Privacy notice

1. Who handles your data

DTO Flow is operated by HYPERPLANE SOLUTIONS, obrt za izradu softvera, vl. Filip Bebić, Zadar, Vlade Janjića Cape 11, Croatia. Contact support@dtoflow.com about this notice or your personal data.

We act as controller for account administration, business enquiries, billing, support and service security. For personal data in customer files and exchange records handled on customer instructions, we act as processor, or subprocessor where the customer is a processor. The customer determines the purpose, permitted recipients and instructions. Our customer terms include the processing schedule for that relationship.

2. Information and sources

You provide your name, email, organization name, password, language and time-zone preferences, and optional profile images. Passwords are stored as hashes, not readable passwords. Administrators and partners may supply your business contact details, invitations and access assignments.

The service handles submitted files, samples, file names, feed rules, validation results, delivery destinations and exchange/activity history. Files and field values may contain personal data supplied by customers or their partners. Support correspondence includes information you choose to send.

Security and operational records can include IP addresses, browser details, timestamps, account/request identifiers, authentication events and diagnostics. Registration evidence includes the user, workspace, accepted terms version, notice version presented, language and acceptance time. Stripe supplies subscription, payment-status, invoice and billing details. Full payment-card details are entered on Stripe-hosted payment pages rather than stored as card fields by DTO Flow.

3. Purposes and legal bases

We use account and service information to provide access, administer workspaces, run agreed exchanges and respond to requests. If you contract personally as a business operator, this is necessary for the contract or requested pre-contractual steps (GDPR Article 6(1)(b)). For organizational representatives and invited users, we rely on legitimate interests in providing and administering the business service (Article 6(1)(f)).

Legitimate interests also support security, abuse prevention, troubleshooting, business enquiries and establishing or defending claims. We consider necessity and the impact on individuals; you may object on grounds relating to your situation. Accounting, tax and legally required disclosures rely on legal obligations (Article 6(1)(c)). Customer-file processing follows the customer's instructions and legal basis, rather than general consent obtained by DTO Flow.

Required registration details are needed to create and secure the workspace; without them we cannot register it. Profile images are optional. Accepting customer terms is a contractual agreement, not blanket consent to personal-data processing.

4. Recipients and providers

Authorized organization users and partners receive information according to configured access. Customer-selected download, API, webhook and notification recipients receive the information the customer chooses to share. Customers are responsible for their destinations and recipients.

Microsoft Azure provides hosting, database/file storage, messaging, transactional email and operational monitoring. Stripe provides payment and billing services and may act as processor or independent controller for its own purposes, as described in its privacy policy. Authorized operator personnel may access relevant information to operate, secure and support the service. We may disclose information as required by law or necessary for legal claims, with appropriate safeguards. We do not sell customer personal data or use uploaded files for advertising.

The provider register in the customer terms describes service roles, relevant data and locations. Contact support for the applicable provider contractual entities and transfer documentation. Customer-controlled file processing and our own billing or account processing have different roles and purposes.

5. Hosting and international transfers

Core partner-file and exchange data is hosted in Azure EU regions: database/file storage in West Europe and application processing in Germany West Central. Transactional email uses the Europe data location. This does not mean every provider operation remains in the EU: Microsoft's documented service/support exceptions and Stripe's international operations can involve processing outside the EEA.

Relevant provider arrangements use applicable transfer safeguards, such as European Commission standard contractual clauses, or an applicable adequacy decision. Contact us for information about safeguards relevant to your data and how to obtain a copy, subject to necessary redactions. Customer-directed destinations may be abroad; customers must ensure their instructions and destinations are lawful.

6. Retention, closure and recovery copies

Account and workspace records are retained while needed to provide and secure the service. Files, exchange history and audit records remain subject to product access rules. Subscription expiry or cancellation does not automatically erase them, and displayed plan retention values are not automatic deletion schedules.

We determine retention separately for account, billing, support and security information. Relevant criteria include whether an account or request remains active, applicable accounting duties, an unresolved security investigation and the need to establish, exercise or defend a specific legal claim. We delete or anonymize information when its applicable purpose and legal retention requirements have ended. Retaining these records does not authorize unrelated use of customer files.

An authorized representative can contact support for workspace closure, return or deletion. Outside the statutory switching procedure, we follow the customer's lawful instructions without undue delay and agree a reasonable timetable where permitted by law, taking account of scope and technical requirements. Agreement on a timetable is not a condition for meeting mandatory deadlines. Statutory switching arrangements have their own transition, retrieval and erasure timetable and take precedence. Necessary lawfully retained controller records are separated from processor content. Verification or timetable arrangements do not extend individual rights-response deadlines.

The documented database recovery-retention policy and blob or container soft-delete settings are 14 days. Where legally permitted, active deletion may leave restricted copies that expire through the provider-managed lifecycle. The setting is not itself confirmation of every copy's physical erasure. We confirm completed deletion actions and identify remaining restricted recovery copies. Statements about provider-managed backup expiry or erasure are based on available provider documentation and evidence, with relevant limitations explained. Copies remain protected and excluded from ordinary use; restoration must respect completed deletion instructions. Our subprocessor responsibilities and mandatory erasure duties remain unaffected. Provider-held billing data follows the provider's applicable retention rules and legal duties.

7. Cookies and browser storage

Authentication cookies maintain signed-in sessions. Browser storage holds language, theme, session indicators and cached application settings. Authentication tickets normally last eight hours and may renew during use; remember-me affects persistence. Preferences can remain until changed or cleared. These functions support requested access and preferences. Clearing or blocking them may sign you out or reset settings.

The DTO Flow client currently contains no advertising trackers or third-party marketing analytics. Server-side Azure monitoring supports reliability and security. Stripe-hosted checkout and billing pages have their own cookies and privacy practices; consult Stripe's policy when visiting them.

8. Validation and automated processing

Configured deterministic rules check supported spreadsheet content and determine file validation results. These concern the exchange, not a DTO Flow decision about an individual's creditworthiness, employment or similar legal status. Customers are responsible for how they use results in their decisions. We do not currently send uploaded files to an AI provider or use them to train AI models.

9. Your rights and requests

Subject to applicable conditions, you may request access, correction, erasure, restriction and portability, and object to processing based on legitimate interests. If a specific activity relies on consent, you may withdraw it without affecting earlier lawful processing. This notice does not request such consent.

Send requests to support@dtoflow.com. We may request proportionate evidence of identity and authority. We normally respond within one month; if the GDPR permits an extension for complexity or number of requests, we explain it and the reasons within the first month. Restrictions, refusals or necessary legal retention will be explained.

For customer-controlled data, contact the relevant organization first. If you contact us, we assist or refer the request to that customer as appropriate. You may complain to the Croatian Personal Data Protection Agency (AZOP), or the competent supervisory authority where you live, work or believe an infringement occurred. Judicial remedies remain available.

10. Changes to this notice

This notice is version 2026-10-02.4. We publish dated updates when practices change and communicate material changes through appropriate account or service channels. A changed notice does not itself amend an accepted customer contract. Registration evidence preserves which notice version was presented.