Privacy Policy

1 About this Policy

1.1 Who we are

This Privacy Policy is issued by the business operating onflowads.com from India under the name Onflow Ads, which is subject to Indian law and to the jurisdiction of the Indian courts ("Onflow Ads", "we", "us" and "our"). We are the Data Fiduciary under India's Digital Personal Data Protection Act, 2023 for the Personal Data this Policy describes, and the controller of that data under the EU General Data Protection Regulation and the UK GDPR where they apply. Our contact details are in section 29.

Where we collect information that Indian law treats as sensitive personal data, such as a password or financial information, we collect it with your consent, given when you provide it, and use it only for the purposes this Policy describes for that information.

1.2 What this Policy covers

This Policy applies to Personal Data we process when you use any of the Services: the Website at onflowads.com and its subdomains, including the Guide and our blog; our Telegram bot, @OnflowAdsBot (the Bot); our emails and notifications; and the support chat, contact form and tickets. The Website and the Bot are one service with one Account. This Policy applies to Visitors as well as Members. It does not cover services that other people run, even when we link to them.

1.3 How to read this Policy

The following statements are commitments. We change them only with the notice set out in section 26:

1. we do not sell your Personal Data (section 16);
2. we do not train AI models on your Personal Data (section 12.4);
3. we never show your email address to another Member who deals with you (section 13.2); and
4. no member of our team ever asks you for your password or a verification code, and we ask you to enter a code only in a step on onflowads.com that you started yourself, including a request in our support chat (section 21.3).

The rest of this Policy describes our practices, which we keep accurate and update under section 26. If a statement here does not match what the Services do, tell us at privacy@onflowads.com.

1.4 Languages

This Policy is written in English. On request to privacy@onflowads.com, we provide it, within a reasonable time, in any language listed in the Eighth Schedule to the Constitution of India. To the extent the law allows, the English text governs.

2 Words used in this Policy

A word in this Policy that begins with a capital letter has the meaning given to it in section 2 of the Terms of Service. That includes Personal Data, Processing, Data Fiduciary, Data Principal, Processor, Account, Member, Visitor and Wallet. A "controller" under the GDPR is a Data Fiduciary, and a "data subject" is a Data Principal. "Personal data" written in lower case means the same as Personal Data. "Including" means including without limitation. Headings and the In-short boxes help you find your way; they are not part of this Policy.

3 Who is responsible for your data

3.1 Where we decide, we are responsible

We are responsible for Personal Data where we decide why and how it is processed: your Account, your use of the Services, payments and payouts, support, security and the enforcement of our Terms.

3.2 Where you decide, you are responsible

You decide, and are responsible under data-protection law, for Personal Data that you choose to collect, publish or send through the Services. That includes:

1. personal data contained in your creative, listings, posts and other Your Content;
2. your own channel audience and how you deal with it.

You must have a lawful basis for that data and give the people concerned any notice the law requires. Terms, section 23.6 sets out these duties.

3.3 Where neither of us decides

Telegram and the other platforms you use with the Services decide how they process data on their own services, under their own terms and privacy policies. We do not control them and are not responsible for them.

4 Information you give us

4.1 Your Account

When you create and use an Account we collect:

1. your name, your email address, a password (which we store only in a form that cannot be read back), how you signed up, and the identifiers we assign to your Account;
2. your confirmation, when you create the Account, that you are 18 or older and that you accept the Terms and this Policy, and the same age confirmation each time you add funds;
3. your Account role, Advertiser or Channel Owner, which you choose once, and a record of when it was set and of any correction we made to it, with the reason (Terms, section 3.2). We use your role to show you the dashboards, menus, notices and Bot messages for your side, to let you start only what your role allows, to choose which of our emails about a product are relevant to you, and so that our team and the Support Assistant can see which side you act on when they help you;
4. if you turn on two-factor authentication, the information needed to check your codes;
5. your notification and marketing choices; and
6. your Account's standing and any restriction on it.

Before you start anything new in our marketplace products, your Account may need a verified email address and a link to the Bot (Terms, section 3.4).

4.2 Your Channels

When you connect or list a Channel, we collect what the marketplace needs to list, match, price and verify it: its name, link, description, category, language, audience and engagement figures, and the prices and availability you set. We also keep a preview of your channel's recent public posts, shown to signed-in advertisers. Section 6 explains what we read from Telegram.

4.2.1 Your Channel's audience profile. To list a Channel you must tell us three things about it, its audience profile: the country it is run from, the country most of its audience is in, and the language it posts in. They are required to list a Channel and are your own statement, not something we measure. Where your Plan includes it, the audience profile is shown with the listing on the marketplace and on the Channel's public page, which anyone can open (section 13.3), and advertisers' audience-country and language filters match its audience country and language. Where your Plan does not include it, your answers are kept with the listing and our staff can see them, but they are not shown to other users or matched by those filters until your Plan includes it. The country a Channel is run from may say where you are. We never ask for your precise location (section 9).

4.3 Campaigns, creative, Orders and proofs

We collect the creative you submit (text, images, buttons and links), the details of your Orders and Campaigns (target links, schedules and budgets), and the delivery figures, proofs and certificates that result. Creative is not private. Proof and certificate pages can be opened by anyone who holds the link, and a certificate shows the price and any problem we found.

4.4 Payments, your Wallet and payouts

We keep a record of every transaction: the amount, currency, method, reference, status, fees and the movement in your Wallet. We also record the network address and device details behind each payment, to protect against fraud and settle disputes.

Card and UPI details are entered on our payment partner's secure page. We never see your full card number or your UPI PIN. Cryptocurrency payments are handled on our crypto payment partner's own page. For a payout, we collect the payout destination you give us, such as a UPI ID, a Telegram username or a cryptocurrency address, depending on the methods your Wallet offers. If you ask for a top-up refund, we keep your request, the reason you give, our decision and its reason, the payment reference and, for a cryptocurrency refund, the address you give us (Refund Policy, section 10). The Terms, section 12 explain the Wallet.

4.5 Verification for payouts

As your total earnings grow, we may require you to verify your identity before we release further payouts (Terms, section 7.12). The first level asks for your legal name and country. At higher levels, our team tells you what is needed, why it is needed and who will see it before you send anything. We use what you send only for verification, for meeting our legal obligations and for preventing fraud. We do not store government identity numbers in your Account.

4.6 Support, the contact form and the support chat

1. Contact form. Your name, email address and message.
2. Support tickets. Your name, email address, an optional phone number, the page you were on, your browser and network address, and the messages exchanged.
3. The support chat. It may be answered first by the Support Assistant (Terms, section 10.7). Section 12 explains what reaches an AI model provider. On some Plans the Support Assistant can carry out a task you confirm (Terms, section 10.10); we keep a record of what it did for you, with sensitive values hidden. The chat cannot prove an account for you: account questions are answered for a signed-in Member, or through the routes in section 22.2.
4. Signed-out chat. If you use the chat while signed out, we keep limited technical information about your browser and connection, to prevent misuse and to remember your answer to the chat's notice, and delete it after about six months.
5. Screenshots. The support chat does not accept screenshots (Terms, section 10.9).
6. Closed chats and reports. When a chat closes, we email you a copy where we have your email address, and we keep the conversation as section 20.1 describes. If you report an answer from the Support Assistant, we keep that conversation until the report is resolved.
7. Improving our answers. We may turn what we learn from support conversations into general answers for our support knowledge base. Those answers are written to answer questions in general, not about you.
8. Support links. A link in a support email opens that conversation to anyone who holds it, so do not forward it.
9. Support restrictions. If we restrict access to support because of abuse, we keep a record of the restriction for as long as it applies.
10. Onflow AI context. If you buy Onflow AI context (Terms, section 10.11), we keep a record of each purchase, of what you paid with Onflow Credit and from your Wallet, and of each unit added, used (with the conversation and the message it paid for), refunded or expired. These are financial records: we keep them after the conversation is deleted and after your Account is deleted (section 20.2).

4.7 Our blog newsletter and comments

If you subscribe to our blog, we keep your email address and a record of your confirmation, and send you new posts only after you confirm. If you unsubscribe, we keep a record that you did, so that we do not email you again. Where comments are open and you comment on a post, we keep your name, email address and comment. Your name and comment appear only if we approve them; your email address is never published.

4.8 Onflow Credit

We keep a record of your Onflow Credit: each entry, its source (such as a referral reward or a make-good), the reference it relates to, the date and the balance after it. We use it to show you your statement, to apply and reverse credit as the Terms, section 30, describe and to check that every balance is right.

4.9 Reports, Appeals and statements

When you report a Campaign or another Member, make an Appeal or give a statement, we keep what you send, including testimony and screenshots. The Member you report never sees your report or your evidence.

5 Information collected automatically

5.1 Device and connection

When you use the Services we receive your network address, your approximate country, your browser and device type, and the page that referred you. We use them to provide the Services and for security and preventing fraud and abuse.

5.2 Activity and security records

We keep a record of actions taken on the Services for up to about 13 months. Separately, we keep records of sign-ins and security changes, including the network address and device used, for as long as they are needed for security and legal claims. Staff access to your Account is recorded. Some operational records are shared with our team through internal communication tools, with sensitive values removed or masked.

5.3 How you use the Services

We record which pages and features you use and the actions you take, such as signing up, placing an Order or making a payment.

5.4 What we work out about you

From your activity we work out your Reliability Score, your standing and your delivery record (Terms, section 15). When you open an Account, we record once how you first found us: the link you arrived from and any campaign tags on it. If you arrived through a Member's link, that Member can be rewarded, and sees only totals and your Onflow Ads ID (Terms, section 31). We check that referrals are genuine, and we may refuse or reverse rewards that are not.

5.5 Security identifiers and device information

To protect accounts and the marketplace, we store random identifiers in your browser, in cookies and similar browser storage, and use information about the device and browser you use. We set them for every visitor, signed in or not, and connect them to an Account only while you are signed in. We use them for security and to prevent fraud and abuse of our rules (Terms, section 16). They are not used for advertising, not sold and not shared outside our service providers, except as section 15 allows. Where they lead to a restriction, you can ask a person to review it.

5.6 Advertising link, join and conversion records

When someone taps a link in an advertisement, a Cross-Promotion or a Syndicate attribution line we published, we record the tap without storing the network address or the full browser line it came from. At the moment of the tap we work out the device type, operating system, browser, language, the name of the referring site (never the full address of the page) and, when our network provider tells us, the country, and we keep those with a coded value that lets us count each reader once a day. That value is made from the network address and browser with a random key that changes every day and is deleted two days later, so it cannot link a reader from one day to the next or be traced back to an address once the key is gone. If you are signed in to an Account when you tap, we also record which Account it was, so that taps by the advertiser or the Channel Owner on their own links are not counted and fraud can be detected. We do not look up a location from the network address. The network address is used only in memory, to make that coded value and to spot automated or abusive tapping, and is never written down. We delete the detailed record of a tap after 395 days and keep only daily totals, which identify no one. The same 395 days apply to the per-reader records of visits and conversions reported by our measurement tag (section 8.1) and of visits through a referral link, whose daily totals per link (visits, readers that day, referring sites and device types) are kept. When someone presses a button under a Subscriber Exchange ad in Telegram, the Bot records which button and that person's Telegram ID, so that each person is counted once per placement; we delete that record after the same 395 days and keep only the ad's daily totals per button. When someone joins a channel through a campaign link or a Syndicate attribution line, we count the join without storing who joined. We never count who leaves. Opening one of our short links sets no cookie. If an advertiser uses our measurement tag on their own website, section 8.1 applies.

We also count, per day and without any identifier, how often the Verified, Brand Safety Shield and Pulse marketplace pages are viewed and how often a quote or purchase is started from them, and we record a Pulse poll's total number of voters over time. These counts set no cookie and use no browser storage. Advertisers see the figures for their own campaigns and Channel Owners for their own Channels, as totals, never as a list of readers.

6 Telegram and connected platforms

6.1 Signing in through Telegram

When you sign in with Telegram, Telegram confirms your identity to us and shares your Telegram account number (your Telegram ID), name, username and profile picture. It does not share your phone number, contacts or messages.

6.2 The Bot

The Website and the Bot are one service with one Account (Terms, section 11). Linking the Bot connects your Telegram account to your Account. A link to the Website that you open from Telegram opens it like any other browser: it does not sign you in or share your Telegram profile with us. An Account opened by signing in with Telegram is yours, and every right in this Policy applies to it.

If the Telegram account you link already has an Account that was opened by signing in with Telegram, we offer to combine the two, and combine them only if you confirm, after signing in with that Telegram account on the Website to show it is yours (we use that sign-in only for this check). Restrictions on either Account carry over to the combined Account; you can ask a person to review the result. The Bot keeps only the records it needs to deliver, notify and check. Joining our Updates Channel is described in Terms, section 34.

6.3 What the Bot does not do with your Channel

The Bot never messages your subscribers, posts only what you agreed to, and is never given your subscriber list.

6.4 Channel information we read

We read the public information Telegram makes available about your Channel. We also read:

1. the Channel's list of administrators, including co-administrators' Telegram account numbers, to confirm that you run the Channel and to attribute actions taken in it;
2. where a product requires it and an Onflow Ads account is already one of your Channel's administrators, your Channel's record of administrative actions for the post or member in question, read through that account; we never ask you to add it. We keep what we read as evidence for the Decision it concerns, including after your Account is deleted;
3. for a cross-promotion, whether the other party remains a member of the Channel as the deal requires.

6.5 Signing in through Google or Apple

If you sign in with Google, Google shares your basic profile and email address with us. If you sign in with Apple, Apple shares your name and email address, which you may choose to relay through Apple's private address.

6.6 Other platforms

If we add other platforms, we will update this Policy before you can connect them.

6.7 Research and trust features

These records serve Onflow Verified, Brand Safety Shield, Syndicate, Pulse and Brand Lift (Terms, section 6), where and when we offer them:

1. Fingerprints of posts. If the Channel Owner switches on Post fingerprints for a Channel connected to the Services (they are off until switched on), then when that Channel publishes or edits a post, the Bot records a fingerprint of it: identifiers of its media, a short code computed from its text, the text's length, whether it has links and to which sites, and when it was posted or edited. We never keep the post's text in this record. The Bot also records these fingerprints, whether or not Post fingerprints is switched on, for a Channel that hosts a Syndicate licence, under the host's acceptance of the licence: for every post published or edited in that Channel from when we start publishing the licensed post until one hour after its minimum time live has ended. Fingerprints are kept for 30 days. Fingerprints from Channels whose Owner switched them on are used to match reposts of listed Syndicate items (the repost radar uses no others); fingerprints from a Channel hosting a licence are used only to find the licensed post and check that it keeps its attribution line. Brand Safety Shield does not use fingerprints; it uses the text described in point (b).
2. Text classified for Shield. While a Channel carries a placement booked with Shield on, the text of the Channel's new posts is held only long enough to classify it against the advertiser's choices, and deleted within one hour at most. We keep the verdict and a link to the post, not the text.
3. Scores and verdicts. Verified scores and their parts are computed from records we already hold about placements on the Services. Brand Safety verdicts are computed from a Channel's recent public posts. We keep scores, verdicts and the evidence links behind them so that they can be reviewed, appealed or corrected.
4. Poll totals. Pulse polls are anonymous. We receive and keep only the total votes for each option in each Channel, never who voted or how any person voted. The Bot records these totals only for the polls it sent for Pulse. We use them for the report of the poll or study they belong to and, combined with other polls and without naming the brand, the Channel or the question, for benchmarks.
5. Syndicate items. For a post you list for licensing, we keep what is needed to republish it, including its text or caption, until you remove the item, and any translation you approve. A post can be listed only from a public Channel; we read what we need from the Channel's public page.
6. Repost radar alerts. When a fingerprint of a post in a Channel whose owner has turned on post fingerprints matches a listed Syndicate item, we record an alert: the two Channels, the matching post's identifier and date, whether its media or its text matched, and what was done about it. We tell the owner of that Channel and, where their Plan includes it, the owner of the item. An alert never penalises anyone by itself.
7. Checks that a hosted poll is in place. While a Pulse poll runs in a host's Channel, the Bot checks from time to time that the poll is still there and records when it checked and what Telegram answered. We keep these records with the poll so that a penalty is applied only when they prove it (Terms, section 6.10).
8. Payout disputes and early releases. When a brand disputes a host's payout, we keep the reason and the evidence the brand gives, the decision and its reason. When a brand releases a payout early, we keep who did it and when, the network address the request came from, each item the brand acknowledged and the amount released. We use these records to decide the dispute, to prevent fraud and to answer questions about the payment (Terms, section 6.8 and section 6.9).
9. Paid Promotions Concerns and early releases. When an Advertiser raises a Concern about a booking, we keep the reason and the evidence they give, the network address the request came from, a copy of what our checks had recorded about the post at that moment, the decision and its reason. When an Advertiser releases a Channel Owner's payout early, we keep who did it and when, the network address the request came from, each item they acknowledged and the amount released. We use these records to decide the Concern, to prevent fraud and to answer questions about the payment (Terms, section 7.9 and section 7.10).
10. Penalty cases. Before a Pulse penalty that a person decides, our team records a case: what was found, the evidence, a fingerprint of the evidence that shows it has not been changed, your answer, and the decision with its reason. You see a plain summary of the evidence; our team sees all of it.

7 Information we receive from others

We receive:

1. from our payment partners, the payment reference, status and amount, and sometimes the type of method and the last four digits of a card;
2. from our crypto payment partner, the transaction reference and the confirmed amount;
3. the result of security checks; and
4. from other people, information about you in reports, complaints and Appeals.

If someone sends us information about you that we did not ask for and do not need for a purpose in this Policy, we do not use it.

8 People who are not our users

8.1 Readers of promotions

Taps on links in advertisements are recorded as section 5.6 describes, and joins through a campaign link or a Syndicate attribution line are counted without storing who joined. An advertiser may add our measurement tag to their own website. If you arrive there from one of their ads, the tag lets us count the visit and any conversion they report. It sets no cookie of ours and does not identify you; it remembers the campaign link in your browser's storage on that site so that a later conversion can be counted. The advertiser must tell you about it in their own privacy notice. Ad clicks and conversions are counted in aggregate and never attributed to a person (Terms, section 17.4).

8.2 How long these records last

We never store the network address of a tap. We delete the detailed record of a tap, and the per-reader records of visits and conversions our measurement tag reports, after 395 days; the daily totals we keep identify no one. The coded values we keep are pseudonymous, and we do not use them to identify anyone.

8.3 Taps on some older promotions

On some older promotions, tapping a button opens our Telegram bot, and Telegram tells the bot your Telegram account number. We use it only to count unique taps; the advertiser sees totals.

8.4 The audience of a Channel

We do not collect a Channel's member list.

8.5 People you tell us about

Creative, screenshots, tickets and reports can contain information about other people. We use it only for the purpose for which it was given to us. If you give us information about someone else, you must be entitled to do so.

8.6 Administrators and other people we process data about

We also process Personal Data about:

1. administrators of a Channel, including their Telegram account numbers and their actions in the Channel's administrative record (section 6.4);
2. blog subscribers and commenters (section 4.7); and
3. people who use our contact form or our support chat without an Account (section 4.6).

8.7 Your rights if you are not a user

If you are not a Member and believe we hold Personal Data about you, you have the rights in section 22. Write to privacy@onflowads.com.

9 What we do not collect

We do not ask for, and do not intentionally collect:

1. special categories of personal data, such as data about health, religion, sexual life, biometrics or political opinions;
2. your full card number, your UPI PIN or other full payment credentials;
3. your Telegram password or login codes;
4. your precise location;
5. a Channel's member list; or
6. data bought from data brokers.

Where we look at a specific person, such as the other party to your deal, an administrator who acted on a promotion or a person who tapped an older promotion, we say so in section 6 and section 8, and we use that information only for the purpose stated there. Do not send us special categories of personal data in support messages or creative.

10 Purposes and lawful bases

Under Indian law, we process your Personal Data for each purpose in the table because you gave it to us voluntarily for that purpose (a legitimate use), because the law requires it or for legal claims, or with your separate consent where the table says so. You can withdraw a consent as easily as you gave it (section 22.1), and withdrawal does not affect processing already done. The purposes for which you give us information include protecting the Services, their Members and us from fraud and abuse, and enforcing our Terms. Under the GDPR and the UK GDPR, the basis for each purpose is given in the table.

10.1 No new purpose without notice

We do not use your Personal Data for a purpose that is incompatible with the purposes set out in section 10. If we want to use it for a new purpose, we tell you first under section 26, and we ask for your consent where the law requires it.

10.2 Our legitimate interests

Where we rely on legitimate interests, those interests are: keeping the Services and their Members secure; preventing fraud and abuse; enforcing our Terms; understanding and improving the Services; and establishing, exercising and defending legal claims. We weigh them against your rights and do not rely on them where your rights override them.

10.3 What you must give us

The information we need to open an Account, to take a payment, to make a payout or to list a Channel, including its audience profile (section 4.2.1), is required. If you do not give it, we cannot provide that part of the Services. Everything else is optional, and the product tells you which fields are required.

11 Scores and automated decisions

11.1 What is decided automatically

We use Automated Measures alongside people. Decisions that can be made automatically include:

1. your Reliability Score and your standing, which can affect which products you can use and how you appear to other Members;
2. whether your standing meets the minimum a product requires before you start something new in it;
3. the reliability band read when a Pulse payout is released, which sets how long it waits (Terms, section 6.7); a payout never waits less than the time the Terms set for every member;
4. the reliability band read when a Paid Promotions payout is released, which sets how long it waits in the same way (Terms, section 7.2);
5. your reliability band, which limits what you can start in some products (Terms, section 15.12); it is read from your own Account. Where we link another Account to you on the standard described in section 5.5, never on the device model, the network address or the location alone, a lower band on that Account does not lower yours by itself: it opens a review, and a person decides on the evidence whether to restrict your Account. A person also reviews the link if you ask;
6. whether an automatic penalty may be applied: only on a complete record of evidence (section 11.4); otherwise a person decides;
7. a Hold while an Account is Under Review;
8. Decisions about broken agreements, which can be a warning, a mark on your standing or a movement of money under the terms of the deal within the Holding Period; where it is unclear who was responsible, a person decides;
9. restrictions while a Debt is unpaid;
10. refusal of referrals that are duplicated or made to yourself;
11. content checks, which can refuse or hold a submission. AI never applies a penalty on its own: a person confirms any penalty an AI check suggests;
12. prices that depend on your history, which are always shown before you pay; and
13. automatic orders and renewals that you set up yourself.

11.2 A person will look if you ask

No automated decision closes your Account permanently. Where an automated check moves money under the terms of a deal, you can appeal and a person will review and can reverse it. You can appeal from the Appeal button shown with a Decision or on your reliability page (Terms, section 15.4), or by writing to privacy@onflowads.com. Where the GDPR or the UK GDPR applies, you have the right to obtain human intervention, to express your point of view and to contest a decision based solely on automated processing that significantly affects you.

11.3 What we will tell you

On request, we will explain the main reasons for an automated decision about you, the main factors involved and what would change it. We do not disclose details of how our protections work that would help people evade them.

11.4 The evidence behind a penalty

Before an automatic penalty, we record the evidence for it (Terms, section 15.10): what was observed and when, each check we made and when, what Telegram answered (its status and error description, never access keys), the checks that ruled out other explanations, why the event was attributed to you, and whether any problem on Telegram's side or ours was found at the time. Each record carries a fingerprint that is linked to the record before it, so that any change would show. When our Bot is added to or removed from a Channel or group, or its rights there change, Telegram tells the Bot which Telegram account made the change, and we keep that report to tell whether a removal was your own act. When a penalty is reversed, we record who reversed it, why, and each effect that was undone, including any money paid back. We use these records to decide whether a penalty may be applied, and for reviews, appeals and reversals. You can have a plain summary of the evidence about you; our team sees all of it.

12 AI features

12.1 What the AI does

Our AI Features help you write copy, create images on some Plans, understand your figures and find suitable matches, and the Support Assistant answers support questions and, on our careers pages, questions about working with us. We also use AI to screen listings, posts, pictures and reviews against our rules, and to prepare summaries and review material that help our team handle support, disputes and moderation. A person makes the decisions that AI helps our team with.

12.2 What reaches an AI model provider

When an AI feature runs, the content it works on is sent to an AI model provider we use. The table shows what that is.

Before your first conversation, and again whenever the notice changes, you are shown a short notice about the AI support chat, and you can decline it; on our careers pages the notice links our careers privacy notice (section 31). You can also ask us to keep AI out of your support; a person will then answer you.

12.3 What we keep

We log that an AI feature ran, not what you asked or what it answered. The exception is text that our checks blocked, which we keep as evidence. Support conversations are kept as section 20 describes. With each support conversation we also keep the assistant's working notes on it (the topics, the pages it used, what it had already said, and facts you told it in the conversation, such as your name or budget) and, for each answer, a technical record of the checks it passed, the pages it drew on and what it cost, which holds none of your words; we delete them with the conversation. The support chat does not accept screenshots or other pictures.

12.4 Training

We do not train AI models on your personal data. We do not sell or license your content to anyone for training. Our AI model providers process content to provide the feature to us, under their terms with us. You can ask us which provider processed your data and on what terms (section 14.5).

12.5 What AI output is, and is not

AI output is a draft that you review before you use it (Terms, section 10.3). AI model providers may process data outside your country, including in the United States (section 17). We may change the providers we use.

12.6 If AI is switched off

If we switch an AI feature off, nothing is sent to an AI model provider for that feature.

13 What other users can see about you

13.1 What a counterparty sees

A Member you deal with sees your display name, the information about your Channel that the deal needs, your standing, and the details of the deal itself.

13.2 What a counterparty never sees

Other Members see you by your display name: the name you set or, until you set one, a name derived from your email address (for example, john.doe@… reads as John Doe). No form of the address itself — whole, partial or masked — is rendered to another Member, not even a masked form such as al****@g***.com. A counterparty also never sees, through the Services, your Wallet balance or ledger, your payout destination, your verified legal name, your network address, or your other Channels and Campaigns unless you make them public.

13.3 What is public to anyone

Some things are public:

1. an active listing's page, which search engines may index, including the Channel's audience profile where the owner's Plan includes it (section 4.2.1) and the totals of thumbs-up and thumbs-down votes, never who voted;
2. reviews;
3. approved blog comments, with the name you gave; and
4. proof and certificate pages, to anyone who holds the link.

A link in a support email opens that conversation to anyone who holds it (section 4.6).

13.4 People who copy what is public

We cannot control copies that other people make of public information. We take measures against scraping, and scraping the Services breaches our Terms.

13.5 What our staff can see

Only staff who need it for their work can see your Account, and every access is recorded. Staff may change your Account only to help you, to enforce our Terms or to meet a legal obligation. Where a change affects your money, your sign-in or your access, we tell you and, where we can, why, unless the law or the integrity of an investigation prevents it. Staff will never ask you for your password or a verification code. If you ask us in the support chat to unlink your Telegram account, a member of staff may send you a one-time code by email or through our Bot; you type it into the chat, which checks it, and they see only whether it matched (section 19.5). A reply from our team carries an Admin ID, so that you can tell us who helped you. Staff do not look at Accounts out of curiosity.

14 Service providers and sub-processors

14.1 Categories of service providers

14.2 Payments and payouts

We use our payment partner for cards and UPI in India, our crypto payment partner, and the payout channels for the methods offered in your Wallet. They receive the amount, our references, what you enter on their pages and, for a payout, the payout destination you gave us.

14.3 AI model providers

AI model providers receive the content an AI feature works on (section 12.2). We name them to you on request.

14.4 Analytics, support and trust tools

Analytics providers receive your network address, device details, the pages you view and the actions you take. For a signed-in Member they also receive an account reference and, in the case of one of them, your name and email address. When a payment completes, we may report the purchase to an analytics provider under your account reference. Advertising partners receive information only after you accept marketing cookies (section 18.3). Where we use a review widget or a live-chat provider, it receives your network address and browser details; a live-chat provider may also receive your name, email address and basic Account details.

14.5 How we describe providers, and how to ask for details

We describe our service providers by category. You can ask us for more detail about the providers that process your data, including their names, by writing to privacy@onflowads.com. Our providers process Personal Data for us under written contracts, and we remain responsible for processing they carry out on our behalf. Adding a new category of provider, or a provider in a new country, is a material change under section 26.1.

15 Legal, safety and business disclosures

15.1 Legal requirements

We disclose Personal Data where we are required to by law, by a court order or by a lawful request from a government authority (Terms, section 16.6). Where the law allows, we tell you about a request for your data, unless the authority asks us not to or doing so would be unsafe or would harm an investigation.

15.2 Fraud, safety and enforcement

We may disclose Personal Data where we reasonably believe it is necessary to prevent or investigate fraud, abuse or harm, to enforce our Terms, to respond to our payment partners or platforms about a transaction or an Account, or to inform a victim where the law requires it.

15.3 Professional advisers

We may share Personal Data with our lawyers, accountants, auditors and insurers, who are bound by duties of confidentiality.

15.4 A change of business

If the Services, or the business that runs them, are merged, sold or transferred, or are the subject of a proposed transaction, we may share Personal Data with the other party and its advisers under a duty of confidentiality. Before Personal Data passes to a new owner, we will tell you, and the new owner must protect it as this Policy does unless it changes this Policy under section 26.

15.5 If the Services stop

If we stop providing the Services, we will give notice, let you withdraw any Withdrawable Balance and export your data, and delete personal data we no longer need, keeping only what the law requires.

16 We do not sell your personal data

16.1 Sale, and sharing for advertising

We do not sell your personal data. If you accept marketing cookies, our advertising partners receive information about your visit, which some US state laws call "sharing". You can refuse or withdraw at any time in Cookie preferences, and we honour Global Privacy Control signals.

16.2 What we do not do

We do not upload your Personal Data to advertising platforms to build audiences. We do not sell the data of anyone under 18. We have never sold Personal Data.

17 International transfers

17.1 If you are in India

Your data is hosted in the United States. It is also processed in other countries where our service providers operate: our network provider handles traffic in many countries, our messaging and communication providers hold data in their own data centres, our payment partners operate in India and elsewhere, and AI processing may take place in the United States or other countries. We transfer data outside India as Indian law permits, with contractual and security safeguards.

17.2 If you are in the EEA, the UK or Switzerland

Where we transfer your Personal Data to a country without an adequacy decision, we rely on the standard contractual clauses approved by the European Commission, the UK Addendum or the UK International Data Transfer Agreement, or an adequacy framework under which a provider is certified. You can ask us for a copy of the relevant safeguards.

17.3 The limits of safeguards

The laws of another country may allow its authorities to access data held there, whatever a contract says.

18 Cookies, storage and tracking

18.1 What we store, by category

18.2 Storage in your browser

Your cookie choice and some preferences are kept in your browser's own storage and are not sent to us.

18.3 Third-party tags, and your consent

The cookie banner offers Accept all, Reject all and Manage preferences. Closing the banner without choosing saves nothing. The choices are:

1. Essential. Strictly necessary storage, security identifiers, preferences, and the analytics tools we use to run and repair the Services, which are operated by third parties. Essential cannot be switched off in the banner. Section 18.5 explains the controls your browser gives you.
2. Marketing. Tags that measure our own advertising on other platforms. They load only after you accept them, and you can withdraw that acceptance at any time in Cookie preferences.

Some pages also load third-party content that sets or reads its own storage: a security check; a review widget and a live-chat widget, where we use them; and, on the pages where you pay or sign in, our payment partner's checkout and Telegram's sign-in. The Guide, our blog and our careers pages (but not the application form or its thank-you page) load the same analytics tools without a banner. We describe these tools by category; you can ask us for their names (section 14.5).

18.4 Global Privacy Control

If your browser sends a Global Privacy Control signal, we treat it as a refusal of marketing tags, and we do not show you the banner. We do not respond to Do Not Track signals, because there is no common standard for them.

18.5 Your browser controls

Your browser lets you block or delete cookies and other site data. If you block strictly necessary or security storage, you may not be able to sign in or use parts of the Services.

19 Emails, notifications and marketing

19.1 Messages that come with your Account

We send you messages about your Account, your transactions, security and changes to our documents while your Account is open (Terms, section 23). We keep copies of the emails we send as a record of delivery, except the two automatic emails our website sends about a job application (to our careers inbox, and the confirmation to the applicant), of which we keep no copy (section 31), and messages our team writes to you are kept as part of our records.

19.2 Marketing is separate, and opt-in

Basis: Consent. We send marketing email only if you opt in, by ticking the unticked box at sign-up or when you add funds, or by switching it on in your notification settings (Terms, section 23.2). Every marketing email has a one-click unsubscribe link, and the same setting turns it off. We check your choice when each message is sent. We send marketing email only to our own Members; we never buy, rent or pass on email addresses.

19.3 Telegram messages

The Bot sends you notifications by category. You can change the categories in your notification settings.

19.4 Browser notifications

If you turn on browser notifications, we keep the subscription details your browser gives us. We remove subscriptions that no longer work.

19.5 Verification codes by email or our Bot

We send verification codes by email. To unlink the Telegram account linked to your Account, we may also send a code through our Bot to that Telegram account. We never send codes by phone or WhatsApp, and only for a step you started yourself, including a request you made in our support chat. You type a code into the page or the support chat that asked for it, which checks it for you: our staff never see it, and no member of our team will ever ask you to read a code to them.

19.6 Our blog newsletter

We send no newsletter email until you confirm your address. Every newsletter email has a one-click unsubscribe link. When you unsubscribe, we keep a record that you did, so that we do not email you again.

20 How long we keep data

20.1 By category

We keep Personal Data for as long as we need it for the purposes in section 10, and then delete or anonymise it. Where the law requires us to keep data for longer, we keep it for that period.

20.2 When your Account is deleted

You can ask for your Account to be deleted as section 22.2 describes (Terms, section 24.1). Deletion takes effect after a waiting period shown when you ask, during which you can stop it. We will not complete a deletion while money is due to be paid to you, or while a deal with another Member is unfinished (Refund Policy, section 33).

Your Channels, listings, Orders, Campaigns, referral records, support tickets, contact messages and copies of emails we sent you are deleted. Creative that has already been published, and information that other Members hold, stays with them.

20.3 What we keep after deletion

After an Account is deleted we keep:

1. reports you made about others and how we handled them, as evidence about someone else; the screenshots you attached are deleted;
2. Decisions about rule-breaking and their evidence, including records read from a Channel's administrative record;
3. moderation and staff-access records;
4. the record of actions the Support Assistant took for you, with sensitive values hidden;
5. records of deletion and data-report requests;
6. our register of Onflow Ads IDs (section 28);
7. restrictions, for as long as they stand; and
8. messages our team wrote to you.

If you close an Account while it is restricted, we keep the records needed to stop the restriction from being avoided through another Account. After an Account is deleted, we may refuse a new Account for the same person, email address or Telegram account.

20.4 Bot records and messaging copies

When an Account is deleted, the Bot's records about it are erased. If any record linked to your Telegram account remains, we remove it on request. Copies of operational records shared with our team through internal communication tools may remain in those tools' history; on request we can delete a specific record.

20.5 Backups

We keep encrypted backups to recover from failures, with providers that store them for us. Deleted data can remain in a backup until that backup is deleted; we do not restore deleted data to live use.

20.6 Long-dormant Accounts

We may close an Account that has been inactive for a long time, after notice, as Terms, section 12.10 describes. The retention periods in section 20.1 continue to apply to its data.

20.7 Deleting inactive Accounts with an extremely low reliability score

This applies only to an Account in the Restricted or Frozen reliability band whose score stayed at or below the line in Terms, section 15.14 for 30 days. It never applies to a regular Account. To run it we use the time of your last sign-in or use of the Website, the Bot or our API while signed in, the times of your money movements, Orders and hostings, and your score history. If such an Account has no activity for 30 days, we warn you by email and, if linked, through the Bot, and delete the Account 7 days later unless you sign in, through the same deletion as when you ask us to delete your Account: the data described in section 20.1 as kept after deletion stays for the periods shown there, and everything else is deleted. We then tell you by email and through the Bot, and after that remove the link to your Telegram account and ask the Bot to erase its own copy. We keep a record of the process (when we warned you, your band and score at the time, how it was cancelled or carried out, and which notices reached you), with the Keep my account link stored only in a form that cannot be used, for as long as we keep the record of a deletion. Your score is not changed by any of this.

21 How we protect data

21.1 What we do

We use encryption in transit, access controls, strong password protection, optional two-factor authentication, monitoring, logging of staff access and regular encrypted backups. Access to personal data is limited to people who need it for their work. We review these measures and require our service providers to protect the data they process for us.

21.2 What we will not claim

No system is perfectly secure. We cannot guarantee that data will never be accessed without authorisation. If a breach affects you, we will tell you as section 25 describes.

21.3 Your part

Use a password you use nowhere else, turn on two-factor authentication, keep your Telegram, Google or Apple account secure, and treat proof, certificate and support links as private. Tell us at once at support@onflowads.com if you think someone else has accessed your Account. No member of our team will ever ask you for your password, a verification code, a card number, a UPI PIN or your Telegram login code. Enter a verification code only on onflowads.com, in a step you started yourself, including a request you started in our support chat; a code our support team sends you there, by email or through our Bot, is typed into the chat, which checks it without showing it to them. Anyone who asks you for one of these anywhere else is not us.

21.4 Reporting a vulnerability

If you find a security vulnerability in the Services, report it to our published security contact, listed at /.well-known/security.txt. That contact is support@onflowads.com; put "security" in the subject line. Give enough detail for us to reproduce the issue, and give us a reasonable time to fix it before you disclose it to anyone else. The published contact is the authority on the route: if we provision a dedicated mailbox it will appear there first.

We will not initiate action against a researcher who acts in good faith: who tests only against their own Account and their own test data, does not degrade the Services, does not access, alter or keep anyone else's data, does not exploit an issue further than is needed to show that it exists, does not ask for payment in exchange for the details, and tells us before telling anyone else. This commitment covers our systems and our own decision whether to take action. It does not bind the authorities or waive the rights of anyone else. The systems of Telegram, our payment partners and our other service providers are not in scope, and this section does not authorise testing them.

21.5 Automated protections

Automated protections limit repeated or abusive requests (Terms, section 16.7).

22 Your rights

22.1 What you can ask for

Subject to the law that applies to you and to section 22.4, you can ask for:

1. access: a summary of the Personal Data we hold about you, our processing of it, and the recipients we shared it with;
2. correction and completion of inaccurate, incomplete or outdated data;
3. erasure of data we no longer need or have no basis to keep (section 20.3 lists what we keep);
4. a copy of the data you gave us, in a structured, commonly used format;
5. withdrawal of consent, as easily as you gave it, without affecting earlier processing;
6. objection to processing based on legitimate interests or a legitimate use (section 10.2);
7. restriction of processing while a question about accuracy or basis is resolved;
8. human review of an automated decision (section 11.2);
9. nomination of a person to act for you on your death or incapacity (section 22.5); and
10. grievance redressal, and a complaint to the Data Protection Board of India or your supervisory authority (section 24).

Marketing email rests on your consent, which you can withdraw with one click (section 19.2). We do not treat you less favourably for exercising a right.

22.2 How to use them

Anyone can write to privacy@onflowads.com, from the email address on the Account if you have one, or use our contact form, with your Onflow Ads ID or other detail that lets us find the records. If your Account has no working email address, use the contact form and we will verify you another way. On eligible Plans you can also use the support chat to ask for your data report, after extra security checks, and to start a deletion of your Account, confirmed with a code we email you. You can stop a scheduled deletion at any time before it takes effect, from the notice in your Account or by contacting us. A data report from the chat may not include every record; ask by email for the rest.

We aim to acknowledge within 72 hours and always respond substantively within 30 days. If a request is complex and we need longer to complete it, we tell you why within those 30 days and complete it within the further period the law allows. Exercising your rights is free. We may refuse a request that is manifestly unfounded or excessive where the law allows, and will tell you why.

22.3 Verifying it is you

In the product, we rely on your sign-in and security codes. By email, a request from the Account's address is normally enough; otherwise we may ask for more proof. We use verification information only for verification. Someone acting for you must show us your authority.

22.4 When we may say no

We may refuse a request in whole or in part where the law requires us to keep the data, where meeting it would reveal Personal Data about someone else or affect their rights, where we need the data for legal claims, where the data is a record kept so that a restriction cannot be avoided (section 20.3), or where meeting it would harm the security of the Services or of other Members. We tell you the reason unless the law prevents it.

22.5 Nomination, and if an Account holder has died

To nominate a person to exercise your rights if you die or lose capacity, write to privacy@onflowads.com from the Account's email address with their name and contact details; we will record the nomination. A nominee or legal representative must give us proof of the death or incapacity and of their own identity.

22.6 Your duties when you make a request

You must not make a false or frivolous complaint, impersonate another person or suppress material information. Under applicable Indian data protection law, breaching these duties may carry a penalty.

23 Children and minimum age

You must be 18 or older, or the age of majority where you live if higher, to use the Services. You confirm this when you create an Account and each time you add funds. The rule applies however an Account was opened, including by signing in with Telegram. We do not ask for a date of birth or an identity document when you sign up. If we ask you for proof of your age (Terms, section 3.1), we use what you send only to confirm your age.

We do not knowingly process the Personal Data of a child. If we learn that an Account belongs to a person under 18, we close it and delete its data, except what the law requires us to keep. We do not carry out tracking, behavioural monitoring or targeted advertising directed at children. Where Indian law requires the verifiable consent of a parent or lawful guardian, including for a person with a disability who has a lawful guardian, we will not process the data without it. If you believe a child has given us data, tell us at privacy@onflowads.com.

24 Grievance redressal and complaints

24.1 Come to us first

Send a grievance about Personal Data to privacy@onflowads.com with "Grievance" in the subject line, or use our contact form. Include your Onflow Ads ID if you have one. Every grievance is acknowledged within 24 hours and resolved within the time the law requires for that kind of complaint, and in any event within one month of receipt.

24.2 Who is responsible

Our Grievance Officer and contact for questions about Personal Data is our designated Grievance Officer (named on written request). You can write to the Grievance Officer at privacy@onflowads.com or at our principal place of business in India. If we are required to appoint a Data Protection Officer, we will publish their details here.

24.3 Going further

If you are not satisfied with our response, you may complain:

1. in India, to the Data Protection Board of India, through its official website, once you have used our grievance route;
2. about a decision on content, to the Grievance Appellate Committee, as Terms, section 23.5 describes;
3. in the EEA or the UK, to your supervisory authority; and
4. elsewhere, to the authority that the law where you live provides.

We do not require you to arbitrate or to waive a statutory complaint route.

25 Personal data breaches

25.1 What we will tell you

If a personal data breach affects your Personal Data, we will tell you without undue delay: what happened, its likely consequences, what we have done about it, what you can do to protect yourself, and whom to contact. We tell you by email, in the product or, where relevant, through the Bot.

25.2 Regulators

We report a breach to the Data Protection Board of India and to other authorities as the law requires, including a detailed report within the time the law sets. Where the GDPR or the UK GDPR requires it, we notify the supervisory authority within 72 hours of becoming aware of the breach.

25.3 Delay only where the law requires

We delay telling you only where an authority directs us to, for example so as not to harm an investigation.

26 Changes to this Policy

26.1 Material changes

A material change is one that collects a new category of Personal Data, uses it for a new purpose, adds a new category of recipient or a new country, lengthens a retention period, or narrows a commitment in section 1.3. We give at least 30 days' notice of a material change by email and in the product before it takes effect (Terms, section 25). New processing that needs your consent is asked for, not assumed. A change required by law or needed urgently to address a security or fraud risk takes effect when it must (Terms, section 25.2), and we tell you as soon as we can.

26.2 Other changes

Other changes, such as corrections and clarifications, take effect on publication. Each version shows its publication and effective dates.

26.3 What this Policy said before

Earlier versions are no longer published on the Website; if you ask us at privacy@onflowads.com, we send you a copy of the version that applied to you. This version applies from 26 October 2026. Version 3.6 applied from 23 October 2026 and changed only what concerns job applicants and the careers pages. Version 3.5 applied from 20 October 2026 to anyone who first accepted it on or after that date, and from 21 October 2026 to everyone else. If you do not agree to a change, you may withdraw a consent we rely on (section 22.1) or ask us to delete your Account (section 22.2) before it takes effect.

27 Additional Privacy Terms

Additional Privacy Terms published under this heading form part of this Policy, each showing the date it was added, and govern their subject if they conflict with another section. One that makes a material change, as section 26.1 defines it, takes effect only after the notice that section requires; others take effect on publication. We keep a record of what we publish. An empty section is not proof that nothing is in force; ask us.

No Additional Privacy Terms are published at present.

28 Onflow Ads IDs

28.1 A pseudonymous reference

An Onflow Ads ID, such as OFA-123-4567 (a fictional example), is a reference we assign to an Account or another record. It is pseudonymous: it does not contain your name or contact details.

28.2 What it is linked to

An ID is linked in our records to the Account or record it names, so that we can find it when someone quotes it. An ID gives no one access to your Account or your contact details.

28.3 IDs on payments

Payment and Wallet records carry IDs and the details section 4.4 describes.

28.4 After an Account is closed

Our record of IDs and of enforcement actions is kept after an Account is closed so past references can be answered and decisions reviewed.

29 How to contact us

Onflow Ads, a business operating from India and subject to Indian law. Our legal name and address are not published on this page; we furnish them on written request to support@onflowads.com where a law, a court, a regulator, a payment provider or a dispute requires it, and the Grievance Officer below answers in that name.

Some requests, such as a data report or an Account deletion on eligible Plans, can also be made in the product (section 22.2).

30 Social media and off-platform channels

30.1 Plain links

Our links to our accounts on social networks, on the Website and in our emails, are plain links, with no click-tracking redirect and no widgets or scripts from those networks, so a network learns of your visit only when you click. The Bot offers the same accounts as buttons. To replace or remove those buttons later, it remembers which set it last sent you: your Telegram ID and a short code identifying that set. We delete that record when you delete your Account.

30.2 If you follow or interact with us there

If you follow us or interact with us on a social network, that network's terms and privacy policy apply to what you do there.

30.3 Messages sent to us there

Messages sent to us on social networks may go unread. To reach us, use the routes in section 29.

31 Job applicants: the careers privacy notice

This notice explains what happens to the information you send us when you apply for a job at Onflow Ads. It is also section 31 of our Privacy Policy, which says the same.

31.1 Who is responsible

Onflow Ads, a business operating from India, is responsible for the information in your application. Our Privacy Policy explains who we are and how to reach us.

31.2 What we collect

When you apply, we collect:

• about you: your name, your country, your time zone and, if you give them, your city and your age;
• that you are 18 or older, or the age of adulthood where you live if that is higher;
• how to reach you: your email address, your Telegram username, your WhatsApp or phone number if you give it, and the way you prefer;
• your languages and your level in each, the roles you chose and your main choice;
• your experience, your situation right now, your earliest start date, the hours a week you can give and the hours you could be online;
• your answers to the role questions, and to the question about how you would handle a real task;
• how well you know Telegram, whether you have used Onflow Ads (and your account, if you tell us), and how you heard about us;
• your pay expectations;
• the links you add, and why you want to join us;
• your CV;
• the two boxes you ticked at the end: that you read this notice, and that your answers are true;
• the date and time you sent the form, and the reference number we give your application.

To stop spam, the form uses a security check. We also count how many applications come from the same internet connection or the same email address. These counts delete themselves after a short time.

When you visit our careers pages, we keep the same visit records as on the rest of our website (section 5 of our Privacy Policy). Like our user guide and our blog, these pages use analytics: tools that help us understand how people use our website, including a tool that records what you do on the page. These tools work without asking you first. These pages do not show a message asking you about cookies, the small files that websites save in your browser (section 18). The application form and the thank-you page use none of these tools. One exception to the visit records above: opening the form, sending your application and seeing the thank-you page are not added to our record of what people do on our website.

Our careers pages have a chat, Onflow AI, that answers questions about the roles and how to apply. It is an AI. A conversation there is never a job application: only the form sends an application to our hiring team, so please do not paste your CV or your contact details into the chat. We hide email addresses and phone numbers in your messages before they are saved or sent on. Each message, the conversation so far and the page you are on go to the company that runs the AI for us, so that it can answer you. We keep the conversation as we keep our other support chats (section 20 of our Privacy Policy). If you ask for a person, our team answers you by email.

Please do not put identity numbers, bank details or health information in your CV or in your answers. We do not need them.

31.3 Why we use it

We use your application only to:

• consider you for the roles you chose;
• contact you about your application; and
• keep the form safe from spam and misuse.

We use it because you asked us to consider you for a job, and you agreed to this notice when you sent the form. We run the security check and the spam counts to keep the form safe (section 10 of our Privacy Policy). We do not use your application for marketing, and we never sell it.

31.4 How long we keep it

• Your draft. While you fill in the form, your answers are saved only in your browser, on your device. We do not receive them. The draft is cleared when you send your application, or when you press Start again. Your CV is never saved in the draft.
• After you press Send. Your application and your CV are kept on our website only until they are emailed to our careers inbox. When that email arrives, we delete them from our website. If sending fails, we keep trying, and our team is told if it keeps failing. If your application cannot be delivered within 14 days, we delete it and your CV.
• Backups. The company that stores our website's information copies it all the time into locked safety copies (backups), and deletes each copy within 35 days. Until then, your application and your CV stay in those copies. We also make our own safety copies. They do not include applications. We never bring deleted data back into use.
• In our careers inbox. The email with your application stays in the inbox only as long as we need it for hiring. You can ask us to delete it at any time.
• The emails. The email with your application is kept only in our careers inbox. We keep no other copy of it. We also keep no copy of the short confirmation email we send you.

31.5 Who sees it

• Our hiring team: the people at Onflow Ads who handle hiring. They read your application in our careers inbox.
• Our website does not show applications to anyone, not even to the people who run our website. Applications reach us only by email.
• People who use Onflow Ads, such as advertisers and channel owners, never see your application.
• Companies that work for us handle it only to do their job for us. The companies whose computers run our website hold your application while it waits to be sent. The company that stores our website's information also keeps the backups described above. The computers of all these companies are in the United States. The company that protects our website carries it to us and runs the security check. The company that sends our emails delivers the email to our careers inbox, and the confirmation email to you. The email service that holds our careers inbox stores it.
• We share it with anyone else only in the cases in section 15 of our Privacy Policy, such as when the law requires it.

31.6 Where it is kept

Our website runs on computers in the United States. Some of the companies that work for us handle your information in other countries too. Section 17 of our Privacy Policy explains the steps we take to protect it there.

31.7 Keeping it safe

Your application is protected (encrypted) on its way to us. We check that your CV is a real PDF, and we refuse files that are locked with a password or damaged. Apart from that check, our website does not open your CV. It only passes it on to our hiring team. No system is perfectly secure, which is one reason we delete your application from our website as soon as it reaches our careers inbox.

31.8 Your age

You must be 18 or older, or the age of adulthood where you live if that is higher, to apply. If we learn that someone too young has applied, we delete their application.

31.9 Your rights

You can ask us to:

• show you the data we hold about you;
• correct it;
• delete it; or
• give you a copy of it.

Section 22 of our Privacy Policy explains all your rights. For example, if you tell us your data is wrong, or that we are not allowed to use it, you can ask us to pause using it while we check.

You can also take back your agreement to this notice at any time. We then delete your application. Using your rights is free.

If you are not happy with how we handle your data, you can complain to us. You can then go to the Data Protection Board of India, or to the authority that the law where you live provides, such as your data protection authority in the EEA (the European Union, Iceland, Liechtenstein and Norway) or the UK.

31.10 How to reach us

Write to privacy@onflowads.com, from the email address you used in the form if you can. Add your reference number if you have it. We aim to confirm that we got your request within 72 hours, and we always answer within 30 days. For a complaint, put "Grievance" in the subject line, and we confirm it within 24 hours.

For anything else, write to support@onflowads.com.

31.11 Changes to this notice

We change this notice as section 26 of our Privacy Policy describes: we update this page and section 31 together, change the date at the top, and tell you before a material change starts. A material change is a big one, such as using your information for something new or keeping it for longer.