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Privacy Policy

1. General Provisions

1.1. This Policy establishes the procedure for processing and protecting the personal data of users (hereinafter referred to as the «User») that may be transmitted to the Operator when using the website and communicating via messengers.

1.2. The Operator processes personal data in accordance with Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”, in order to ensure the protection of the rights and freedoms of individuals during the processing of their personal data, including the right to privacy, personal and family confidentiality.

1.3. This Policy applies to all cases where the User voluntarily initiates communication with the Operator via messengers such as Telegram, a Telegram bot, or WhatsApp, using the links provided on the website https://flowbee.me.

1.4. In accordance with Part 2, Article 18.1 of the Personal Data Law, this Policy is published in open access on the Internet via the Operator’s website.

2. Terms and Definitions

This Policy uses the following definitions:

2.1. Website — the Operator’s online resource located at https://flowbee.me, including all its subdomains, components, and functional modules.

2.2. Operator — LLC “Flowbee”, which independently determines the purposes and methods of processing the personal data of Users obtained through the Website and messengers.

2.3. User — any individual using the Website and/or engaging with the Operator via the mentioned messengers (Telegram, WhatsApp).

2.4. Personal Data — any information related to an identified or identifiable individual (data subject) that may be obtained by the Operator during interaction with the User, including Telegram ID, username, name (if provided), and phone number visible in WhatsApp.

2.5. Processing of Personal Data — any action (operation) or set of actions performed with or without the use of automation tools with personal data, including collection, systematization, storage, updating, usage, transfer, anonymization, blocking, deletion, and destruction.

2.6. Messengers — software tools used for message exchange between the User and the Operator. For the purposes of this Policy, «messengers» refer to Telegram (including Telegram bot) and WhatsApp.

2.7. Request — a User’s voluntary initiation of communication with the Operator via the Telegram bot, Telegram account, or WhatsApp, including by clicking relevant buttons on the Website such as «Get a consultation», «Discuss a project», «Contact us», «Open chat», or similar that clearly indicate the start of a dialogue.

2.8. Cookies — fragments of data automatically stored on the User’s device when visiting the Website, used for the correct functioning of the Website and for traffic analysis.

2.9. Anonymized Data — data that does not allow direct identification of the User, including browser technical data, IP address, interface language, and behavioral information on the Website transmitted to third parties via cookies.

3. Data Subject and Data Controller

3.1. The data controller (Operator) is:

Limited Liability Company “Flowbee”

Email: flowbusiness.mne@gmail.com

3.2. The Operator independently determines the purposes, scope, and procedure for processing the personal data of Users received through communication channels and is responsible for their protection.

3.3. The data subject is an individual (User) who voluntarily initiates interaction with the Operator via messengers (Telegram, Telegram bot, or WhatsApp), including by clicking a button on the Website that triggers communication, such as “Get a consultation”, “Discuss a project”, “Contact us”, “Open chat” or any similar action clearly indicating the start of a dialogue.

4. Purposes of Personal Data Processing

4.1. The Operator processes the User’s personal data strictly for the purposes specified in Article 6, Part 1, Clause 5 of Federal Law No. 152-FZ «On Personal Data», namely:

  • to respond to messages or provide consultation at the User’s request;
  • to conduct a one-time follow-up communication if the User has clearly expressed an intention to interact with the Operator;
  • to provide technical support for the correspondence initiated by the User in Telegram or WhatsApp by voluntarily clicking a button on the Website such as “Get a consultation”, “Discuss a project”, “Open chat”, “Contact us” or similar.

4.2. The Operator does not use the User’s personal data for the following purposes:

  • for automated or manual bulk messaging (including advertising messages);
  • to create a customer database or integrate into a CRM system;
  • for analytical processing or profiling;
  • for sharing with third parties, except where required by applicable Montenegrin law.

4.3. The fact of initiating interaction via Telegram or WhatsApp is considered a voluntary request by the User, within which the Operator is entitled to use the provided data once for the purpose of responding to the inquiry.

5. Personal Data Subject to Processing

5.1. No personal data is collected directly through the Website, as it does not contain any feedback or contact forms.

5.2. When transitioning to messengers (Telegram or WhatsApp) and initiating a dialogue, the Operator may obtain the following technical information:

5.2.1. Via Telegram:

  • Telegram ID (a unique numerical identifier),
  • Username (nickname beginning with “@”),
  • Name provided in the Telegram profile (if available).

5.2.2. Via WhatsApp:

  • User’s phone number (automatically displayed in the chat).

5.3. The Operator does not require the User to provide additional personal information such as:

  • Full name or passport details,
  • Residential address,
  • Email address,
  • Any other identifiers beyond what is automatically transmitted by the messengers.

5.4. Personal data is not verified or clarified unless the User voluntarily provides such information during the course of the conversation.

6. Procedure, Duration, and Scope of Processing

6.1. Personal data is processed without recording into databases, without systematization, and without the creation of registries.

6.2. All actions with personal data are limited to:

  • Viewing the message,
  • Preparing and sending a response.

6.3. Correspondence with the User in messengers (Telegram, WhatsApp) is not saved or archived by the Operator, nor is it used for creating client databases, analytics, profiling, or follow-up communications.

Processing of personal data is performed solely within the scope of fulfilling an individual request or pre-agreed interaction, if such communication was voluntarily initiated by the User.

7. Disclosure and Transfer of Personal Data

7.1. The Operator does not disclose or transfer personal data to third parties, except in the following cases:

  • If such transfer is required to comply with applicable legislation of the Russian Federation (including requests from authorized government bodies entitled to access such data);
  • If the User has provided explicit, voluntary, and informed consent to such transfer.

8. Data Security

8.1. The Operator undertakes all necessary and appropriate organizational and technical measures to ensure the security of personal data and to prevent unauthorized access, alteration, blocking, copying, distribution, or other unlawful actions.

Such measures include, but are not limited to:

  • Restriction of access to devices,
  • Use of two-factor authentication in messengers and for securing work devices,
  • Absence of any local or cloud-based user data storage systems.

9. Use of Cookies and Third-Party Technologies

9.1. The website https://flowbee.me uses cookies and similar technologies solely to ensure the proper technical operation of the site and to analyze traffic.

9.2. Cookies are not used to identify individual Users, do not contain personal data, and are not stored by the Operator in any structured form.

9.3. Visiting the Website may result in the automatic transmission of anonymized technical data to third-party services, in accordance with their privacy policies. The Operator does not control or manage the processing of such data by third parties.

9.4. By continuing to use the Website, the User consents to the use of cookies in accordance with this Policy. If the User does not agree, they must stop using the Website or disable cookies in their browser settings.

10. User Rights

10.1. The User has the right to:

  • Request information regarding the fact and purpose of their data processing;
  • Request deletion of messages, conversations, or contact information;
  • Withdraw their inquiry without stating any reasons.

10.2. To exercise these rights, the User may send a request via the Operator’s email: flowbusiness.mne@gmail.com

11. Changes to the Policy

11.1. The Operator reserves the right to amend this Policy without prior notice to the User.

11.2. The updated version becomes effective immediately upon its publication on the Website at: https://flowbee.me/politika

By initiating contact with the Operator via messengers, the User confirms that they have read and accepted this Privacy Policy. If you do not agree with the terms of this Policy, please refrain from using messengers to interact with the Operator.