Privacy Policy

1. Overview

Enigmatic Saola LTD (“the Company”, “we”, “us”, or “our”), a company registered at HaKeren 1, Ra’anana in Israel, is committed to protecting the privacy of everyone who uses FlowWrite. This Privacy Policy explains what information we collect, how we use it, and your rights in relation to it. By using FlowWrite, you agree to the practices described in this Policy.

2. Information We Collect

Non-Identifiable Data: We may collect aggregated, anonymized usage data such as feature usage frequency and general performance metrics. This data cannot be used to identify you personally and is used solely to improve the App.

Personal Data: When you use FlowWrite to generate text, you provide writing prompts and descriptions (your “Inputs”). This information is:

• Processed in order to generate the text output you requested
• Transmitted to third-party AI service providers (such as Anthropic) solely for the purpose of generating your requested content
• Not stored on our servers beyond what is necessary for immediate processing
• Not used to build user profiles or track your activity over time

3. How We Process Your Data

Your Inputs are used exclusively to fulfill your writing request within the App. We do not retain, sell, rent, or share your Inputs with any party other than the AI service providers required to generate your content. Search queries entered through the App may be processed by our designated Search Provider to deliver relevant search results and to support the App’s search functionality. Aggregated, non-identifiable search data may be shared with affiliated entities for revenue attribution purposes in accordance with our carrier distribution model.

4. GDPR - Legal Basis for Processing

For users in the European Economic Area, we process your data under the following legal bases:

• Contractual Necessity: Processing your Inputs is necessary to provide the writing assistance service you have requested.
• Legitimate Interests: We process limited usage data to maintain and improve the App, where such interests are not overridden by your privacy rights.
• Consent: Where required by applicable law, we will obtain your consent before processing your data for purposes beyond those described above.

5. Classification of Personal Data Collected and Disclosed

Category A - Identifiers: We may collect online identifiers such as IP addresses when your device communicates with our service infrastructure or with third-party AI providers. This data is used solely for technical purposes (such as routing requests) and is not used to identify you personally.

Category F - Internet or Electronic Network Activity: We collect information about your interactions with the App, including the writing types and features you use, in aggregated and anonymized form. We do not collect individual browsing histories or detailed behavioral profiles.

6. Data Sharing Practices

We do not sell your Personal Data. We may share limited data in the following circumstances:

• AI Service Providers: Your writing Inputs are transmitted to third-party AI providers (such as Anthropic) solely to generate the requested text. These providers have their own privacy policies governing their use of data.
• Search Provider: Search queries submitted through the App may be processed by our designated Search Provider. Aggregated search data may be shared with affiliated entities for revenue attribution in connection with our carrier distribution model.
• Legal Requirements: We may disclose data if required to do so by law, regulation, or valid legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction.

We do not sell your Personal Data to any third party.

7. Search Data and Third-Party Search Provider

FlowWrite may incorporate search functionality powered by a third-party Search Provider designated by the Company. Search queries you enter through the App’s search features are transmitted to this provider to deliver search results. De-identified or aggregated data related to search usage may be shared with affiliated entities for the purposes of revenue attribution and performance reporting in connection with our carrier distribution agreements. You may opt out of interest-based advertising related to search activity through the Digital Advertising Alliance (DAA) at www.aboutads.info or the Network Advertising Initiative (NAI) at www.networkadvertising.org.

8. Data Storage and Retention

Text you generate using FlowWrite is stored locally on your device only. We do not upload or store your generated content on our servers. When you uninstall the App, locally stored data is removed from your device. We retain minimal anonymized usage data for as long as necessary to support App improvement, after which it is deleted or permanently anonymized.

9. Data Security

We implement commercially reasonable technical and organizational security measures to protect data during transmission to AI service providers, including encryption in transit. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. You use FlowWrite at your own risk with respect to data security.

10. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate personal data.
• Erasure: Request deletion of your personal data, subject to applicable legal requirements.
• Restriction: Request that we limit the processing of your personal data.
• Portability: Request transfer of your personal data to another party in a machine-readable format.
• Objection: Object to our processing of your personal data where we rely on legitimate interests.
• CCPA Non-Discrimination: If you are a California resident, we will not discriminate against you for exercising any of your rights under the California Consumer Privacy Act.

To exercise any of your rights, please contact us at [email protected].

11. Children’s Privacy

FlowWrite is not directed at children under the age of 16. We do not knowingly collect personal data from individuals under 16. If you believe we have inadvertently collected data from a child under 16, please contact us immediately at [email protected] and we will take steps to delete such information promptly.

12. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify users of material changes by updating the “Last Updated” date at the top of this document. Your continued use of the App after changes take effect constitutes your acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Enigmatic Saola LTD
HaKeren 1, Ra’anana in Israel
[email protected]