Privacy Policy

1. What is the purpose of this Privacy Policy?

FLUGIA attaches great importance to the protection and confidentiality of your personal data. This Privacy Policy reflects our commitment to comply with applicable data protection regulations, and in particular the General Data Protection Regulation (GDPR) where applicable.

This Policy aims to inform you about how we process your personal data and the reasons why we do so in the context of the services we provide — namely a platform of specialized AI co-workers (Marketing, Sales, Support, HR, Legal, etc.) that connect to your existing business tools to automate tasks and improve team productivity.

2. Who does this Privacy Policy apply to?

This Privacy Policy applies to you, regardless of your country of residence, as long as you are at least 16 years old and use the FLUGIA platform (flugia.com).

If you are under the minimum legal age, you are not authorized to use our services without the prior and explicit consent of one of your parents or legal guardian, which must be sent to us by email at: privacy@flugia.com.

If you believe we hold personal data about your children without having consented to it, please contact us at the address above.

3. Why do we process your personal data and on what legal basis?

We process your personal data primarily for the following purposes:

• To provide and operate the FLUGIA platform, including access to AI co-workers (David, Emily, Edouard, and others) that automate tasks across your business departments — based on our Terms & Conditions.
• To manage your user account (creation, access, deletion) — based on our Terms & Conditions.
• To connect your existing business tools (CRM, email, calendar, support platforms, etc.) to FLUGIA's AI agents — based on our Terms & Conditions.
• To verify the accuracy of information provided during registration — based on our legal obligations.
• To communicate with you via our support channels, chat, or contact form — based on our Terms & Conditions.
• To process online payments — based on our Terms of Sale.
• To send you technical emails essential to the proper functioning of the service (e.g., password resets, account notifications) — based on our Terms & Conditions.
• To allow you to upload and import documents onto our platform — based on our Terms & Conditions.
• To use generative AI features that assist you with marketing, sales, customer support, HR, legal, and other business tasks — based on our Terms & Conditions.
• To ensure the daily security and quality of our services (statistics, data security, etc.) — based on our legal obligations, Terms & Conditions, and our legitimate interest in ensuring proper service operation.

Your data is collected directly from you as a user of the FLUGIA platform. We commit to processing your data only for the purposes described above.

4. What personal data do we process and for how long?

Below is a summary of the categories of personal data and their respective retention periods:

• Personal identification data (e.g., first name, last name) and contact information (e.g., email address) for individual users — retained for the full duration of service provision plus applicable legal limitation periods (generally 5 years).
• Professional identification data (e.g., name, position, company) and professional contact details for business users — retained for the full duration of service provision plus applicable legal limitation periods (generally 5 years).
• Financial and economic data (e.g., bank account details, verification codes) for individual users — retained for the duration necessary for transaction processing and billing management, plus legal limitation periods (generally 5 to 10 years).
• Financial and economic data for professionals where the business name coincides with the individual's name (e.g., sole traders, micro-enterprises) — retained for the same period as above.
• Email address used for technical communications — retained until account deletion.
• Content entered by the user (text, prompts, requests, documents, task configurations) during use of AI co-workers — retained for the full duration of service.
• Connection data (e.g., logs, IP address) — retained for a period of 1 year.
• Business and financial situation data — retained until account deletion, then for a 5-year limitation period.

Upon expiry of the applicable retention periods, deletion of your personal data is irreversible and we will no longer be able to provide it to you. We may only retain anonymized data for statistical purposes.

Please note that in the event of a dispute, we are obliged to retain all data relating to you for the entire duration of proceedings, even after the expiry of the retention periods described above.

5. What rights do you have to control the use of your personal data?

Applicable data protection law grants you specific rights that you may exercise, at any time and free of charge, to control how we use your data:

• Right of access and copy of your personal data, provided this does not conflict with business confidentiality or correspondence secrecy.
• Right of rectification of personal data that is inaccurate, outdated, or incomplete.
• Right to erasure ('right to be forgotten') of personal data that is not essential to the proper functioning of our services.
• Right to restriction of processing, allowing you to freeze the use of your data in the event of a dispute regarding the legitimacy of the processing.
• Right to data portability, enabling you to retrieve part of your personal data in order to store or transfer it from one information system to another.
• Right to provide instructions regarding what happens to your data in the event of your death, either directly or through a trusted third party or beneficiary.

To exercise any of these rights, you must submit your request directly to: privacy@flugia.com. Requests made by any other means cannot be processed.

Requests can only come from you personally. We may therefore ask you to provide proof of identity if we have any doubt about the identity of the requester.

We will respond to your request as quickly as possible, with a maximum response time of three months from receipt, in cases where the request is technically complex or we receive a high volume of requests simultaneously.

Please note that we may decline to respond to any request that is excessive or unfounded, in particular due to its repetitive nature.

6. Who may have access to your personal data?

Your personal data is processed by our teams and our technical service providers solely for the purpose of operating our service.

We carefully vet all our technical service providers before engaging them to ensure they strictly comply with applicable data protection regulations.

FLUGIA GUARANTEES THAT WE NEVER TRANSFER OR SELL YOUR DATA TO THIRD PARTIES OR COMMERCIAL PARTNERS.

7. Can your personal data be transferred outside your jurisdiction?

FLUGIA processes user data in compliance with international data protection standards. We make every effort to ensure that our technical infrastructure and tool providers implement appropriate safeguards to ensure the confidentiality and protection of your personal data.

Where personal data is transferred to countries outside the European Economic Area (EEA) or your applicable jurisdiction, we ensure that such transfers are governed by appropriate legal mechanisms (e.g., Standard Contractual Clauses, adequacy decisions).

8. How do we protect your personal data?

We implement the following technical and organisational measures to ensure the daily security of your personal data and to guard against any risk of destruction, loss, alteration, or disclosure:

Technical security measures

• Separation of password databases from user identifiers
• Mandatory complex passwords enforced at login
• HTTPS protocol for all data transmissions
• Access traceability and audit logging
• VPN access for FLUGIA team members
• Encrypted storage of sensitive credentials
• Regular security audits and penetration testing

Organisational security measures

• Access control policies and role-based permissions
• Information systems charter for all team members
• Data breach management procedure
• Individual rights management procedure
• Code of conduct and acceptable use rules
• Team security awareness training, conducted twice a year

9. How is your data used by FLUGIA's AI co-workers?

FLUGIA respects the confidentiality of your data accessed through our AI agents and platform integrations. We want to assure you that all user data processed through FLUGIA's AI co-workers is used exclusively to provide and improve the specific features of the FLUGIA platform as intended for you.

MORE SPECIFICALLY, WE DO NOT USE ANY USER DATA PROCESSED THROUGH OUR PLATFORM TO DEVELOP, IMPROVE, OR TRAIN GENERALIZED ARTIFICIAL INTELLIGENCE (AI) OR MACHINE LEARNING (ML) MODELS. Our objective is to deliver a useful and secure experience within the context of FLUGIA, without exploiting your data for broader AI/ML development purposes.

When FLUGIA's AI agents connect to your third-party tools (e.g., CRM, email, calendar, support platforms), access to such integrations is governed by the respective platform's API terms and by the permissions you explicitly grant. We only request the minimum permissions necessary to deliver the requested service.

10. Do we use cookies?

FLUGIA GUARANTEES THAT WE DO NOT USE ANY ADVERTISING OR STATISTICAL TRACKING COOKIES IN THE OPERATION OF OUR PLATFORM.

We use only technical cookies that are strictly necessary for the proper functioning of our platform. These cookies do not require a consent banner and we recommend that you do not delete them.

If you nonetheless wish to object to their use, you can do so through your browser settings. Instructions are available for Chrome, Microsoft Edge, Safari, Firefox, and Opera.

11. Who can you contact for more information?

To ensure the best possible protection and integrity of your data, FLUGIA has appointed a responsible contact point for all data protection matters.

You may contact us at any time and free of charge at: privacy@flugia.com for any further information or clarification on how we process your data.

12. How can you contact a supervisory authority?

If you believe that your data protection rights have not been respected, you have the right to lodge a complaint with the competent supervisory authority in your country of residence. For EU residents, this is typically the data protection authority of your member state (e.g., CNIL in France, ICO in the UK, etc.).

You can find your local supervisory authority through the European Data Protection Board (EDPB) website: www.edpb.europa.eu.

13. Can this Privacy Policy be modified?

We may update this Privacy Policy at any time to adapt to new legal requirements or new processing activities we may implement in the future. We will notify you of any significant changes through the platform or by email.

The most recent version of this Policy is always available at: flugia.com/privacy-policy