Notice of Financial Incentives

This Notice of Financial Incentives is provided by FLOW FN PTE. LTD. (UEN 202617303Z), a company incorporated in Singapore ("FlowFn", "we", "us"), to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA/CPRA"), and analogous statutes in Colorado, Connecticut, Virginia, Utah, and other U.S. states. The purpose of this notice is to describe the financial incentives we offer to consumers, the categories of personal information involved, the material terms of the program, and how to opt in and opt out.

This notice applies to the FlowFn Referral Program ("Referral Program"). Under the Referral Program, an existing customer (the "Referrer") may share a unique referral code or link. When a new customer (the "Referee") creates a paid FlowFn account using that code or link and remains a paying customer for the qualifying period defined in the Referrer's tier configuration, both parties may receive a reward in the form of (a) FlowFn account credit, (b) cash payouts to a connected payment account, or (c) a combination of the two, as published in the Referrer's tier on the Referrals dashboard.

To operate the Referral Program we collect and process the following categories of personal information: (a) identifiers (name, email address, account ID, referral code, IP address); (b) commercial information (subscription plan, billing status, referral attribution events, payout history); (c) internet or other electronic network activity (referral link clicks, signup attribution); (d) financial-account identifiers necessary for cash payouts (e.g. Stripe Connect account ID, last-4 of bank account where applicable). We do not knowingly collect sensitive personal information through the Referral Program.

(a) Eligibility: Both Referrer and Referee must be 18 years or older (or the age of majority in their jurisdiction), have valid FlowFn accounts in good standing, and be located in a jurisdiction where the Referral Program is offered. (b) Reward calculation: Reward amounts and qualifying conditions are published on each Referrer's tier in the Referrals dashboard and may change with notice. Rewards accrue only after the Referee's first qualifying paid invoice clears (typically after the standard refund window). (c) Payouts: Credit rewards are issued to the Referrer's account balance and may be used for FlowFn subscription charges. Cash payouts require a verified Stripe Connect account and are subject to Stripe's terms; FlowFn does not act as a money transmitter. (d) Cap: We may impose per-account, per-month, and lifetime caps to prevent abuse. (e) Termination: We may suspend or terminate participation, or claw back rewards, in cases of fraud, self-referral, or violation of our Terms of Service or Acceptable Use Policy.

Under CCPA/CPRA Section 1798.125(b), we are required to provide a good-faith estimate of the value of the consumer data that forms the basis of the financial incentive. We have estimated this value by reference to (a) the marginal expected revenue from a successfully attributed paying customer over the standard 12-month subscription term, less (b) the cost of the reward paid to the Referrer and Referee, less (c) the average cost of acquiring an equivalent paying customer through paid advertising channels. Based on this calculation, the value of the personal information processed under the Referral Program is approximately equal to the published reward amount, and in no case materially exceeds it. The Referral Program is not designed to be an exchange of money for personal information; it is intended to reward word-of-mouth advocacy by existing customers.

Our methodology for the value calculation in Clause 5 considers (i) average revenue per paying customer (ARPU) drawn from internal billing reports for the prior 12 months; (ii) average customer lifetime (LTV / churn) drawn from internal cohort analytics; (iii) industry-standard customer acquisition cost (CAC) benchmarks for B2B SaaS in the FlowFn category; and (iv) Stripe processing fees and tax-collection costs. We review and update this methodology at least annually.

Participation in the Referral Program is voluntary. You opt in by generating a referral code from the Referrals dashboard or by creating a paid account through another customer's referral link. You may opt out at any time by (a) ceasing to share your code, (b) emailing legal@flowfn.com requesting that we deactivate your code and remove you from the Referral Program, or (c) submitting a request through the Submit a Data Request form at /legal/data-request. Opting out does not affect rewards already earned and credited prior to the opt-out date. We will not deny goods or services, charge different prices, or provide a different level or quality of service because you decline to participate, except for the difference attributable to the value of the reward itself, as permitted by California Civil Code §1798.125(b).

We do not retaliate against consumers for exercising any of their privacy rights. Specifically, we will not (a) deny goods or services to non-participants, (b) charge different prices or rates for the underlying FlowFn Service, (c) provide a different level or quality of FlowFn Service, or (d) suggest that any such consequence will result. Reward differences between Referral Program participants and non-participants are limited to the published reward and are reasonably related to the value provided to FlowFn by the data processed for that program.

Cash payouts may be reportable income in your jurisdiction. Where required by law (for example, U.S. IRS Form 1099-NEC for U.S. recipients exceeding the reporting threshold in a calendar year), we, or our payments sub-processor Stripe, may issue tax forms and report payouts to the relevant tax authority. You are responsible for any taxes owed on rewards received.

We may update this Notice of Financial Incentives from time to time. Material changes will be notified through in-app notice, email, or by updating the version date at the top of this page. Continued participation in the Referral Program after the effective date of a change constitutes acceptance of the updated terms.

Questions about this notice or the Referral Program can be sent to our Data Protection Officer at legal@flowfn.com. To exercise CCPA/CPRA rights including the right to opt out of the sale or sharing of personal information, see our CCPA Compliance Statement and submit a request via https://www.flowfn.com/legal/data-request.