Provisional version. The final text is being prepared with our legal advisor and will be published here shortly.
Version 22.08.2026 — Drawn up in Italian. Versions in other languages are courtesy translations: in case of divergence, the Italian version prevails.
1. Data Controller
The controller of personal data processing is Flow Motion SA, with registered office at via Pineta 40a, 6979 Brè sopra Lugano, Switzerland, business ID no. CHE-111.990.822, e-mail: info@flow-motion.net, which operates the EntryMind service (entry-mind.net).
2. Scope: when we are Controller and when Processor
EntryMind is a subscription management software (SaaS) for professional studios. This distinction matters:
• We act as Controller for the personal data of the site's visitors and of the Clients (and their contacts) who create an account, subscribe and are billed — that is, the data described in this policy.
• We act as Processor for the personal data that a studio enters into the Service about its own clients (e.g. contact records, appointments, invoices). For such data the studio is the Controller, and we process it only on its instructions, under the Data Processing Agreement (DPA) set out in Annex A of the General Terms.
3. Types of Data Collected
As Controller we process the following personal data:
• First and last name, and role/position;
• Studio name and, where applicable, VAT / business ID number;
• Phone number, e-mail address;
• Chosen subdomain and account/configuration data;
• Subscription and billing data (payment data is not stored on our site: it is handled by the payment provider, see section 8);
• Support communications (the messages you send us);
• Anonymized technical/browsing data (via technical and analytical cookies).
4. Purpose of Processing
Data is processed to:
• Create and manage the account and subscription;
• Activate and run the studio's environment (subdomain, hosting, configuration);
• Billing and accounting and tax obligations (via Paddle, see section 8);
• Provide support and service communications;
• Ensure technical operation, security and fraud prevention;
• Where separately consented, send service or marketing communications.
5. Legal Basis
• Contract performance (Art. 6(1)(b) GDPR / Art. 31 nFADP);
• Legal obligations, e.g. accounting and tax (Art. 6(1)(c) GDPR);
• Legitimate interest, e.g. Service security and fraud prevention (Art. 6(1)(f) GDPR);
• Consent, for cookies and any marketing communications (Art. 6(1)(a) GDPR).
6. Retention and Security
Data is processed electronically and retained for the time necessary to provide the Service and to comply with legal obligations (maximum 10 years for accounting records). For the studio's data (Processor role), the Client may export a copy within 60 days of contract termination, after which deletion takes place (Art. 9.3 of the General Terms). We apply appropriate technical and organizational measures (encryption in transit, access control, backups).
7. Rights of the Data Subject
At any time you may:
• access, rectify or delete your data;
• restrict or object to processing;
• withdraw a consent given;
• request data portability.
Requests to: info@flow-motion.net
Competent authorities:
• In Switzerland: Federal Data Protection and Information Commissioner (FDPIC);
• In the EU: the supervisory authority of your Member State.
8. External Services and Recipients
We rely on the following providers, each with measures compliant with GDPR and nFADP:
• Infomaniak Network SA (Switzerland) — hosting of the Service and of the studios' environments (sub-processor);
• Paddle.com Market Ltd — payments and billing as an autonomous controller and "merchant of record": tax and payment data are processed by Paddle under its own privacy policy.
9. International Transfers
Data is stored on servers located in Switzerland or the European Economic Area. Any transfers to third countries take place only with appropriate safeguards (e.g. standard contractual clauses) or where an adequacy decision exists, under Art. 45-46 GDPR and Art. 16-17 nFADP.
10. Cookies
This site uses cookies to improve the user experience:
• Technical cookies — always active, necessary for the operation of the site and the account;
• Anonymized analytical cookies — collect aggregate statistics;
• Third-party cookies — used only with prior consent, for marketing purposes.
You can accept or reject non-essential cookies at any time via your browser settings or the cookie banner.
11. Communications and Newsletter
Newsletters or promotional communications are sent only with explicit consent and can be revoked at any time via the "Unsubscribe" link.
12. Policy Updates
Flow Motion SA may update this policy in case of regulatory or technical changes. The "Version" date above always reflects the current version.