Privacy policy

1. Who is responsible

Imhauser Technologies LLC, McLean, Virginia, United States. Contact: info@imhauser.net.

• For the accounts of our customers (the planners) and for this website, we are the controller.
• For the stakeholders a customer adds (the people they keep informed), the customer's organization is the controller and we process the data on its behalf, under the data processing agreement. If you are a stakeholder, the organization that planned you is your first contact; you can also write to us.

2. What we process, and why

Who	Data	Purpose and legal basis
Planners	First name, surname, email address, password (stored only as a salted hash), organization name and time zone	Providing the service under the terms (contract)
Stakeholders	First name, surname, email address, roles in the customer's projects, whether they unsubscribed, when they last opened their page, and the log of notifications sent to them	Keeping them informed about their activities, on the customer's instructions
People joining the waiting list	First name, last name, email address and organization, entered in the form on the website	Telling you when FlowPilot opens for your organization (your consent, which you can withdraw at any time)
Visitors of this website	The pages you view and the page you came from, your browser and device type, your approximate location (derived from your IP address) and an identifier kept in a cookie, collected by Google Analytics	Understanding how the website is used and improving it (legitimate interest)
Everyone using the app	Technical data needed to run it securely: IP address (for rate limiting and security), browser type, error reports	Security and reliability of the service (legitimate interest)

Emails carry no project content: only a notice and a link. The personal link in them is never stored, and it is removed from our logs and telemetry.

3. Cookies

This website uses Google Analytics to measure visits; it sets cookies (_ga and _ga_…, kept for up to two years) that tell one visitor from another. You can block them in your browser or with Google's opt-out add-on. On the waiting-list page, the form is provided by HubSpot, which may also set cookies needed for the form to work. The app uses no analytics and no tracking: it uses only strictly necessary cookies: one that keeps the planner signed in, and one that protects forms against cross-site request forgery. Stakeholder pages set no sign-in cookie.

4. Where the data is, and who helps us

Everything is hosted by Microsoft Azure, in the United States (East US 2 region, Virginia). Emails are sent through Microsoft 365 Exchange Online, sending from notifications@flowpilot.net. Our subprocessors:

• Microsoft Corporation (Microsoft Azure): Hosting of the application, the database, the email queue and the application logs (United States).
• Microsoft Corporation (Microsoft 365 Exchange Online): Sending the notification and account emails (United States).

The waiting-list form on the website is provided by HubSpot, Inc. (United States), which stores what you enter in it on our behalf. Visits to the website are measured with Google Analytics, provided by Google LLC (United States); the app and the stakeholder pages do not use it.

We do not sell data and do not use it for advertising.

5. International transfers

FlowPilot is operated from, and hosted in, the United States. If you are in the European Economic Area, the United Kingdom or Switzerland, your personal data is transferred to the United States. We rely on the European Commission's Standard Contractual Clauses (and their UK and Swiss equivalents) for these transfers. You can ask us for a copy of the safeguards.

6. How long we keep it

• Account and stakeholder data are kept while the account exists.
• Waiting-list details are kept until your organization is invited or you ask us to remove them.
• When a planner deletes a stakeholder, their name and email address are erased at once, and their personal link stops working.
• When a customer deletes their account, the organization, the planner and every stakeholder are anonymized at once, and no more emails are sent.
• Database backups hold earlier states for up to 14 days (point-in-time restore) and weekly backups for up to 12 weeks. They are used only to recover from incidents, and they expire on their own.

7. Your rights

You can ask for access to your data, its correction or erasure, a copy of it, or to restrict or object to its processing. Stakeholders can stop the emails at any time with the link at the bottom of every email. Write to info@imhauser.net; we answer within one month. You can also lodge a complaint with the data protection authority of the country where you live, if you are in the European Economic Area, the United Kingdom or Switzerland.

8. Security

Connections are encrypted (HTTPS only), the database is encrypted at rest, our services reach each other with managed identities rather than passwords, passwords are hashed, and access to one organization's data by another is prevented and tested.

9. Changes

We will publish any change to this policy here, with a new date at the top, and tell customers by email when the change is material.