PRIVACY POLICY (incorporating the DPA)

1. Scope and Roles (Controller vs. Processor)

This Privacy Policy outlines how your personal data is collected, stored, and managed when using our services.

StyleFlo as a Data Controller: For any information you provide to set up and manage your StyleFlo SaaS account (including administrative contact details, staff profiles, billing addresses, and sitemaps), wp-123 is the Data Controller.
StyleFlo as a Data Processor: When your end-consumers interact with your website chatbot (FloChat), social channels (WhatsApp/Instagram), or call your Voice AI phone receptionist (FloVoice), you are the Data Controller, and StyleFlo acts as the Data Processor processing this consumer data on your explicit instruction.

2. Personal Data We Collect as a Controller

When you register on app.styleflo.ai, we collect and store:

Account Credentials: Business name, owner names, telephone numbers, business email addresses, and secure hashed passwords.
Platform Metadata: Website URLs, crawled sitemap indices, operating hours, and service catalogs.
Payment Records: Billing addresses and Stripe payment identifiers.
Dashboard Performance Data: Session statistics, click-through rates, and messaging usage metrics.

This information is processed to authenticate your session, deliver system notifications (such as hitting 85% of your plan's message cap), and manage billing.

3. Customer Data We Process as a Processor (The DPA)

When an end-consumer interacts with your automated channels, StyleFlo processes the following data on your behalf:

Identification Records: Consumer names, phone numbers, and email addresses collected during appointment scheduling or RAG intake queries.
Written Transcripts: Complete conversational text logs of web widget, WhatsApp, and Instagram interactions.
Audio Recordings & Voice Logs: High-fidelity audio call recordings, call duration metadata, and speech-to-text transcriptions generated during phone receptionist calls.

4. Multi-Tenant Row-Level Security (RLS) & Technical Architecture

To guarantee absolute compliance with the UK General Data Protection Regulation (UK GDPR), StyleFlo implements a secure, isolated database architecture:

UK Data Residency: All databases, indexed vector stores (pgvector), and Next.js serverless functions are deployed on Google Cloud Platform (GCP) inside the europe-west2 region (London, UK).
Row-Level Security (RLS): Every table in our Supabase PostgreSQL database (including user profiles, chatbot configurations, vector embeddings, sitemaps, and conversations) is configured with strict Row-Level Security. Every single query is authenticated and dynamically constrained to matching tenant_id hashes. A chatbot, stylist, or admin from Business A can never query, read, or leak data belonging to Business B.
AI Model Sovereignty: StyleFlo utilizes vertex and Gemini API models. We enforce strict data policies with our LLM partners: your private customer transcripts and uploaded knowledge documents are never utilized to train public foundational AI models.

5. Subprocessor Infrastructure & Third-Party Handoffs

To deliver real-time, low-latency conversational processing across web, social, and telephony channels, StyleFlo orchestrates secure data handoffs to the following vetted subprocessors:

Subprocessor	Core Purpose	Data Handling & Location
Google Cloud	Core PostgreSQL database (pgvector), serverless compute (Cloud Run), and Vertex AI (gemini-2.5-flash).	London, UK ( europe-west2 ). Full UK data residency compliance.
Twilio Inc.	Telecom SIP trunking, A2P SMS carrier routing, and geographic phone number allocation.	US / UK. Governed by Standard Contractual Clauses (SCCs).
Vapi, Inc.	Real-time WebRTC voice call orchestration, latency optimization, and stream routing.	US / UK. Transients stream via EU/UK endpoints; call data automatically purged post-call via API.
ElevenLabs, Inc.	Text-to-speech natural voice synthesis.	Non-EEA. Covered by EU/UK DPAs; opted out of model training on custom API keys.
Deepgram, Inc.	Real-time automatic speech recognition (Speech-to-Text).	US / UK. Real-time transient audio parsing only; no persistent storage.
Cloudflare, Inc.	Edge middleware routing, DDoS protection, and Cloudflare Turnstile bot challenges.	Global / UK. Processes transient IP and request headers under SCCs.
Stripe, Inc.	Payment processing, subscription billing management, and customer invoicing.	US / UK. Full PCI-DSS Level 1 compliance and SCC coverage.
Meta Platforms, Inc.	Carrier routing for Instagram DMs and WhatsApp business conversations.	US / UK. Governed by Meta Business Terms and 24-hour messaging window rules.

> Data Minimization & Model Training Guarantee: None of the third-party AI sub-processors listed above are permitted to use your business data, customer transcripts, or voice audio to train public AI models. All real-time streaming data on third-party voice platforms (Vapi/Deepgram) is subject to automated post-session API deletion triggers to enforce strict storage limitation principles under UK GDPR Article 5(1)(e).

6. GDPR Data Subject Rights (DSAR) & Automated Erasure Module

Under the UK GDPR and the Data Protection Act 2018, individuals retain the right to request access to or complete erasure of their personal records ("The Right to be Forgotten").

Centralized DSAR Portal: StyleFlo provides a dedicated compliance module within our /superadmin interface. This allows us to instantly query our multi-tenant PostgreSQL partitions, locate every log, vector chunk, or message history containing the requesting user's email or telephone number, and execute a secure, cascading deletion.
Cascade Wiping: Once authorized, the platform executes a cascading deletion that completely sweeps the records from our primary Supabase tables, clears cached memory indexes, and removes their identity from our active subprocessor queues.

7. The Regulatory and Legal Hold Check Exception

Because StyleFlo serves beauty salons, cosmetic clinics, and aesthetic spas, our data erasure workflows include a critical safety gate:

The Business & Regulatory Hold Check: Prior to executing a permanent cascade delete, the system issues a warning to the business subscriber. Cosmetic and aesthetic service providers are subject to strict UK statutory financial, medical, and clinical history retention laws.
Selective Partitioning: If the salon owner flags a customer record as subject to an active regulatory, tax, or medical insurance hold, StyleFlo will immediately scrub all operational chat logs, tracking pixels, and customer marketing tags. However, the transaction records, invoice copies, and treatment forms will be securely partitioned into a restricted-access, read-only legal archive until the statutory retention period concludes.