Privacy Notice

1. Who we are

This Privacy Notice describes how PE Andrei Vavilov (“we”, “us”, “our”), operating the reflow.deals service (the “Service”), collects, uses, shares, and protects personal data. For the purposes of applicable data protection law, PE Andrei Vavilov is the data controller of personal data processed in connection with the Service.

For any questions about this notice or your personal data, contact us at re@g24.tech.

2. Categories of personal data we collect

• Account data: name, email address, phone number, login credentials, profile data.
• Agent and lead data: information you submit about deals, leads, contacts, and clients.
• Communications: messages you send to support, feedback, and correspondence.
• Usage and telemetry: pages visited, actions taken, device identifiers, browser type, IP address, approximate location, log and diagnostic data.
• Payment-related data: wallet balance and transaction history within the Service. Card details and billing information are collected directly by our Merchant of Record, Paddle, and are not stored by us.

3. Purposes and legal basis

We process personal data for the following purposes and on the following legal bases:

• Providing the Service (account creation, agent wallet, lead exchange) — performance of a contract.
• Security and fraud prevention — legitimate interests and legal obligation.
• Customer support — performance of a contract and legitimate interests.
• Service improvement and analytics — legitimate interests.
• Marketing communications — consent, where required by law.
• Compliance with legal obligations — legal obligation.

4. Sharing of personal data

We share personal data with the following categories of recipients:

• Service providers and subprocessors that host our infrastructure, provide analytics, email, and support tooling.
• Paddle, our Merchant of Record, for the sale of paid features and balance top-ups, subscription management, payments, tax compliance, invoicing, and refund handling. See Paddle’s privacy notice at paddle.com/legal/privacy.
• Professional advisers such as lawyers and accountants, where reasonably necessary.
• Competent authorities where required by law or to protect our rights.

5. International transfers

Personal data may be transferred outside your country, including to the UK, EEA, and the United States, where our service providers operate. Where required, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses or equivalent mechanisms.

6. Data retention

We keep personal data for as long as needed to provide the Service and meet the purposes described in this notice, and thereafter for the periods required by law (for example, tax and accounting records). When data is no longer needed, it is deleted or anonymised.

7. Your rights

Subject to applicable law, you have the right to:

• access the personal data we hold about you;
• request rectification of inaccurate or incomplete data;
• request erasure of your data;
• request restriction of, or object to, processing;
• data portability;
• withdraw consent at any time, where processing is based on consent;
• lodge a complaint with your local data protection authority.

To exercise any of these rights, contact us at re@g24.tech. We will respond within the period required by applicable law (typically within one month).

8. Security

We implement appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and regular review of our security practices. No system is fully secure, but we work to mitigate risks proportionate to the data we process.

9. Cookies

The Service uses cookies and similar technologies that are strictly necessary for authentication and core functionality. Where we use analytics or marketing cookies, we ask for your consent and provide controls to manage your preferences.

10. Changes to this notice

We may update this notice from time to time. Material changes will be communicated through the Service or by email. The “Last updated” date above reflects the most recent revision.