Party (as defined under the Protection of Personal Information Act 4 of 2013, "POPIA") for personal information processed through our website and application.
Name: [Information Officer Name]
Email: privacy@flowsale.co.za
Address: [Your Business Address], South Africa
2. Information We Collect
We collect information in two ways: information you provide to us directly, and information collected automatically.
2.1 Information You Provide
- Account information: Your name, email address, phone number, and business name when you sign up, start a Free Trial, subscribe, or submit an enquiry.
- Trial registration: When you register for a Free Trial, we collect your name, email address, phone number, business name, and preferred subdomain or custom domain. No payment information is collected during Free Trial sign-up.
- Payment information: Billing details required to process your subscription. Payment card data is handled directly by our payment processor and is never stored on our servers. Payment information is only collected when you activate a paid Subscription.
- Communications: Any messages, customisation requests, or support enquiries you send to us.
- Licence activation: Your licence key and the device identifier used to register your tablet with our system.
2.2 Information Collected Automatically
- Device information: A unique device identifier generated by the FlowSale app on first installation. This identifier is stored encrypted on your device and used solely for licence validation.
- Usage data: Basic technical data such as app version, operating system version, and licence validation timestamps.
- Website data: When you visit our website, standard server logs may record your IP address, browser type, pages visited, and referring URL.
2.3 Information We Do Not Collect
We do not collect, store, or process your business transaction data — including customer names, order histories, product details, or payment records processed through the FlowSale app. This data resides solely on your device and your own business systems.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Providing our services: To create and manage your account, issue licence keys (including Trial Licence Keys), process subscription payments, and deliver app updates.
- Free Trial administration: To activate your 7-day Trial Licence, send you access credentials, and remind you before the Trial Period expires. If you selected add-ons (custom domain or email hosting) during trial sign-up, we retain that preference to provision those services if and when you convert to a paid Subscription.
- Licence validation: To verify that a device is authorised to access the FlowSale application and to enforce device limits.
- Customer support: To respond to your enquiries, troubleshoot issues, and process customisation requests.
- Communications: To send you important service notifications, licence expiry reminders, and updates to this policy. We do not send unsolicited marketing emails.
- Improving our services: To analyse usage patterns in aggregate (non-personally identifiable) form to improve the application and website.
- Legal compliance: To meet our obligations under applicable South African law, including POPIA and the Electronic Communications and Transactions Act.
4. Legal Basis for Processing
Under POPIA, we process your personal information on the following lawful grounds:
- Contract performance: Processing necessary to provide the services you have subscribed to.
- Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention and service improvement, where these interests are not overridden by your rights.
- Legal obligation: Processing necessary to comply with a legal obligation.
- Consent: Where we ask for your consent for a specific purpose (such as optional marketing communications), processing is based on that consent, which you may withdraw at any time.
6. Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.
- Active accounts: Personal information is retained for the duration of your subscription and for a reasonable period thereafter to handle any post-cancellation queries.
- Free Trial accounts (not converted): If you complete a Free Trial and do not convert to a paid Subscription, we will delete or anonymise your account data within 90 days of Trial Period expiry, unless you contact us or we are required to retain it for legal purposes.
- Cancelled accounts: We typically delete or anonymise account data within 12 months of subscription cancellation, unless a longer retention period is required for legal or accounting purposes.
- Device identifiers: Retained for the duration of an active device licence. Removed when a device is deregistered or the associated licence expires and is not renewed.
- Support communications: Retained for up to 3 years from the date of the communication.
7. Your Rights Under POPIA
As a data subject under the Protection of Personal Information Act, you have the following rights:
- Right to access: You may request a copy of the personal information we hold about you.
- Right to correction: You may request that we correct any inaccurate or incomplete information.
- Right to deletion: You may request deletion of your personal information, subject to certain legal retention obligations.
- Right to object: You may object to the processing of your personal information on grounds of legitimate interests.
- Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
- Right to complain: You have the right to lodge a complaint with the Information Regulator of South Africa if you believe your rights have been infringed.
Website: www.inforegulator.org.za
Email: inforeg@justice.gov.za
To exercise any of the above rights, please contact our Information Officer using the details in Section 14. We will respond within 30 days of receiving your request.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:
- Encrypted storage of credentials on-device using Android's EncryptedSharedPreferences.
- Secure HTTPS communication between the app and our servers.
- Access controls limiting employee access to personal data on a need-to-know basis.
- Regular review of our security practices.
No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in harm to you, we will notify you and the Information Regulator as required by POPIA.
10. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review the privacy policies of any third-party sites you visit.
11. Children's Privacy
Our services are intended for use by businesses and are not directed at children under the age of 18. We do not knowingly collect personal information from individuals under 18. If you believe we have inadvertently collected such information, please contact us immediately and we will take steps to delete it.
12. Cross-Border Transfers
Some of our service providers may be located outside South Africa. Where we transfer personal information to another country, we take steps to ensure that appropriate safeguards are in place to protect your information in accordance with POPIA, including ensuring the recipient country provides an adequate level of protection or entering into data transfer agreements.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you by email (using the address on your account) and update the "Last updated" date at the top of this page.
Your continued use of our services after the effective date of any changes constitutes your acceptance of the updated policy. We encourage you to review this policy periodically.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information, please contact our Information Officer:
Email: privacy@flowsale.co.za
Address: [Your Business Address], South Africa
Phone: [Your Phone Number]
We will acknowledge your request within 3 business days and aim to fully respond within 30 days.