Privacy Policy

1. Scope of this Policy

This Policy applies to personal data processed in connection with the website clusterflowhq.com, including any information you send to us (e.g., your name, phone, and/or email) when contacting us or requesting a callback/consultation.

2. What personal data we collect

• Contact data submitted via forms: name, phone, email.
• Message content you type in forms.
• Technical data (examples): IP address, browser type, device identifiers, approximate location derived from IP, and pages viewed, for security and basic site operations.

3. How we use personal data

We process personal data for the following purposes:

• Responding to your inquiries and contacting you back regarding the services you request.
• Managing and improving our website and communications.
• Ensuring security, preventing fraud/abuse, and maintaining system integrity.

4. Legal basis for processing (Ukraine)

We process personal data under the Law of Ukraine “On Personal Data Protection” (Про захист персональних даних | від 01.06.2010 № 2297-VI). Depending on the situation, our legal basis may include performance of obligations related to your request, and/or your consent where required.

5. Consent, electronic messages, and marketing

If we send commercial electronic messages/newsletters by email/SMS/messengers, we generally do so only with your consent (opt-in), or under an applicable exception. You may withdraw consent at any time, using the contact details below.

Legal basis: Закон України "Про електронну комерцію".

6. Cookies and similar technologies

We may use cookies and similar technologies to operate the website and analyze its performance. For non-essential purposes, we use a cookie consent mechanism where required. You can manage your cookie preferences through the cookie settings provided on the website.

Where applicable, consent may be required before non-essential cookies are placed.

7. Data retention

We retain personal data only as long as necessary for the purposes described in this Policy and for as long as required by applicable laws and legitimate business needs (e.g., to respond to requests and resolve disputes). After that, we delete or anonymize data in line with our internal procedures.

8. Who we share data with

We may share personal data with service providers that process data on our behalf (e.g., hosting, IT services), based on instructions and confidentiality obligations. We will not sell your personal data.

9. Your rights

Under the Law of Ukraine “On Personal Data Protection” (Про захист персональних даних | від 01.06.2010 № 2297-VI), you may have rights such as access to your personal data, requesting correction or deletion, and other rights provided by law. To exercise your rights, contact our privacy team using the details below.

10. How to contact us (privacy requests)

For privacy requests, you can contact us at:

Business information

Business name: clusterflowhq.com (PE). Legal representative: Sara Petersen, Managing Director.

• EDRPOU registration code: 61729809
• VAT: Single tax payer; VAT optional.