Privacy notice

1. Who we are

FlowWise ("we," "us") is a subscription tool for Philippine water refilling stations operated by Subay Media. We are the data processor. The station owner who signs up is the data controller for order contact details and station operational data they enter, including names, phone numbers, delivery addresses, and order history.

2. What data we hold

• Your account. Email for owners, username for staff, name, role, station, password hash, and last-active timestamp.
• Your station’s records. Order contact names, phone numbers, addresses / landmarks, product catalog, orders, deliveries, accepted payments (cash, GCash, Maya), Payment Pending state, bottle movements, balance ledgers, and audit logs.
• Usage analytics (currently inactive). FlowWise does not currently load an Umami script or send analytics events. If the owner later approves enablement, only behavioral events such as screens viewed and rough usage flow may be sent; personal identifiers, payment values, and order-contact details remain excluded.

3. Who can see what

• You and your station’s staff see data for your station only. Other stations’ data is invisible to you.
• Subay Media (founder admin) has audited support access across stations. Founder admin can also perform limited account-level actions: create stations, manage subscription state, suspend/reactivate a station, and purge an eligible closed/demo station through guarded tooling. Founder admin does not act as a station operator on your order/payment data and does not send messages on your behalf.
• No third parties receive station data for advertising, lending, resale, or analytics resale.
• Sentry processes technical error and performance information for FlowWise so Subay Media can detect and diagnose application failures. FlowWise applies an application-level monitoring filter intended to exclude customer, payment, AI prompt or response, and credential content before monitoring data is sent. Sentry may also process technical network metadata associated with an event according to the Sentry account configuration and Sentry’s terms. Sentry is used for application monitoring, not advertising, profiling, or resale of station data.

4. Where data is stored

Servers are located outside the Philippines, on infrastructure we administer directly.

5. How long we keep your data

Ledger and audit entries are retained for 5 years; operational data follows the same window unless an approved deletion/redaction request clears order-contact fields earlier.

6. Your rights (PH DPA)

You have the right to:

• Access — request a copy of your station’s data.
• Correct — fix inaccurate account or operational data through the app or by writing to us.
• Delete — request deletion/redaction of personal data, subject to legal retention obligations for ledger, financial, and audit records.
• Object — to processing you believe is unlawful.
• Complain — to the National Privacy Commission (privacy.gov.ph).

To exercise these rights, email privacy@subaymedia.co. We respond within 10 working days.

7. Order contact data you enter

The station owner is the data controller for order contact personal data. The station is responsible for telling delivery contacts what data it collects and why. FlowWise supports redaction of order contact fields while preserving required order, ledger, bottle, payment, and audit lineage.

8. Security

• TLS in transit.
• Strong-password policy and per-user PocketBase tokens.
• Session cookies are Secure in production and SameSite=Lax. The PocketBase auth cookie is intentionally not HttpOnly because the app’s browser client must talk to PocketBase; strict CSP is the compensating control.
• Audit log of enumerated data-modifying actions plus founder cross-station support access.
• Bottle, balance, audit, and idempotency ledgers are insert-only.

9. Changes to this notice

Material changes are emailed to all account holders at least 14 days before they take effect.

10. Contact

Subay Media