This Privacy Policy (“Policy”) is issued by RHO DEVELOPERS LLC, having its registered office at SHAMS, Sharjah Media City, Sharjah, UAE (“Company”, “We”, “Us”, or “Our”).
The objective of this Policy is to:
- Describe the categories of personal data collected and processed by the Company;
- Explain the lawful purposes and manner of such processing;
- Set out the rights available to individuals whose personal data is processed; and
- Demonstrate the Company’s commitment to compliance with applicable data protection laws.
This Policy governs the processing of personal data in connection with the mobile application “Flow AI: Voice Note Taker App” (“Application” or “Service”) and any associated websites, support channels, or services operated by the Company.
By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
Words with capitalized initial letters have meanings defined below. These definitions apply whether the terms appear in singular or plural.
Definitions
Application refers to Flow AI: Voice Note Taker App, the mobile application provided by the Company.
Company (referred to as “We”, “Us”, or “Our”) refers to RHO DEVELOPERS LLC,
SHAMS, Sharjah Media City, Sharjah, UAE.
Country refers to the UAE.
Data Principal means the individual to whom the personal data relates.
Device means any device that can access the Service, such as a smartphone or tablet.
Personal Data means any information relating to an identified or identifiable individual.
Processing means any operation or set of operations performed on personal data, whether automated or otherwise.
Service refers to the Application and its features.
Service Provider means any third party that processes data on behalf of the Company to support analytics, performance, or app functionality.
Usage Data means technical and analytical data collected automatically through use of the Application.
You means the individual accessing or using the Service.
Scope and Applicability
This Policy applies to:
- All users who download, access, or use the Application;
- All personal data processed in digital form by the Company; and
- Personal data initially collected in non-digital form and subsequently digitised.
For the purposes of this Policy, the Company acts as a Data Fiduciary and determines the purpose and means of processing personal data.
Data Minimisation
The Application is designed on a data minimisation basis. The Company collects only such data as is strictly necessary to provide and improve the Service and to comply with applicable legal obligations.
Collecting and Using Data
Data Not Actively Created
The Company does not intentionally collect direct personal identifiers such as name, email address, phone number, or postal address, unless such information is voluntarily provided by the user when contacting customer support or communicating with the Company.
Usage Data
Usage Data is collected automatically to help us understand how the Application is used and to improve performance.
This may include:
- Device type and operating system
- Application version
- Anonymized IP address
- Date and time of app usage
- Feature interactions and usage duration
- Crash logs and diagnostic data
This data is used strictly for analytics, performance monitoring, bug fixing, and service improvement.
File and Document Access
To provide core functionality:
The Application may request access to files or content explicitly selected by You.
Files are processed locally on your device or temporarily via secure servers only to complete the requested action.
The Company does not access, view, store, or share your content beyond what is necessary to deliver the feature.
Files are not retained after processing is complete.
You can manage or revoke file access permissions at any time through your Device settings.
Purpose of Processing
Personal data is processed strictly for lawful and limited purposes, including:
- Provision, operation, and maintenance of the Application;
- Performance optimisation and feature enhancement;
- Monitoring Application stability, security, and integrity;
- Detection and resolution of technical issues;
- Processing in-app purchases, subscriptions, and refunds through authorised platforms;
- Compliance with legal, regulatory, and app store requirements.
Personal data is not processed for marketing, advertising, or resale purposes.
If a refund is requested, limited non-personal usage information may be shared with Apple or Google as required by their policies.
Lawful Basis and Consent
Personal data is processed on the basis of:
- Consent provided by the Data Principal through clear affirmative action; and/or
- Deemed consent, where processing is necessary for the performance of services expressly requested by the user.
Users may withdraw consent at any time by discontinuing use of the Application or contacting the Company. Withdrawal of consent may result in the unavailability of certain features in the Application.
Disclosure and Sharing of Personal Data
Personal data may be disclosed only in the following circumstances:
Service Providers
To carefully selected Service Providers engaged for:
- Analytics and performance monitoring;
- Crash reporting and diagnostic services;
- Payment processing and subscription management.
All Service Providers are contractually bound to process data solely on documented instructions of the Company and to implement appropriate technical and organisational safeguards.
Legal and Regulatory Requirements
Where disclosure is required to comply with applicable laws, court orders, governmental requests, or regulatory obligations.
Corporate Transactions
In the event of a merger, acquisition, restructuring, or transfer of business assets, subject to continued protection of personal data.
With Explicit User Consent
Where the user has expressly consented to such disclosure for a specified purpose.
We do not sell or rent Personal Data to third parties.
Data Retention
Usage Data is retained only for as long as necessary to fulfill the purposes outlined in this Policy.
Files and content processed in the App are not stored after the requested operation is completed, except for short-term technical processing if required.
Cross-Border Data Transfers
Personal data may be processed or stored on servers located outside UAE, subject to:
- Jurisdictions permitted by applicable authorities;
- Implementation of reasonable contractual, technical, and organisational safeguards; and
- Compliance with applicable data protection laws.
Delete Your Data
Since no account is required:
- You may remove the Application to stop data collection;
- You may contact us to request deletion of any retained data.
Certain information may be retained if required by law or legitimate business purposes.
Information Security Measures
The Company implements reasonable and appropriate administrative, technical, and organisational measures, including:
- Encryption and secure transmission protocols;
- Role-based access controls;
- Internal confidentiality obligations;
- Regular security reviews and updates;
- Monitoring and incident response procedures.
While reasonable efforts are made to protect personal data, no method of transmission or storage is completely secure.
Personal Data Breach Management
In the event of a personal data breach, the Company shall:
- Take prompt remedial and containment measures;
- Assess the impact and scope of the breach;
- Notify affected individuals and relevant authorities, where required under applicable law;
- Maintain records of the breach and corrective actions taken.
Rights of Individuals
Subject to applicable law, individuals have the right to:
- Obtain confirmation regarding processing of personal data;
- Request access to personal data;
- Seek correction or updating of inaccurate or misleading data;
- Request erasure of personal data;
- Withdraw consent at any time;
- Seek grievance redressal.
Children’s Privacy
The Service is not intended for children under 13.
We do not knowingly collect Personal Data from children. If you believe a child has provided data, please contact us and we will take appropriate action.
Links to Third-Party Websites
The Service may contain links to third-party websites.
We are not responsible for the content or privacy practices of those websites.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
Any changes will be posted on this page and the “Last updated” date will be revised.
Contact Us
If you have any questions about this Privacy Policy, you can contact us at: