Privacy Policy

1. Introduction

FlowClear is a brand operated by Changzhou Jingtu International Trade Co., Ltd. (Business Registration Number: 91320411MADH337131), located at Room 08009, Building 3, Hefengyuan, Longye Road, Longhutang Street, Xinbei District, Changzhou City, Jiangsu Province, China.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, engage our consulting services, or interact with us through any communication channel. We are committed to protecting the privacy and confidentiality of all individuals and organisations we work with.

2. Information We Collect

We may collect the following categories of personal data:

• Identity Data: Full name, job title, company name, professional qualifications
• Contact Data: Email address, telephone number, business address
• Financial Data: Bank account details, payment card information, billing addresses
• Technical Data: IP address, browser type and version, time zone settings, operating system, device identifiers
• Usage Data: Information about how you use our website, including pages visited, time spent, navigation paths, and referral sources
• Communication Data: Records of correspondence, meeting notes, project-related communications
• Cookie Data: Information collected via cookies and similar tracking technologies (see our Cookie Policy for details)

3. How We Use Your Information

We use your personal information for the following purposes:

• Service Delivery: To provide consulting services, manage client engagements, and deliver project outcomes
• Communication: To respond to enquiries, send project updates, and provide relevant industry insights
• Business Operations: To process payments, manage contracts, and maintain accurate business records
• Website Improvement: To analyse usage patterns and enhance the functionality and content of our website
• Legal Compliance: To comply with applicable laws, regulations, and professional standards
• Marketing: With your consent, to send information about our services, events, and publications that may be of interest to you

4. Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose, such as subscribing to our newsletter or accepting cookies
• Contractual Necessity: Where processing is necessary to fulfil a consulting engagement or other contract with you, or to take pre-contractual steps at your request
• Legitimate Interest: Where processing is necessary for our legitimate business interests, such as improving our services, marketing, and maintaining security, provided those interests do not override your rights
• Legal Obligation: Where processing is necessary to comply with a legal or regulatory obligation

5. Information Sharing

We do not sell your personal data. We may share your information with the following categories of recipients:

• Service Providers: Trusted third parties who assist us with website hosting, payment processing, analytics, email delivery, and IT support — all bound by strict confidentiality agreements
• Professional Advisors: Lawyers, accountants, and insurers who provide professional advice to our business
• Legal Requirements: Government authorities, regulators, or law enforcement agencies when required by applicable law or to protect our legal rights
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change

6. Client Engagement & Project Data

In the course of our consulting engagements, we may collect and process data specific to the client's business context. This includes:

• Project briefs, scoping documents, and engagement letters
• Organisational data provided for analysis and strategic planning
• Interview transcripts, survey results, and workshop outputs
• Financial models, operational data, and performance metrics shared during engagements

All client engagement data is treated with the highest level of confidentiality and is governed by the terms of our engagement agreements. Access is strictly limited to authorised project team members.

7. Professional Communication Records

We maintain records of professional communications including emails, meeting minutes, and project updates. These records are retained to ensure continuity of service, support engagement quality, and satisfy professional record-keeping obligations. Communications may be stored in secure cloud-based systems and are accessible only to relevant team members.

8. Service Delivery & Performance Data

We track engagement milestones, deliverable timelines, and project performance data to ensure the quality and timeliness of our services. This data may include time tracking records, progress reports, and client satisfaction feedback. Performance data is used internally to improve our processes and may be anonymised for benchmarking purposes.

9. Billing & Invoicing Information

We collect and process billing information necessary to invoice for our services, including company details, purchase order numbers, payment terms, and bank account information. Financial data is stored securely and retained for the period required by applicable tax and accounting regulations. We use reputable payment processing services that comply with industry security standards.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our general retention periods are:

• Client engagement data: 7 years after the conclusion of the engagement, in line with professional and legal obligations
• Financial records: As required by applicable tax and accounting regulations (typically 7-10 years)
• Marketing data: Until you withdraw consent or unsubscribe
• Website analytics data: 26 months
• Enquiry correspondence: 3 years after last contact

When data is no longer required, it is securely deleted or anonymised.

11. Your Rights

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

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data, subject to legal obligations
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Restrict Processing: Request limitation of how we process your data
• Right to Object: Object to processing based on legitimate interest or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us using the details provided in the Contact Us section below. We will respond to your request within 30 days.

12. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls and authentication mechanisms
• Regular security assessments and vulnerability testing
• Employee training on data protection and confidentiality
• Secure cloud infrastructure with industry-recognised certifications
• Incident response procedures for data breach management

While we strive to protect your personal data, no method of electronic transmission or storage is 100% secure. We encourage you to contact us immediately if you suspect any unauthorised access to your information.

13. International Transfers

As a globally operating consulting firm, your personal data may be transferred to and processed in countries outside your jurisdiction, including China, the Netherlands, and other locations where our team members or service providers are based. When we transfer data internationally, we implement appropriate safeguards such as:

• Standard contractual clauses approved by relevant data protection authorities
• Ensuring recipients maintain adequate data protection standards
• Obtaining your explicit consent where required by law

14. Children's Privacy

Our services are designed for business professionals and organisations. We do not knowingly collect or solicit personal data from individuals under the age of 16. If we become aware that we have collected personal data from a child without appropriate parental consent, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us immediately.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last updated" date at the top of this page
• Post a prominent notice on our website
• Where appropriate, notify you directly via email

We encourage you to review this policy periodically to stay informed about how we are protecting your data.

16. Contact Us

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

Changzhou Jingtu International Trade Co., Ltd.
Room 08009, Building 3, Hefengyuan, Longye Road,
Longhutang Street, Xinbei District,
Changzhou City, Jiangsu Province, China

Email: info@flowclear.xyz
Phone: +31 117 870 579

Business Registration Number: 91320411MADH337131