Refund policy
GrowWithFlows (a project by Userability OÜ)
Last updated: 17.02.2026
1. Data Controller
The data controller responsible for processing your personal data is:
Userability OÜ
Ahtri 12
10151 Tallinn
Estonia
Registration Number: 16132175
VAT ID: EE102329663
Email: inquiries@growwithflows.com
2. What Personal Data We Collect
We may collect and process the following categories of personal data:
- Name and contact details (email address, billing address)
- Company name and VAT ID (if applicable)
- Payment and transaction information
- Website usage data (IP address, browser type, device data)
- Marketing preferences and email engagement data
- Communication history (emails, support inquiries)
3. How We Collect Data
We collect data when you:
- Purchase a product or service
- Subscribe to our newsletter
- Book a consultation or strategy call
- Contact us via email or contact forms
- Browse our website (via cookies and analytics tools)
4. Legal Basis for Processing (GDPR)
We process your personal data under the following legal bases:
- Contract performance – to deliver purchased products and services
- Legal obligation – accounting and tax compliance
- Legitimate interest – improving services, fraud prevention
- Consent – email marketing and newsletters
5. Email Marketing & Klaviyo
We use email marketing platforms such as Klaviyo to manage newsletters, automated flows, and customer communication.
When you subscribe or purchase from us, your data may be stored and processed by Klaviyo in accordance with their data processing terms.
You can unsubscribe from marketing emails at any time using the unsubscribe link in the email.
6. Payments
Payments are processed through secure third-party payment providers. We do not store full credit card information.
7. Third-Party Services
We may share data with trusted third-party providers where necessary to operate our business:
- Shopify (e-commerce platform)
- Klaviyo (email marketing)
- Stripe / payment processors
- Zapier / Make.com (automation tools)
- Analytics providers (e.g., Google Analytics)
- Accounting and legal service providers
These providers process data only under contractual safeguards and in compliance with GDPR where applicable.
8. Cookies & Tracking
Our website may use cookies and similar technologies to:
- Ensure website functionality
- Analyze website performance
- Track conversions and marketing effectiveness
- Improve user experience
You can control cookie preferences via your browser settings.
9. Data Retention
We retain personal data only as long as necessary for:
- Contract fulfillment
- Legal and tax obligations
- Business documentation requirements
When data is no longer required, it will be securely deleted or anonymized.
10. Your Rights Under GDPR
You have the right to:
- Access your personal data
- Request correction of inaccurate data
- Request deletion of your data
- Restrict or object to processing
- Data portability
- Withdraw consent at any time
To exercise your rights, contact us at: [Insert Contact Email]
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse.
12. International Data Transfers
Some of our service providers may be located outside the European Economic Area (EEA). In such cases, data transfers are protected by appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.
13. Complaints
If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate or your local supervisory authority.
14. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website.
15. Contact
GrowWithFlows
Userability OÜ
Ahtri 12
10151 Tallinn
Estonia
Email: inquiries@growwithflows.com