TheFlow Privacy Policy

Last updated: October 6, 2025

Welcome to TheFlow. This Privacy Policy explains how we collect, use, and protect your information you provide directly to us when you use our music platform in the United States. This Privacy Policy is a part of our Terms.

This policy describes how we collect, process, retain, and disclose personal data about you when providing the Service to you, and our practices for using, maintaining, protecting, and disclosing that information.

If you are a California resident, please review our California Privacy Notice which supplements this policy.

Privacy at a Glance

How We Protect Your Privacy

You own and control your data

Full data export and deletion rights

Minimal data collection for features

Transparent about what we collect

What We Never Do

Never sell your personal information

No cross-site tracking or surveillance

No training AI on your private content

No sharing data by us for advertising off TheFlow

1. What Information We Collect

1.1 Information You Provide

Account and profile information including but not limited to your name, email, username, profile details, preferences, your listening/content consumption activity on TheFlow, and other information you elect to provide as part of your profile and/or in any communications on the Service

Account activity including information about your subscription, transactions, and purchase/order history

Content and communications including but not limited to music, posts, messages, photographs, videos, audio recordings, and/or other materials you upload or share

Payment and transaction information when you make purchases or receive payments, including credit/debit card information, address and phone information, information about the payment services you use in connection with the services

Biometric Information such as face prints, iris or retina scan, and other such information collected at the time we verify you as a human upon creation of your account (provided that information is used by us solely to perform such verification process at that time)

Verification and identity information to confirm your account and prevent fraud

Some of the information identified above may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

We also collect:

Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.

Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

1.3 Information from Third Parties

Service providers that you engage with in connection with TheFlow including but not limited to payment processors and third party verification services

Connected platforms that you choose to link to your account (subject to their policies/terms over which we have no control)

Public sources for verification, safety, and fraud prevention purposes

2. How We Use Your Information

2.1 Provide and Improve Our Services

Deliver our platform offerings including but not limited to music streaming, social features, creator tools, and personalized recommendations, as well as any other content, features, information, or products made available through TheFlow

Fulfill and manage subscriptions, purchases, payments, etc.

Fulfill any other purpose for which you provide it

Provide you with notices

Process transactions and calculate creator earnings and payments

Personalize your experience based on your preferences and activity

Develop new features and improve existing features

Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection

Notify you when Service updates are available and about changes to any products or services we offer or provide though them

In any other way we may describe when you provide the information

For any other purpose with your consent

2.2 Safety, Security and Legal Compliance

Maintain platform security and prevent fraud, abuse, and violations

Verify accounts and prevent unauthorized access

Comply with legal obligations including copyright, tax, and regulatory requirements

Retain information to the extent necessary to comply with law, prosecute and/or defend claims

Enforce our terms and community standards

2.3 Communication and Support

Provide customer support and respond to your questions

Send important updates about your account, our services, and policy changes

Enable community features and facilitate connections between users

Maintain platform security and prevent fraud

3. Your Data, Your Control

3.1 You Own Your Data

Your music, audience data, and creative work belong to you, not us. You can export everything and take it with you if you leave (subject to limited retention rights/obligations reserved to the Cooperative).

3.2 Export Your Information

Download all your account data in standard formats

Get your listening history and music analytics

Export your music catalog with all metadata

Access your earnings and payment history

3.3 Privacy Controls

Listening privacy: Choose who sees what you listen to

Social settings: Make your profile public or private

Music sharing: Control who sees your playlists and activity

Following: Keep your following/followers list private if you want

Turn off social features: Use TheFlow just for listening if you prefer

3.4 Delete Your Account

Request complete account deletion anytime

We'll use commercially reasonable efforts to delete your personal data within 30 days

Some records kept for legal requirements (like tax documents)

4. When We Share Your Information

4.1 We Never Sell Your Data

We will never sell, rent, or license your personal information to third parties for their marketing or commercial purposes outside of TheFlow. (As a reminder, some of your personal information will be shared with Creators whose content you choose to engage with on TheFlow.)

4.2 When We Share Information

We share your information in the following circumstances, including but not limited to:

With your consent including but not limited to social media connections you choose to make, Creators you choose to engage with (including their content), third-party apps, and services you choose to connect

Service providers including but not limited to payment processors, cloud hosting, customer support, and security services

Legal requirements including but not limited to court orders, legal compliance, tax reporting, and regulatory obligations

Safety and security including but not limited to preventing fraud, abuse, illegal activity, and protecting user safety

Business operations including but not limited to corporate governance, cooperative oversight, and transparency reporting

To enforce or apply our Terms

To protect rights, property, or safety of the Cooperative, our users, our Creators, or others

For any other purpose disclosed by us at the time you provide the information

4.3 What's Public vs. Private

Without limiting our rights and obligations in this Privacy Policy and under law, the following are examples of what is typically automatically made public to other users of TheFlow and what is typically private as it relates to other general users of TheFlow

Public Information (only what you choose to make public):

Your profile and content you publish

Public playlists and social activity you share

Comments and interactions on public content

Always Private:

Personal contact and payment information

Private messages and communications

Detailed analytics and earnings data

4.4 Business Transfers
Protecting You During Changes

If TheFlow is ever sold, merged, or undergoes significant corporate changes:

Your data rights transfer with you to any successor organization

We'll notify you 60 days in advance of any such transaction

You'll have the option to delete your account before the transfer

The same privacy protections must be maintained by any successor

5. Data Security

5.1 How We Protect Your Information

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. Our measures include:

Encryption and secure transmission of your data both in transit and at rest

Access controls and authentication to limit who can access your information

Regular security monitoring including but not limited to audits, testing, and threat detection

Secure infrastructure with industry-standard protections and safeguards

Employee training and policies to ensure proper handling of your information

However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Service. In particular, email, texts, and chats sent to or from the Service may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

6. How Long We Keep Your Data

6.1 Data Retention Principles

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Service, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified. Retention periods vary based on the type of information and the purposes for which we use it.

6.2 General Retention Periods

Active accounts: Information retained while your account is active and as needed to provide services

Deleted accounts: Most personal data deleted within a reasonable timeframe, with some information retained as required by law (we may retain anonymized data beyond this period of time as well for a legitimate business purpose as permitted by law)

Legal and financial records: Retained as required by applicable laws and regulations

Technical and usage data: Retained for limited periods to improve our services, then deleted or anonymized

6.3 Specific Circumstances

We may retain information for longer periods when required by law, for safety and security purposes, to resolve disputes, or to comply with regulatory requirements. In some cases, we may also retain information in anonymized form for research and service improvement purposes.

7. Children's Privacy

7.1 Age Requirements

You must be at least 13 years old (or the minimum age in your country or region, whichever is higher) to use our services. Some features, including but not limited to monetization and certain creator tools, may require you to be older or have parental consent as required by applicable law. We never knowingly collect any information from children under 13. If you believe we have collected information from you (and you are under 13) or your child (who is under 13) please contact us immediately at legal@theflow.com.

7.2 Enhanced Protections for Teens

Users under 18 receive additional privacy protections, including but not limited to:

More restrictive default privacy settings to limit data collection and sharing

Enhanced content controls and filtering for age-appropriate experiences

Limited data use for personalization and advertising purposes

Parental consent requirements where required by applicable law

Restricted monetization features until appropriate age verification

7.3 If We Discover Underage Users

If we become aware that we have collected personal information from a child under the applicable minimum age without proper consent:

Immediate action: We will promptly suspend the account and cease data collection

Data deletion: We will delete the child's personal information within a reasonable timeframe

Process improvements: We will take steps to prevent similar situations in the future

Parental notification: We will notify parents or guardians when required by applicable law

If you are a child, or you are the parent/guardian of child, and believe we have improperly collected personal information from you, please contact us immediately at legal@theflow.com.

7.4 Parental Rights and Controls

Parents and guardians have rights regarding their children's information, including but not limited to the ability to review, request deletion of, or refuse further collection of their child's personal information, subject to applicable law.

8. Cookies & Tracking

8.1 How We Use Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to provide and improve our services, including but not limited to:

Essential functions required for platform operation, security, and basic functionality

Analytics and performance to understand how our services are used and improve user experience

Personalization to customize content, recommendations, and platform features

Security and fraud prevention to protect your account and prevent unauthorized access

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.

Web Beacons. Some parts of the Services [and our emails ]may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or [opened an email ]and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

8.2 Your Choices and Controls

You can control cookies and tracking technologies through various methods, including but not limited to:

Browser settings to block, delete, or manage cookies and similar technologies

Platform controls within your account settings for personalization and analytics

Opt-out mechanisms for non-essential tracking and data collection

Third-party tools that help manage online tracking and privacy

8.3 What We Don't Do

No cross-site tracking across other websites or services for advertising purposes

No third-party advertising networks or marketing cookies from external companies

No behavioral profiling sold to third parties for external advertising or data broker purposes

No unnecessary tracking beyond what's required to provide our Service and optimize your experience on TheFlow

8.4 Third-Party Technologies

Some third-party services we use may employ their own tracking technologies, subject to their own privacy policies and your choices with those providers. Be aware that if you choose to link third party accounts to TheFlow, such as certain payment processor accounts, social media accounts, or others chosen by you, we have no control over such third parties and how they collect and/or handle your information. You are encouraged to read their applicable privacy policies, terms of service, and other rule governing their products and services.

9. Third-Party Services

9.1 Who We Work With

Payment processing: Trolley and Stripe for secure payments

Human verification: Sumsub for one-time liveness detection

Cloud hosting: AWS and Google Cloud for secure storage

Customer support: Tools to help us assist you better

9.2 How This is Protected

Strict contracts: All partners have agreed with us in a contract to protect your data from processing beyond what is necessary to support the Service and your chosen use of TheFlow

Limited data sharing: Only share what's necessary for the Service

Regular audits: We reserve the right to check their security practices regularly

10. Your Privacy Rights

10.1 Your Choices and Controls

Depending on your state of residency, you may have certain rights related to your personal data, including:

Access and Data Portability. To the extent feasible, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request

Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.

Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.

Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes.

10.2 US Privacy Rights

If you live in certain US states, you may have additional rights under state privacy laws, including but not limited to the right to know about, delete, or correct your personal information. Contact us at legal@theflow.com to exercise these rights.

10.3 How to Make Changes

Account settings for most privacy controls and data management

Email us at legal@theflow.com for other requests

Response time we will reasonably respond as quickly as possible, and aim to respond within 90 days for formal requests, unless a shorter response time is required

No charge for reasonable requests

11. Changes to This Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Service. We may email or otherwise communicate reminders about this policy, but you should check our Service periodically to see the current policy and any changes we have made to it. We may also send a summary or notice to you through other means you have provided to us for communications, but we are not obligated to.

12. Contact Us

12.1 All Privacy & Legal Questions

Email: legal@theflow.com

Expected Response time: we aim to respond within 90 days for rights requests asserted in good faith, unless a shorter response time is reuqired

We handle: Privacy questions, rights requests, legal matters, security issues directly related to our Service

We do not: Provide legal advice to you

12.2 Mail

TheFlow Cooperative, Inc.
ATTN: Legal/Privacy

675 Tiffany Court

Sunnyvale, CA 94087

12.3 General Support

Email: support@theflow.com

For: Account help, technical issues, platform questions

This Privacy Policy applies to all users of TheFlow's services in the United States.

Last Updated: November 6, 2025