Privacy notice
Last update: October 13, 2026
Who processes your data
The controller for account, subscription, security and support data is ACTAFLOW S.R.L., VAT number 04311920138, Via Canturina 153, 22100 Como (CO), Italy. Privacy contact: info@actaflow.ai; certified email: actaflow@namirialpec.it. This notice covers the ActaFlow website and service. For content entrusted to a business workspace, ActaFlow acts as a processor on the customer’s instructions. The customer remains the controller, or a processor acting for its controller. Our Data Processing Agreement (DPA) governs that relationship.
Data collected and its sources
We collect information you provide during registration and in settings: name, email, optional business and tax details, address, plan and service usage. Firebase Authentication manages sign-in and, where configured, the second factor. We cannot access your plaintext password. Stripe handles payments: ActaFlow receives payment references and status, not your full card number. Workspace data includes chat messages, uploaded files and documents, Knowledge and its sources, information from authorised integrations, playbook configurations, outputs, run history and activity records. Sources may come from you, authorised team members, connected services or pages and resources you ask us to consult. They may contain information about customers, colleagues, correspondents and other people. We also process technical information needed to operate and secure the service, such as IP addresses, browsers, requests and errors. If you enable dictation, the microphone is used with your device’s permission; audio is sent for transcription and the resulting text may be added to the chat.
Google user data and requested permissions
Signing in to ActaFlow with Google and connecting Gmail are separate operations. Sign-in uses your account identity, email and basic profile; it does not by itself authorise Gmail access. When you connect Gmail, we request mailbox identity and, depending on the enabled features, permission to read messages (gmail.readonly) and send email on your behalf (gmail.send). Reading includes sender, recipients, subject, body, dates, message and thread identifiers, existing labels and attachments. History identifiers and Gmail notifications let us detect new messages. For direct connections, we store encrypted access and refresh tokens. For connections managed by Composio, identified before authorisation, Composio holds and uses the tokens; ActaFlow stores the connection reference. We do not request your Google password. Google’s consent screen shows the actual permissions and may identify Composio as the requesting application for managed connections. Available scopes depend on the connection configuration. New features requiring additional data or permissions are explained before requesting new authorisation.
How Google user data is used
Gmail data is used for the visible features you configure: displaying and searching events, understanding requests and documents, creating or running playbooks, producing results and sending the specified emails. Automations may run in the background under your authorised instructions; steps configured for approval wait for your decision. Relevant content may be processed by Anthropic (Claude) or OpenAI for AI features, according to the provider selected for the workspace, Voyage AI for semantic search and Pinecone to store the search index; documents may be processed by Google Document AI. This processing is disclosed before authorising a connection. Sharing with other integrations or recipients follows your playbook instructions and workspace permissions. Our handling of Google API data follows the Google API Services User Data Policy and its Limited Use requirements. We do not sell this data or use it for advertising, advertising profiles, credit assessment or training general-purpose AI models. These limits also apply to derived data. Personnel do not read Google content unless you explicitly agree to access to specific data, access is necessary for security, or the law requires it, within Google’s permitted exceptions.
Purposes and legal bases
We use account data to provide the service and support and manage our contract with you (GDPR Article 6(1)(b)); tax records to meet legal obligations (Article 6(1)(c)); and information necessary for security and abuse prevention for our legitimate interest in protecting the service (Article 6(1)(f)), subject to individuals’ rights. Separate, optional consent applies to promotional communications and any non-essential tracking. You can withdraw it without losing access to contractual features. Workspace content is processed on the customer’s instructions under the DPA. Customers must establish a suitable legal basis for other people’s data, inform them and configure automations appropriately. Technical OAuth authorisation does not replace these obligations. Marketing consent is not required to register or connect a service.
Optional public website analytics
Only after analytics consent do we use Microsoft Clarity on the public actaflow.ai website to understand how pages are used and improve their clarity and operation. The legal basis is consent (GDPR Article 6(1)(a)), which is optional and can be withdrawn in “Cookie Preferences”. Declining does not prevent use of the website or service. Clarity does not load before consent or after refusal. Clarity collects interactions such as clicks, scrolling and navigation, visited pages and URLs, browser and device information, pseudonymous identifiers and technical connection data, including IP address and derived approximate location. This supports heatmaps, usage metrics and session recordings: reconstructions of interactions with the page, rather than device audio or video recordings. We do not load Clarity in the authenticated app, dashboard, sign-in pages or workspace chats. We explicitly mask contact forms and the public website’s trial chat contents; we do not send email addresses, account identifiers or identification commands to Clarity. Microsoft receives website usage data under its own Privacy Statement. Advertising storage consent remains denied: analytics consent does not authorize personalized advertising. Microsoft may process data outside the EEA, including the United States; safeguards described in its documentation and the “Protection and international transfers” section apply. Details of Microsoft’s collection and use: https://www.microsoft.com/privacy/privacystatement. Under Clarity’s retention terms, session playback data is retained for 30 days; heatmaps, aggregated click data and labeled or favorited sessions for 9 months. Withdrawal stops new collection; it does not automatically delete previously transmitted data. Contact info@actaflow.ai about that data.
AI and automation
ActaFlow uses AI to interpret requests, consult sources and prepare and perform automations. Responses may contain errors: configure approvals and review results to match the operation’s risks. Authorised automations may take actions without confirmation for each run. The service is not intended for solely automated decisions with legal or similarly significant effects on individuals without the conditions and safeguards required by law. Do not upload special-category or criminal-offence data without checking the applicable conditions and suitability of the service. Customers must assess the risks of their use, any need for a data protection impact assessment and appropriate human oversight.
Growth: leads, advertising, video and voice
When you use Growth, we process the website and offer you provide, campaign goals and budgets, chat messages, uploaded materials and generated outputs. The providers involved depend on the feature you request; they do not automatically receive all workspace content. We use Pipeboard (ARTELL SOLUÇÕES TECNOLÓGICAS LTDA) to connect advertising channels. We send it a technical workspace identifier to provision the connection. You authorise access on the selected channel: Pipeboard processes OAuth tokens, ad-account identifiers and data needed for authorised features, such as campaigns, creatives and metrics where available. You do not need a personal Pipeboard subscription. Available channels and actual permissions are those shown during connection; listing a channel in the interface does not mean every operation is already available. We use Higgsfield for video generation and fal.ai for video editing and speech synthesis, including ElevenLabs models for voiceovers. Depending on the operation, we transmit the prompt, text to be spoken, selected voice and language, and any reference files or video to edit. These services may involve the providers of the models used. ActaFlow stores outputs and the references needed to manage processing and costs in the workspace. Creating content does not automatically publish it or launch ads. Integrated lead search uses ActaFlow’s Icypeas account. We transmit audience filters and, when searching for a professional email address, first name, last name and company or domain. We receive professional profiles, available emails and their reliability indicators; this flow does not search for phone numbers. If you select AI Boost, the AI provider selected for the workspace (Anthropic or OpenAI) receives your criteria, relevant profile data and excerpts from accessible company pages to assess relevance and identify uncertainties. Profiles, sources, assessments and usage references are stored in your workspace. Customers may also use their own integration, such as Apollo, subject to its permissions. Discovery and enrichment do not automatically send messages; finding a contact address does not establish permission to contact. The Google data restrictions described above continue to apply: connecting Gmail does not authorise using its content for advertising or advertising profiles.
Connections managed by Composio
For integrations identified as managed, we use Composio (Sampark Inc). It handles authorisation, credentials and provider API calls. It receives a technical workspace identifier, connected-account identifiers and data needed for requested operations, including requests, responses, events and attachments when used. Provider credentials are not sent to the AI model. History discovery and playbook execution remain ActaFlow features.\n\nComposio may retain execution and event logs, including content, for up to one year; temporary files follow its deletion cycle, stated as 24 hours. We do not claim zero retention for managed connections. Disconnecting stops use of the connection in ActaFlow but does not automatically erase imported data or all provider logs. Contact info@actaflow.ai about data already transmitted.
Protection and international transfers
We use HTTPS in transit, workspace authentication and authorisation controls, encrypted integration credentials and cloud infrastructure protection at rest. Administrative access is restricted to operational needs. Not all data uses the same key or application-level encryption: authorised services need to read some content to process it. The production Firestore database is in the European eur3 region; file storage currently uses Google Cloud’s US-EAST1 region. Some AI and service providers may also process data outside the EEA. We therefore do not claim exclusively European data residency. Transfers must be covered by the applicable GDPR Chapter V mechanisms, such as Standard Contractual Clauses and, where applicable to the recipient, an adequacy decision. Contact us to request information about safeguards and a relevant copy.
Retention and deletion
Workspace content, including imported Google data and derived indexes, is retained to provide the service while your account remains active, until you delete it or request account deletion. Pausing a playbook or disconnecting a mailbox stops future use of that connection but does not automatically erase files, events and results already saved. You can delete resources in the platform or request selective deletion through our privacy contact. Account deletion covers database content, stored files, search indexes and credentials. Technical copies and provider-held data also follow applicable deletion cycles and legal obligations. Any information necessary for tax obligations, disputes or security is retained separately only for the necessary period and purpose; workspace content is not automatically subject to the retention periods applying to our own accounting records. AI providers may apply technical and security retention periods under their terms: we do not promise zero retention across all services. Files uploaded for AI processing have a dedicated removal process. ActaFlow does not save dictation as a permanent audio file. Standard Google Cloud operational logs are configured for 30 days; Google platform-required audit logs for 400 days. Deleted bucket files may remain recoverable for 7 days as protection against accidental deletion; those copies are not available in the app. After deletion, we retain a technical account identifier for 90 days, without workspace content, to prevent delayed requests or jobs from recreating data. For Growth, disconnecting a channel stops future access through that connection but does not automatically delete campaigns and content held by the advertising platform or outputs already saved in the workspace. You can also revoke permissions on the original channel. Requests to delete data held by providers follow their contracts and technical deletion cycles; contact info@actaflow.ai about data already transmitted.
Controlling your Google connection
You can disconnect Gmail in Integrations and revoke access from your Google Account’s third-party connections page: https://myaccount.google.com/connections. Revocation stops new access but does not itself delete copies already imported into ActaFlow. Use the deletion features or contact info@actaflow.ai for those copies. Deleting an ActaFlow account cannot recall messages already sent or data delivered to recipients. For managed connections, Google may list Composio: revoke the entry corresponding to the connection you want to stop.
Your rights
Where applicable, you may request access, correction, erasure, restriction and portability, object to processing, and withdraw consent where consent is the legal basis. Contact info@actaflow.ai. We may request proportionate information to verify identity. We normally respond within one month; any extension of up to two further months due to complexity or the number of requests is explained within the first month. For data processed on a business customer’s instructions, contact that controller; ActaFlow assists with the response. You may complain to the Italian Garante (www.garanteprivacy.it) or your competent local supervisory authority. Contractual limitations do not remove these rights.
Cookies and updates
Our Cookie Policy describes website and app technologies. Language is detected from browser or device preferences without using geolocation; your manual choice is stored on your device. Updates are published with their date. Material changes to purposes or recipients will be communicated appropriately; where required, new authorisation will be requested before the new processing begins.