Privacy Policy
Last updated: March 2026
At Safe-Flow, your privacy is our priority. This policy explains how we collect, use, and protect your personal information in compliance with the General Data Protection Regulation (GDPR — EU 2016/679).
Data Controller
The data controller is A-X Software SASU, 122 Rue Amelot, 75011 Paris, France (SIRET: registered in France). For any data protection inquiries, contact our Data Protection Officer at privacy@safe-flow.ai.
Information We Collect
We collect: (a) Account data you provide directly — email address, name, profile photo, language preference; (b) Usage data — breathing sessions, exercise history, progress, dashboard preferences, Coach Flo conversations; (c) Health data from connected devices (heart rate, HRV, stress levels) — only with your explicit consent; (d) Subscription data — Apple transaction identifiers, subscription status, purchase dates, and renewal information processed through Apple's In-App Purchase system. We do not receive or store your payment method details — all payment processing is handled exclusively by Apple.
Legal Basis for Processing (GDPR Art. 6 & 9)
We process your data based on: (a) Contract performance — to provide the Safe-Flow service you subscribed to (Art. 6.1.b); (b) Explicit consent — for health data processing and marketing communications (Art. 6.1.a / Art. 9.2.a); (c) Legitimate interest — for service improvement, security, and fraud prevention (Art. 6.1.f). You may withdraw your consent at any time via the app settings without affecting the lawfulness of prior processing.
Photos & Camera
When you choose to set a profile photo, we may request access to your device's camera or photo library. This access is entirely optional and only used for your profile picture. Profile photos are stored securely on our servers and are only visible to you. You can delete or change your profile photo at any time in the app settings.
How We Use Your Information
Your data is used to: personalize your breathing exercises and wellness experience; provide AI-powered coaching insights (Coach Flo); manage your subscription and verify purchases with Apple; track your progress and generate statistics; improve our services through anonymized analytics. We never sell your personal information to third parties.
Subscriptions & Payment Data
Safe-Flow offers optional paid subscriptions (Flow and Flow Pro) managed through Apple's In-App Purchase system. We store Apple transaction identifiers and subscription status to manage your access. We do not have access to your credit card number, Apple ID password, or any financial details — these are handled exclusively by Apple. Subscription data is retained for the duration of your subscription plus 12 months for accounting and legal obligations. You can manage or cancel your subscription at any time through your Apple ID settings.
Data Storage & Security
Your data is stored securely on servers located in the European Union (Railway, hosted in EU region). We use industry-standard encryption (TLS 1.2+ in transit, AES-256 at rest), secure authentication tokens, and regular security audits. Access to personal data is restricted to authorized personnel only.
Data Retention
Account data is retained for the duration of your account. Usage data (sessions, progress) is retained for 3 years from the date of collection. Health data is retained for 2 years or until you withdraw consent. Subscription transaction records are retained for 5 years for legal and accounting purposes. When you delete your account, all personal data is permanently erased within 30 days, except where retention is required by law.
Data Sharing & Transfers
We share data only with: (a) Apple — transaction identifiers for subscription verification; (b) Anthropic (Claude AI) — anonymized conversation data for Coach Flo (no personal identifiers transmitted); (c) Cloudinary — profile photo hosting (EU servers); (d) ElevenLabs — voice synthesis for guided audio (no personal data shared). We do not transfer data outside the EU/EEA except where service providers offer adequate safeguards (Standard Contractual Clauses).
Your Rights (GDPR Art. 15–22)
You have the right to: (a) Access — obtain a copy of your personal data (available via 'Export my data' in app settings); (b) Rectification — correct inaccurate data via your profile; (c) Erasure — delete your account and all data ('Delete account' in app settings); (d) Data portability — receive your data in a structured, machine-readable format; (e) Restriction — limit processing of your data; (f) Object — object to processing based on legitimate interest; (g) Withdraw consent — for health data and marketing, at any time via app settings. To exercise these rights, contact privacy@safe-flow.ai. We will respond within 30 days. You also have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés, www.cnil.fr).
Children's Privacy & Kids Mode
Safe-Flow includes a supervised "Kids Mode" designed for children to practice guided breathing exercises under parental control. In Kids Mode: (a) The child does not create their own account — the parent sets up a child profile within their own account; (b) Data collected is minimal: child's first name, breathing session history, mood feedback (emoji-based), and garden progress; (c) No personal identifiers, location data, or device data are collected from the child; (d) Access to parental settings is protected by a 4-digit PIN; (e) All child data is stored within the parent's account and deleted when the parent's account is deleted; (f) No advertising, external links, or third-party tracking is present in Kids Mode. Children under 16 should only use Safe-Flow under parental supervision. The parent is responsible for providing consent for their child's use of the service (GDPR Art. 8). If you believe a child has used Safe-Flow without parental authorization, please contact us at privacy@safe-flow.ai.
Contact Us
For any privacy-related questions or to exercise your rights, contact us at privacy@safe-flow.ai or write to: A-X Software SASU, 122 Rue Amelot, 75011 Paris, France.