This Policy explains which personal data Smart Flow+ collects, what we use it for, who we share it with, how long we keep it and how you can exercise your rights. It applies to the Smart Flow+ app, to conversations with Smart Flow+ on WhatsApp and to the website smartflowplus.com.br, and it is part of the Terms of Use.
It was written under Brazil’s General Data Protection Law (Law 13,709/2018), the Brazilian Internet Civil Framework (Law 12,965/2014) and, for users in the European Union, the General Data Protection Regulation (EU Regulation 2016/679).
1 Who we are
Smart Flow+ is a service of MARIO SERGIO SIERRA DELFINO, Brazilian company registration (CNPJ) 63.317.639/0001-15, operating as DelphinosDev. We are the controller of the data processed in Smart Flow+.
Contact for any privacy matter: mario@delphinosdev.com.
2 What data we collect
- Account: name, email, WhatsApp number, password, country and language.
- Your finances: the transactions you record (amount, description, date, type and category), categories, recurring transactions and reminders.
- Messages sent to Smart Flow+ on WhatsApp: texts, voice notes, photos and PDFs you send to record or look up transactions.
- Subscription: plan, price, subscription status and Stripe identifiers. We never receive or store your card details: they are entered directly on Stripe’s payment page.
- Technical data: IP address, date and time of access, app version and device operating system, and a device identifier used only to deliver app notifications.
- Website: pages visited and browsing information collected through cookies (see item 8).
The financial data you record is kept confidential. We do not ask for sensitive data (such as health, religion or political opinions) and ask you not to include it in messages or transaction descriptions.
3 What we use the data for
- Providing the service: recording and organizing your transactions and building charts, forecasts, reminders and summaries (performance of a contract).
- Replying on WhatsApp: confirming transactions and answering the questions you ask Smart Flow+.
- Charging the subscription after the trial period (performance of a contract).
- Sending account notices by email or in the app, such as password recovery codes and important changes to the service.
- Providing support when you contact us.
- Keeping the service secure and keeping the access logs required by Brazilian law (legal obligation).
- Measuring website visits and campaigns (legitimate interest).
We do not sell personal data and we do not show ads in the app.
4 Artificial intelligence
When you send a message to Smart Flow+ (on WhatsApp or in the app), it reaches our server and its content is sent to the OpenAI API to be interpreted: the AI finds the amount, whether it is income or an expense, the category and the date, transcribes voice notes and reads photos and PDFs. The result comes back to our server and is saved to your account. The AI also writes the monthly summary based on your transactions.
- We send OpenAI only what each request needs.
- Under OpenAI’s rules for API use, this data is not used to train its models and is kept by OpenAI for a limited time, for safety purposes.
- The AI can make mistakes. Check your transactions in the app and correct them when needed.
5 Who we share data with
We only share data with the partners needed for the service to work, each with its own privacy policy:
| Partner | Purpose |
|---|---|
| OpenAI (USA) | Interpreting messages, voice notes, photos and PDFs, and writing summaries |
| WhatsApp (Meta) | Receiving your messages and sending Smart Flow+ replies |
| Stripe (USA) | Charging the subscription by credit card |
| Hostinger | Hosting the server, database and website |
| Microsoft (OneDrive) | Storing database backups |
| Google (Firebase) | Delivering app notifications |
| Google (Tag Manager) | Measuring website visits and campaigns |
| Apple and Google | Distributing the app through their stores |
We may also share data when required by law or a court order, to defend the rights of Smart Flow+ or in the event of a sale or merger of the business, keeping the rules of this Policy.
6 International transfers
Some partners, such as OpenAI, Stripe, Google and Microsoft, process data outside Brazil. In these cases, the transfer is made to provide the service you use, with partners that adopt protection measures compatible with Brazilian law and, where applicable, the GDPR.
7 How long we keep data
- Account data and your transactions are kept while the account exists, including after the trial ends or when the subscription expires, so everything is there when you come back.
- When you delete your account, the data is erased. Server backups are automatically replaced within 7 days.
- Access logs are kept for 6 months, as required by Brazilian law.
- Payment records stay with Stripe, under its own rules and tax obligations.
8 Cookies on the website
The website uses its own cookies (for example, to remember your language) and Google Tag Manager cookies, which measure visits and campaigns. You can block or delete cookies in your browser settings; the website keeps working.
9 Security
We use encrypted connections (HTTPS) between the app, the website and the server, restricted access to the server and database, and daily backups. No system is completely immune to failures; if an incident could put you at risk, we will notify you and the Brazilian Data Protection Authority, as required by law.
10 Your rights
At any time, you can:
- confirm whether we process your data and access it;
- correct incomplete or outdated data (most of it can be changed in the app);
- ask for unnecessary data to be anonymized, blocked or deleted;
- ask for the portability of your data;
- find out who we share your data with;
- withdraw consent;
- delete your account, as explained on the Delete account page.
To exercise any right, write to mario@delphinosdev.com. You can also file a complaint with the Brazilian Data Protection Authority (ANPD) or, in the European Union, with the authority in your country.
11 Minors
Smart Flow+ is not intended for anyone under 18.
12 Changes to this Policy
We may update this Policy. The date of the last update is shown at the top of the page and, if the change is important, we will let you know by email or in the app.
13 Data protection officer and contact
Data protection officer: Mario Sergio Sierra Delfino — mario@delphinosdev.com.