Privacy Policy

Last Modified: May 27, 2025

1. Introduction

This Privacy Policy covers how Flowy LLC (“Flowy,” “we,” “our,” or “us”) collects, uses, discloses, and stores information about you when you (as a visitor, account owner, registered user, or other user) access or use our (i) website www.underwritegeni.com (the “Website”), (ii) the Underwritegeni generative AI assistant services for insurance underwriters provided by Flowy as Software-as-a-Service (SaaS) solutions via the Website or through our application programming interface (“API”) or otherwise (collectively, the “Services”), and/or (iii) any other product, service, or solution provided by Flowy (collectively with the Website and Services, the “Flowy Solutions”). Your use of the Services will also be subject to a separate SaaS Agreement or Solution Agreement (“Solution Agreement”). If any terms of the Solution Agreement conflict with the terms of this Privacy Policy, the terms of the Solution Agreement shall have priority over any conflicting terms in this Privacy Policy regarding data processed in connection with the Services.

2. What Information We Collect and How We Collect It

In order to provide our Flowy Solutions to you and to ensure that our Flowy Solutions operate correctly, we collect various types of information, including information that identifies you or may identify you as an individual or the entity you represent (“Personal Information”).

A. Information You Provide to Us:

Contact Information: If you use the contact information provided on our Website to contact us directly (e.g., via email, contact forms), we collect your contact information which may include your name, email address, title, business association, and the reason for your inquiry.
Account and Registration Information: When you sign up for a trial account, or purchase a plan to use our Services requiring registration, we collect information such as your name, email address, mobile phone number (optional), business association, password, billing address, zip code, country, company information, and payment information. Certain payment-related information may also be collected and used by our third-party payment processing service partners.
Submitted Data: We collect all information and data you provide to us when you use our Flowy Solutions, including any information, documents, or data you input, upload, or otherwise provide to or through our Services for processing by the Underwritegeni AI assistant (e.g., data related to insurance underwriting for Health Insurance, Life Insurance, Auto Insurance, Homeowners Insurance, Commercial Property, General Liability, Business Owner's Policy, Workers' Compensation, Professional Liability, Cyber Liability, and Excess & Surplus Lines) (“Submitted Data”). The handling of Submitted Data within the Services is primarily governed by your Solution Agreement.

B. Information We Automatically Collect When You Use Our Flowy Solutions:

Internet Protocol Address (“IP address”): We automatically collect information about your IP address when you visit or use our Flowy Solutions.
Usage Data: We collect information automatically through the Flowy Solutions (or third-party services employed in the Flowy Solutions). This includes domain names of the devices used to access Flowy Solutions, URI addresses, request times, server request methods, response file sizes, server status codes, country of origin, browser and operating system features, time spent on pages, navigation paths within the Flowy Solutions, and other parameters about your device operating system and IT environment (“Usage Data”). Usage Data also includes data generated by Flowy through analysis of service usage, user activity metrics, API calls, and service performance. Such Usage Data may be provided to us by third-party vendors.
Cookies and Similar Technologies: We use cookies and similar tracking technologies to collect information to help us understand and improve the performance of the Flowy Solutions. Please refer to our Cookie Policy (if applicable, or include details here) for more information.
Your Communications with Us: We may collect information communicated with us when you request information about our Flowy Solutions, or request customer or technical support, or otherwise communicate with us.
Job Applications: If we post job openings on our Website and you reply by submitting your application, resume, CV, and/or cover letter, we will collect and use your information to assess your qualifications.

C. Information We Collect From Third Parties:

We may receive Personal Information about you from partners, third-party service providers, external organizations, social media websites (if you interact with our social media pages), and marketing vendors.

3. How We Use The Information We Collect

We use the information we collect for various purposes:

Providing and Operating Services: To set up user accounts, provide, operate, and maintain Flowy Solutions, including the Underwritegeni AI assistant; to customize the user experience and generate output with our Services; process and complete transactions; provide customer service and support and respond to inquiries; send communications (transactional, security alerts, etc.); prevent fraudulent activity; and for registration and authentication purposes.
Service Administration and Improvement: To administer our Flowy Solutions, and to improve their functionality, performance, and user experience. This includes using Submitted Data and Usage Data in an aggregated and/or de-identified form to train and improve our AI models, algorithms, and the overall quality of the Underwritegeni Services. Any use of Submitted Data for AI model improvement will be in accordance with the terms of your Solution Agreement.
Analytics: To understand general information, trends, and usage patterns related to our Flowy Solutions, such as visitor numbers, device types, and user behavior on an aggregated basis. This information is typically de-identified or aggregated and used to improve our Flowy Solutions.
Responding to Inquiries: To respond to your direct inquiries using the contact information you provided.
Handling Payments: To process payments for our Services, often through third-party payment processors.
Tag Management: To manage tags or scripts needed on the Services in a centralized fashion.
User Database Management: To build user profiles and track user activities through analytics features to improve our Services.
Communications and Marketing: When you submit an inquiry, sign up for our Services, or access our API, we may use your information to send you communications from us or via third parties acting on our behalf, including those for marketing purposes, subject to your consent where required by law. You can opt out of receiving marketing communications at any time using the unsubscribe link in the emails or by contacting us.

4. Who We Share Your Information With

We do not rent or sell your Personal Information. We may share and disclose your information (including Personal Information) in the following instances:

Vendors and Service Providers: We share your information with third-party vendors and service providers who perform tasks on our behalf or provide functions for our Services (e.g., hosting providers, payment processors, analytics services, CRM providers, AI infrastructure providers). These parties are contractually bound to protect your Personal Information and use it only for the services they provide to us.
Business Transactions: If Flowy LLC is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, your information may be transferred as part of that transaction.
Public or Government Authorities: We may disclose your Personal Information or Submitted Data if required by law, subpoena, court order, or other formal governmental requests, or to establish or exercise our legal rights, defend against legal claims, or cooperate with government and law enforcement officials.
Consent: We may share your Personal Information if you have asked us to do so or we have received your explicit consent (e.g., posting user testimonials that may identify you).
Aggregated or De-identified Information: We may share aggregated, de-identified, or anonymized information (which cannot be used to identify an individual) for various purposes, including to improve our Flowy Solutions, for research and development, or for other lawful business purposes.

5. Cookies

The Flowy Solutions may place cookies on your browser or device to identify you when you return to our Website, log in to our Services, and for other operational and analytical purposes. For more detailed information on the cookies we use and your choices regarding cookies, please see our Cookie Policy (if you have one) or contact us.

6. Data Retention, Accessibility & Destruction

We will retain your Personal Information, including Submitted Data (as governed by the Solution Agreement), for as long as necessary to fulfill the purposes for which we collected it, including to provide Flowy Solutions to you, improve the Flowy Solutions, comply with our legal obligations, resolve disputes, and enforce our agreements. Upon written request from you, and subject to the terms of your Solution Agreement and applicable law, we will make accessible, destroy, or transfer your Submitted Data as appropriate.

7. No Responsibility for Third-Party Services, Websites or Content

The Flowy Solutions may contain links to third-party websites or applications (“Third-Party Sites”), use third-party content (“Third-Party Content”), or integrate with third-party services (“Third-Party Services,” e.g., payment processors). Your use of such Third-Party Solutions is at your own risk and subject to the terms and policies of the third-party providers. Flowy LLC makes no claim or representation regarding, and accepts no responsibility for, the quality, content, policies, or reliability of Third-Party Solutions.

8. Security

We take the security of your data very seriously. We implement and maintain reasonable administrative, physical, and technical safeguards designed to protect the privacy, security, and confidentiality of your Personal Information and Submitted Data from unauthorized access, use, disclosure, alteration, or destruction, consistent with industry standards and applicable law. These measures include:

Updating and testing our security technology on an ongoing basis.
Restricting access to your Personal Information to employees and contractors who need to know that information to provide services to you and who are subject to confidentiality obligations.
Training our employees and contractors on the importance of confidentiality and data security.
Utilizing secure data centers (e.g., from reputable cloud providers with their own robust security certifications).
Monitoring our systems for potential vulnerabilities and attacks.

9. Encryption

We use encryption technologies to protect data transmitted to and from our Website and Services (e.g., TLS/SSL for data in transit). Where appropriate and feasible, we also encrypt sensitive Personal Information and Submitted Data at rest.

10. Access Control

Access to our operational systems and infrastructure is restricted and controlled. We employ measures such as secure connectivity (e.g., SSL, SSH), multi-factor authentication for privileged access where appropriate, and password policies. Access is granted on a least-privilege basis and reviewed periodically.

11. Employees and Contractors

Our employees and contractors who have access to Personal Information are subject to background checks (where legally permissible), are required to sign confidentiality/non-disclosure agreements, and receive security and privacy training.

12. Vulnerability Management

We employ measures to identify and address security vulnerabilities, which may include regular vulnerability scanning and penetration testing, as appropriate for our systems and Services.

13. Incident Management

We maintain policies and procedures for responding to security incidents, designed to allow us to effectively manage and mitigate the impact of such events.

14. Legal Basis for Processing Your Information (EEA, UK, and Switzerland)

If you are a user of our Flowy Solutions located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

Performance of a Contract: We process Personal Information to perform our contractual obligations to you (e.g., to provide the Services you subscribed to under a Solution Agreement).
Legitimate Interests: We process Personal Information for our legitimate interests (e.g., to operate our Website, improve our Services, for analytics, fraud prevention, and direct marketing, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms).
Consent: We may rely on your consent to process Personal Information for specific purposes (e.g., for certain marketing communications or use of non-essential cookies). You have the right to withdraw your consent at any time.
Legal Obligation: We may process Personal Information where we have a legal obligation to do so.

Flowy LLC, based in Delaware, US, is generally the data controller for Personal Information collected through the Website. For Personal Information processed within the Services (Submitted Data), Flowy LLC may act as a data processor on behalf of its customers, as detailed in the applicable Solution Agreement and Data Processing Addendum (DPA), if any.

Data Storage and Data Transfer: Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. Specifically, our servers are primarily located in the United States (Please verify and update this location if necessary), and our third-party service providers and partners operate around the world. We will take appropriate safeguards to protect your Personal Information in accordance with this Privacy Policy and applicable law, such as by using Standard Contractual Clauses for transfers of Personal Information where required.

15. Children

Our Flowy Solutions are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If you become aware that a child has provided us with Personal Information without parental consent, please contact us, and we will take steps to delete such information.

16. “Do Not Track”

Some web browsers may transmit “Do Not Track” (DNT) signals. We currently do not take action in response to DNT signals because there is no universally accepted standard for how to respond to DNT signals.

17. Your Rights

Depending on your location and applicable data protection laws, you may have certain rights regarding your Personal Information, including:

Right of Access: The right to obtain access to your Personal Information.
Right to Rectification: The right to have inaccurate or incomplete Personal Information corrected.
Right to Erasure (Right to be Forgotten): The right to obtain the deletion of your Personal Information in certain circumstances.
Right to Portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format and to transmit it to another controller.
Right to Restrict Processing: The right to restrict or limit our use of your Personal Information in certain circumstances.
Right to Object: The right to object to the processing of your Personal Information in certain circumstances (e.g., for direct marketing).
Right to Opt-Out of Sale or Sharing (as defined by applicable laws like CCPA/CPRA): The right to opt-out of the "sale" of your Personal Information or "sharing" for cross-context behavioral advertising. Flowy LLC does not currently "sell" Personal Information as traditionally defined, nor do we "share" it for cross-context behavioral advertising.
Right to Withdraw Consent: If we rely on your consent for processing, you have the right to withdraw it at any time.

To exercise these rights, please contact us using the details in the “How to Contact Us” section. We will ask you to verify your identity before responding to such requests. Residents of the EEA, UK, and Switzerland also have the right to lodge a complaint with a supervisory authority.

18. Supplemental Notice to California Residents (CCPA/CPRA)

This section applies only to California residents. The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides California residents with specific rights regarding their Personal Information.

Categories of Personal Information Collected: In the preceding 12 months, we have collected categories of Personal Information as described in Section 2 ("What Information We Collect and How We Collect It"). This may include identifiers (name, email, IP address), customer records information (billing address, payment info), commercial information (services purchased), internet activity (Usage Data), professional or employment-related information (if you apply for a job or provide business association), and inferences drawn from this information.
Business or Commercial Purpose for Collection: We collect Personal Information for the business and commercial purposes described in Section 3 ("How We Use The Information We Collect").
Categories of Sources: We collect Personal Information directly from you, automatically through your use of Flowy Solutions, and from third-party sources as described in Section 2.
Categories of Third Parties with Whom We Disclose Information: We may disclose Personal Information to vendors and service providers, affiliates, legal authorities, and in connection with business transfers, as described in Section 4 ("Who We Share Your Information With").
Sale or Sharing: Flowy LLC does not "sell" your Personal Information as defined under CCPA/CPRA, nor do we "share" your Personal Information for cross-context behavioral advertising. We do not knowingly sell or share the Personal Information of minors under 16.
Data Retention: We retain Personal Information as described in Section 6 ("Data Retention, Accessibility & Destruction").
Your California Privacy Rights:
- Right to Know and Access: You have the right to request information about the categories and specific pieces of Personal Information we have collected about you, the categories of sources, the purposes for collecting it, and the categories of third parties with whom we have disclosed it.
- Right to Delete: You have the right to request the deletion of your Personal Information, subject to certain exceptions.
- Right to Correct: You have the right to request the correction of inaccurate Personal Information.
- Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive Personal Information to that which is necessary to perform the services or provide the goods reasonably expected. (Note: Define what you consider Sensitive PI if you collect it extensively).
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.
Exercising Your Rights: To exercise your rights, please contact us at [email protected] or via the contact information in Section 21. We will verify your request using the information associated with your account or by requesting additional information. You may also designate an authorized agent to make a request on your behalf.

19. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain "covered information" to third parties who intend to license or sell that covered information. Please note that we do not currently sell your covered information as "sale" is defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us.

20. Direct Marketing

When you sign up for our Services or provide us with your contact information, we may process your Personal Information to send you communications, including those for marketing purposes, where permitted by applicable law or with your consent. You can opt-out of receiving marketing communications from Flowy LLC at any time by using the unsubscribe link in the email communications we send or by contacting us.

21. How to Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us at:

Flowy LLC
Attn: Privacy Officer
Email: [email protected]

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes, we will notify you by posting the revised policy on this Website, updating the "Last Modified" date, or by other means as required by applicable law. We encourage you to review this Privacy Policy periodically to stay informed about our collection, use, and disclosure of Personal Information. Your continued use of any of our Flowy Solutions after such posting or notice will constitute your agreement to be bound by such modified policies.