Privacy Policy

1. Who We Are

This Privacy Policy explains how DigifyNow GbR, Grenzweg 9a, 57648 Unnau, Germany (represented by its managing partners Jesper Schmidt and Christian Schiebel; “we,” “us,” or the “Provider”), the operator of the software-as-a-service platform “EmailFlow OS” (the “Service”), handles personal information in connection with the Service.

If you have any questions about this Policy or our data practices, you can contact us at info@digifynow.de or +49 2662 5004345.

2. What We Process

Depending on how the Service is used, we process the following categories of data:

• Account data — information you provide when registering and managing your account, such as your name, email address, and phone number, along with authentication and billing-related details.
• Customer-uploaded recipient / lead data — the recipient and lead data our customers upload and process on their own behalf to run their campaigns (for example, business contact names, email addresses, and company information).
• Campaign and tracking events — data generated when campaigns run, such as sending status and, where the customer enables it, open and click events.
• Uploaded videos — the videos and related media that customers upload or generate for personalization within the Service.

3. Roles: Controller and Processor

(1) For recipient and lead data uploaded and used within campaigns, the customer is the controller and EmailFlow OS acts as a processor, processing that data only on the customer’s documented instructions and on the customer’s behalf.

(2) For account data relating to our own customers (the account holders), the Provider acts as the controller and processes that data to provide, secure, bill for, and improve the Service.

4. Sub-Processors

We use carefully selected third-party providers (sub-processors) to operate the Service. These currently include:

• Railway — application hosting and infrastructure.
• Brevo — email sending, through the customer’s own connected Brevo account.
• OpenAI — AI-assisted generation of email text.
• Pitchlane — personalized video generation.
• Stripe — payment processing.

Each sub-processor processes data only to the extent needed to provide its respective function.

5. Tracking

Open and click tracking is optional and is controlled by the customer on a per-campaign basis. Tracking is only enabled when the customer explicitly turns it on for a given campaign; when it is off, we do not generate open or click events for that campaign. Clicks on tracked booking links are recorded as booking-link click events on behalf of the sending customer.

5a. Cookies and Meta Pixel (Consent-Based)

(1) The Service uses strictly necessary cookies and storage (session cookie for login, CSRF protection, language preference, and the stored record of your cookie choice). These are required to operate the Service and do not need consent.

(2) With your consent only, our public pages use the Meta Pixel (Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, Ireland) to measure and optimize our advertising. The pixel may transmit connection data (including IP address and browser information) and events (such as page views or sign-ups) to Meta, including transfers to the United States (safeguarded by EU Standard Contractual Clauses and/or an adequacy decision such as the EU-U.S. Data Privacy Framework). The pixel does not load unless you accept it, and you can change your decision at any time via the “Cookie settings” link in the page footer.

6. Data Retention & Deletion

(1) We retain personal data for the duration of the service relationship and as needed to provide the Service.

(2) On request, and subject to applicable law, customer data is deleted or returned to the customer. For data processed on the customer’s behalf, we act on the customer’s instructions.

(3) Unsubscribe and opt-out suppression information is retained as necessary to continue honoring opt-out requests and to comply with applicable law.

7. Your Rights & Choices

(1) If you received an outreach email sent through the Service and no longer wish to be contacted, you can unsubscribe using the link included in that email. The unsubscribe request is directed to the sending customer, who is the sender and controller of that communication.

(2) Under the GDPR you have the right to access (Art. 15), rectify (Art. 16), and erase (Art. 17) your personal data, to restrict processing (Art. 18), to data portability (Art. 20), and to object to processing based on legitimate interests (Art. 21). Consent can be withdrawn at any time with future effect. You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR); the authority responsible for us is the State Commissioner for Data Protection and Freedom of Information of Rhineland-Palatinate, Mainz, Germany. Depending on where you live, additional rights under state privacy laws (e.g. CCPA/CPRA) may apply.

(3) You may contact us at info@digifynow.de with any such request, and we will route it appropriately, including to the relevant customer where they act as controller.

8. International Note

The Service is operated from Germany, and data may be processed in Germany, the European Union, and other countries where our sub-processors operate. U.S. state privacy laws (for example, the California Consumer Privacy Act / California Privacy Rights Act, “CCPA/CPRA”) may apply to the personal information of California residents where the applicable thresholds are met, and other state privacy laws may apply as well. Each customer is responsible for its own privacy compliance toward its recipients, including providing any required notices and honoring individual rights requests.

9. Contact & Updates

(1) We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The “Last updated” date above indicates when it was most recently revised.

(2) Questions about this Policy can be sent to info@digifynow.de. For our contractual terms, see our Terms of Service.