Legal
Effective date: 18 August 2026
This Privacy Policy explains how the Flowryd OS platform (the "Services") collects, uses, shares and protects your personal data.
The data controller for the Services is Towler Advisory Ltd, a company registered in England and Wales (No. 16436666) whose registered office is at 128 City Road, London, England, EC1V 2NX, trading as Flowryd OS ("Flowryd OS", "we", "our", or "us").
We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and we are registered with the UK Information Commissioner's Office (ICO) under registration reference ZB990349. By using the Services you acknowledge the practices described here.
Flowryd OS is a neutral orchestration platform operating on the Canton Network. This policy covers personal data we hold and control off-chain. It does not, and cannot, govern data recorded on the Canton Network itself, which is a third-party distributed ledger outside our control (see "Data recorded on the blockchain" below).
Information you provide
Information collected automatically
Party IDs may constitute personal data under the UK GDPR where they can be linked to an identifiable individual. We treat them accordingly for the off-chain records we hold.
| Purpose | Legal basis (UK GDPR Art. 6) |
|---|---|
| Providing orchestration, coordination and matching services | Performance of a contract / legitimate interests |
| Displaying your Canton Network connections and opportunities | Performance of a contract |
| Facilitating connections and deployment | Performance of a contract |
| Communicating platform updates and support | Legitimate interests |
| Improving, securing and optimising the Services, and preventing fraud | Legitimate interests |
| Complying with legal and regulatory requirements | Legal obligation |
| Marketing communications | Consent (withdrawable at any time) |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights.
We may share personal data with:
We do not sell your personal data.
Some recipients (including counterparties, participants and service providers) may be located outside the UK. Where we transfer personal data outside the UK, we rely on an adequacy decision where one applies, or otherwise on appropriate safeguards such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or the Standard Contractual Clauses. You may request details of the safeguards used.
Certain data — including Party IDs and transaction records — is recorded on the Canton Network. Data recorded on a distributed ledger is, by design, public, immutable and outside our control. As a result:
Please consider this before submitting any data to an on-chain transaction.
We implement measures appropriate to the risk, including encrypted transmission and storage, secure authentication, access controls and monitoring, and periodic security review. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We retain personal data for as long as your account is active or as needed to provide the Services, and thereafter only as required for legal compliance, dispute resolution, and legitimate business purposes. Off-chain data is deleted or anonymised when no longer needed for these purposes. Data recorded on the Canton Network cannot be deleted (see above).
Subject to the limits described above, you have the right to:
To exercise any right, contact us at info@flowryd.xyz. We will respond within one month, which we may extend by up to two further months for complex requests, and we will tell you if we do.
If you have a concern, please contact us first. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk. If you are in the EU/EEA, you may complain to your local supervisory authority.
We use cookies and similar technologies to maintain your session and authentication, remember your preferences, and analyse platform usage and performance. Non-essential cookies are used only with your consent, which you can manage through our cookie banner or your browser settings. Strictly necessary cookies do not require consent.
We do not carry out solely automated decision-making that produces legal or similarly significant effects concerning you.
The Services are intended for institutional and professional users and are not directed at children. We do not knowingly collect personal data from anyone under the age of 18.
The Services may link to third-party services, including the Canton Network. We are not responsible for the privacy practices of those services. Please review their privacy policies separately.
This policy, and our processing of your personal data, are governed by the law of England and Wales and the United Kingdom data protection regime (the UK GDPR and the Data Protection Act 2018). Any dispute arising out of or in connection with this policy is subject to the exclusive jurisdiction of the courts of England and Wales.
We may update this policy from time to time. We will post the updated policy with a revised effective date and, for material changes, notify you by email or platform notification. Continued use of the Services after an update constitutes acceptance of the revised policy.