Privacy Policy

1. Who we are

FlowOrca Ltd, a company incorporated in the Cayman Islands (Company No. [Cayman Co. No.]), with registered office at [Registered Office Address], George Town, Grand Cayman. We are the Data Controller for personal data submitted via this website.

2. What data we collect

We only collect personal data that you voluntarily submit to us:

• — Contact form / Buyer Pack request: name, organisation, email, role, message content
• — Briefing booking: name, email, organisation, scheduling preferences (via our calendar tool)
• — Email correspondence: whatever you choose to send us

We do not use cookies for analytics or advertising. We do not run third-party tracking scripts. The site is statically hosted on Cloudflare Pages; the only logs created are standard CDN access logs (IP address, timestamp, requested URL) retained per Cloudflare's policy.

3. Lawful basis (DPA 2021 Revision & GDPR)

We process the personal data above on the basis of legitimate interest in operating a business relationship, and consent where you have voluntarily contacted us. Both are recognised lawful bases under the First Data Protection Principle of the Cayman DPA and Article 6 of the GDPR.

4. How we use your data

To respond to your enquiry; to deliver the Buyer Pack; to schedule and conduct briefings; to maintain our customer relationship management records; to comply with legal obligations.

We do not sell personal data. We do not share personal data with third parties except sub-processors disclosed at /trust/sub-processors.

5. Retention

Inbound enquiries are retained for up to 24 months from last contact, then deleted unless an active commercial relationship exists. CRM records are retained for the duration of any commercial engagement plus 7 years thereafter for tax and contractual record-keeping purposes.

6. Your rights

Under the Cayman DPA (Sections 8–14) and applicable GDPR provisions, you have the right to access, rectify, erase, restrict processing of, and port your personal data. Send requests to privacy@floworca.com. We respond within 30 days under Regulation 4 of the Data Protection Regulations 2018.

7. Complaints

If you are unsatisfied with our response, you may complain to the Office of the Ombudsman of the Cayman Islands, the supervisory authority under the DPA.

8. International transfers

Some sub-processors (email, calendar, CRM) may store data outside the Cayman Islands. Where they do, we rely on the contractual safeguards required by Schedule 4 of the DPA 2021 Revision and standard contractual clauses for GDPR-equivalent jurisdictions.

9. Changes

We update this policy when our practices change. The date at the top of this page reflects the last material update.

10. Contact

Privacy enquiries: privacy@floworca.com
Postal: FlowOrca Ltd, [Registered Office Address], George Town, Cayman Islands.