Data protection (GDPR)
infiniflow · INFINI FLOW S.R.L. · Version: draft 1 · 30 October 2026
This page explains how INFINI FLOW S.R.L. (“infiniflow”, “we”) applies the EU General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) to what it is building: a platform that turns blood tests, body composition and watch data into training, nutrition and supplement guidance for endurance athletes. It goes together with our privacy policy, which lists the data item by item. This page adds the legal footing for each use, who receives the data, what protects it, what the law asks of us and how to use your rights. It says what we do today and what we will have done before the app is opened to other people. It does not describe anything that is not happening.
1. In short
- Who is responsible. INFINI FLOW S.R.L., a company established in Romania, decides why and how the data described here is used. The GDPR therefore applies to everything we do with personal data.
- What is sensitive. Your blood-test results, body composition, weight, training and recovery data and what you eat are data concerning health, a special category of personal data (Article 9 GDPR). We use them only with your explicit consent, which you can withdraw at any time (section 4).
- What we do not do. We do not sell personal data, we do not use it for advertising, and we make no decision about you that has legal or similarly significant effects. We add no analytics tools and no advertising or tracking cookies of our own. Our hosting provider’s script is the exception (section 12).
- Artificial intelligence. Parts of the product use AI models run by other companies. They read documents, draft plans and answer questions. What they produce is information, not medical advice, and no AI makes a decision about you with legal or similarly significant effects (section 6).
- Your rights. You can ask to see, correct, delete, export or restrict your data, object to its use and withdraw your consent. Write to admin@infiniflow.me; we reply within one month (section 9).
- Where we are. This page covers the website, the MVP and the app. The app is in closed testing and handles only its founders’ own data. Before it handles anyone else’s, we will complete the steps in section 11.
2. Who we are and the law that applies
INFINI FLOW S.R.L. is the controller (Article 4(7) GDPR): we decide why and how the data described here is used. A provider that handles data only on our instructions is our processor (Article 28). A service that you connect yourself, such as a watch brand’s account, keeps its own data under its own policy and is a separate controller (section 5).
- Controller
- INFINI FLOW S.R.L.
- Contact for data protection
- admin@infiniflow.me
- Data protection officer
- None appointed (section 11)
- Supervisory authority
- ANSPDCP, the Romanian authority (section 10)
Our establishment is in Romania. The GDPR therefore applies to all the personal data we process, wherever the people concerned live (Article 3(1)), and the Romanian authority is our supervisory authority. The rules we follow are:
- The GDPR, Regulation (EU) 2016/679.
- Law no. 190/2018, which puts the GDPR into effect in Romania. Its Article 3 allows health data to be processed for profiling or automated decisions only with the person’s explicit consent or on an express legal provision with safeguards. We rely on explicit consent.
- Law no. 506/2004, which implements the ePrivacy Directive (2002/58/EC) in Romania: cookies and similar technologies on your device, and marketing messages (section 12).
- The AI Act, Regulation (EU) 2024/1689. Since 2 August 2026 its Article 50 requires that people are told when they are dealing with an AI system (section 6).
3. What we process in our product, and on what basis
Each row covers one part of the product. The legal basis comes from Article 6 GDPR and, for health data, Article 9. The privacy policy lists the fields one by one.
| Part of the product | Data | Why | Legal basis |
|---|---|---|---|
| Website (presentation page) | Your IP address, the time, the page requested and details of your browser and device, in our host’s server logs. | To show you the page and keep it secure and working. | Legitimate interest (Article 6(1)(f)). |
| Writing to us | Your email address, your name if it shows, your message and attachments. | To answer you and keep a record of the conversation. | Legitimate interest, and steps at your request (Article 6(1)(f) and (b)). |
| Your account (MVP) | Email address, password (stored only as a one-way hash), name, country, phone (optional), account type, subscription type, language, and a photo if you upload one. | To create your account, sign you in and run the service. | Performing our contract with you, or steps at your request before entering into it (Article 6(1)(b)). |
| Your body data (MVP) | Sex, date of birth, height, weight and activity level. | To work out your plan. | Explicit consent (Articles 6(1)(a) and 9(2)(a)). |
| Blood-test reports (MVP) | The report you upload is read by an AI model and we do not keep the file. We keep the values read from it, its file name and, when the AI reader fails and the report is read in your browser instead, the text read from it. | To read your report, chart your markers and build your plan. | Explicit consent (Articles 6(1)(a) and 9(2)(a)). |
| Meals and nutrition (MVP) | Photos of meals are read by an AI model and we do not keep the pictures. We keep your calorie records, your nutrition plans, the reports made from them and a record of each plan request (sex, calorie target, marker status and the plan). | To analyse meals, build a plan and track calories. | Explicit consent (Articles 6(1)(a) and 9(2)(a)). |
| Watch, body-composition and training data (app) | Heart rate, power, speed, sleep, heart-rate variability and similar data from files you import or, once you connect it yourself, from a watch brand’s service; weight and body composition from a scan report. | To work out training load, energy needs and plans. | Explicit consent (Articles 6(1)(a) and 9(2)(a)). |
| AI coach (app) | Your plan and thresholds, a summary of recent training and recovery, planned sessions compared with completed ones, your latest fitness estimates (VO2max), reduced copies of the nutrition and supplement plans (which can reveal your body weight), the earlier turns of the conversation and the questions you type. | To answer your questions about your plan. | Explicit consent, asked separately (Articles 6(1)(a) and 9(2)(a)). |
| Support and evaluation (MVP) | What our administrators can see: accounts, profile details and usage statistics, including the country of each account. | To support users and to run the evaluation of the MVP. | Legitimate interest (Article 6(1)(f)); for health data, your explicit consent (Article 9(2)(a)). |
| Security and legal duties | Access records, and any data the law requires us to keep or to give to an authority. | To keep the service secure and to obey the law. | Legitimate interest; legal obligation (Article 6(1)(f) and (c)). |
Rows marked “app” describe what the app does; today it handles only its founders’ own data. The script that our hosting provider inserts into every page is not part of this table: it is the host’s own (section 5, section 12). You are not obliged to give us any of this data. Without the account data we cannot create your account, and without health data the features that need it (reading a report, a nutrition plan, the calorie tracker) do not work.
4. Health data and your consent
Data concerning health is a special category (Article 9 GDPR) and is protected more strictly. In our product it means your blood-test results, body composition, weight, training and recovery data, what you eat, and the plans we derive from them. We use it only on your explicit consent (Article 9(2)(a)). The plans we build from it are a form of profiling (an automatic evaluation of personal aspects, here your health), for which Romanian Law no. 190/2018, Article 3, also asks for explicit consent.
How consent works
- Separate and unticked. When you register yourself in the MVP, you give consent at the end of registration, by ticking a box that is not ticked for you, next to a link to the privacy policy. The box covers the processing of the health data you upload or enter, including by AI services. In the app, the AI coach stays off until you switch it on, and the switch names the AI provider that will receive the data.
- Recorded. For registrations you complete yourself since 27 October 2026, the MVP saves in your sign-in account the time of your consent and the version of the privacy policy you saw.
- Accounts we create for you. An account that we create at your request does not pass through the registration screen with the consent box. Before you upload health data in it, we ask you for the same explicit consent in writing and keep your reply.
- Withdrawable. You can withdraw it at any time by writing to admin@infiniflow.me. We then stop using the data concerned and delete it. Withdrawing does not affect the lawfulness of processing done before. Today you withdraw by email. We will add a way to do it inside the MVP and the app, as easy as giving consent; the app will have it before it is opened to other people.
- Needed for the service. The MVP and the app are built on health data, so when you register yourself the MVP asks for this consent, and you cannot finish registering without it.
- Only for the service. We use your health data to provide the product to you. We do not sell it and we do not use it for advertising.
- Sample documents. The MVP is a prototype: if you can, use sample documents rather than your real medical records, and on a real report cover your personal numeric code (CNP) and your address before you upload it. Never upload documents about other people. Please do not send medical documents by email.
5. Who receives your data
We share personal data only with the providers below, which we use to run the product, and with an authority when the law requires it. We do not sell it. If you ask, we tell you which specific recipients received your data. The last column is about transfers outside the European Economic Area (EEA).
| Provider | What it does | What it receives | Outside the EEA |
|---|---|---|---|
| Supabase | Database, sign-in and server functions of the MVP (our processor). | What is in your MVP account: profile and profile photo, blood-test values and file names, meal records, nutrition plans and plan-request records. Uploaded reports and meal photos pass through its functions to the AI provider and are not stored. It sends the sign-up confirmation and password-reset emails. | The contracting entity is Supabase Pte. Ltd. (Singapore); data can be processed wherever Supabase or its sub-processors maintain facilities. Its data processing terms include the EU standard contractual clauses. |
| Anthropic | The Claude AI models: they read your lab report and meal photos, draft nutrition plans and, in the app, answer coach questions (our processor). | The whole document you upload (a lab report may print your name and other identifiers, such as your date of birth or personal numeric code); meal photos; for a nutrition plan, your sex, calorie target and marker names with their status, without your name or contact details; for the app’s coach, your plan and thresholds, a summary of recent training and recovery data (not the raw files), planned sessions compared with completed ones, your latest fitness estimates, reduced copies of the nutrition and supplement plans, the earlier turns of the conversation and your question. | The contracting entity is Anthropic Ireland, Limited; data can be processed outside the EEA, including in the United States. Its data processing addendum includes the EU standard contractual clauses. Under its published terms it deletes content sent through its API within 30 days (longer only in the cases it lists, such as a legal duty or enforcing its usage policy), and it may not train its models on our content. |
| Image services | OpenAI draws the dishes of a nutrition plan. Google’s image model, reached through an AI gateway, draws generic food pictures when an administrator asks. | The dish name, description and ingredients, or a food name, only. No personal data. | US companies. We send no personal data; in one fallback case your browser loads the finished picture from the provider’s own web address, which shows the provider your IP address, and no transfer safeguard covers that connection. |
| GoDaddy | Hosting of the website and of the MVP’s web files (our processor). It also inserts a script of its own into every page it serves, which sets cookies (section 12). | The technical data of every visit (IP address, time, page, browser) in its server logs. Through its script: visitor and session identifiers, the page address and referrer, browser and device details and page-loading times. | A US company, certified under the EU–US Data Privacy Framework. |
| Our email (Google Workspace, our processor) and the typefaces of the presentation page (Google Fonts): your browser contacts Google when you open that page. | The emails you send us; for the fonts, your IP address and browser details. | A US company, certified under the EU–US Data Privacy Framework; it also offers standard contractual clauses. | |
| Cloudflare | Delivers the graphics library of the presentation page (cdnjs): your browser contacts it when you open that page. | Your IP address and browser details. | A US company, certified under the EU–US Data Privacy Framework. |
| Unsplash | Sample dish photos shown in the MVP, loaded by your browser. | Your IP address and browser details. | A US company. Your browser connects to it directly, and no transfer safeguard covers that connection. |
| Watch brands, such as Garmin | Independent controllers: they hold your training data under their own policies. | Nothing from us. We receive data from them only after you connect your own account yourself, and only what you allow. No such service is connected for any user today. | Their own policies. |
GoDaddy, Google and Cloudflare are certified under the EU–US Data Privacy Framework; an adequacy decision of the European Commission finds the protection in certified US companies adequate. Their contracts also contain the Commission’s standard contractual clauses (a ready-made contract that binds the provider to EU data protection rules) as a fallback. For Supabase and Anthropic we rely on the standard contractual clauses in their data processing terms. Where your browser connects directly to a provider that has none of these, as with the sample photos of Unsplash, no safeguard covers your IP address. You can ask us for a copy of the safeguard that applies (section 9).
6. AI and automated decisions
- What the AI does. In the MVP, a model reads your lab report and your meal photos and drafts a nutrition plan from your sex, calorie target and the status of your markers. In the app, training load, paces, calories and supplement amounts come from fixed, tested rules; the AI coach only explains the plan and proposes changes, the app checks every proposal against its safety rules, and nothing is applied by itself.
- No automated decisions with legal effect. We make no decision about you based solely on automated processing that has legal or similarly significant effects (Article 22 GDPR). Plans and suggestions are for you to use or ignore. You can ask a person at admin@infiniflow.me to explain or review any result.
- You are told when you deal with an AI. The AI Act (Article 50) requires this. The app’s coach screen already says that the coach is an AI; in the MVP, the report-upload and meal-photo screens say so, and we will add it to the nutrition-plan screen.
- No training on your data. infiniflow does not train AI models on your personal data. Under Anthropic’s commercial terms, Anthropic may not train its models on the content we send it.
- Your consent comes first. Your health data goes to an AI model only on the basis of your explicit consent, which you can withdraw at any time (section 4).
7. How long we keep data and how we delete it
| Data | How long |
|---|---|
| Website logs | As long as our hosting provider keeps them, under its own schedule. |
| Emails | As long as the matter needs and the law requires, then deleted. |
| MVP account and data | Until you ask us to delete them or we close the MVP. The MVP does not delete anything automatically yet. If we close it, we delete or anonymise the data. |
| Consent record | With your account, and deleted with it. |
| Copies at the AI provider | Anthropic deletes content sent through its API within 30 days, except in the cases it lists. The image services receive no personal data. |
| Backend logs and backups | The function logs of the MVP’s backend provider can show account details when an administrator creates or deletes an account, and the provider may make routine backups. Both are kept by that provider, on its own schedule; deleted data leaves them when they expire. |
| The app | The founders’ own data stays on their computers until they delete it. Records of sign-in attempts (keyed hashes of the email and address) are purged after 24 hours. |
Deleting your data. Write to admin@infiniflow.me. We act within one month. We delete your account, your profile and the data linked to it. Blood tests, plan-request records and profile-photo files are not removed automatically; we remove them by hand and tell you when it is done. Where the law obliges us to keep something, we tell you what and for how long.
8. How we protect your data
- Data protection by design and by default (Article 25). We collect what a feature needs and no more. Where we can, we send AI providers less than the whole: a nutrition plan, for example, is requested without your name or contact details, and the app’s coach does not receive the items derived from your blood tests. A lab report is sent whole, so that the model can read it. Today the app keeps its data on the founders’ own computers.
- Security of processing (Article 32). The website and the MVP are served over HTTPS, and browsers are told to insist on it (for now it lasts five minutes after each visit; we will lengthen this). Passwords are never stored in readable form. The MVP uses a managed database service with sign-in and access rules. We add no analytics tools or tracking scripts of our own, and our providers publish processing terms (section 11).
- Known limits. The MVP is a prototype and has not yet had an independent security review. Its access rules are still to be reviewed and may let other signed-in users see parts of your profile, so please use sample documents rather than your real medical records. A profile photo, if you upload one, can be opened by anyone who has its web address. We plan to review the MVP’s security before it is used more widely. Tell us at admin@infiniflow.me if you find a weakness.
- Personal data breaches (Articles 33 and 34). Unless a breach is unlikely to put people at risk, we notify the Romanian authority without undue delay and, where feasible, within 72 hours of becoming aware of it. If the risk is high, we also tell the people concerned without undue delay: what happened, what it may mean for them and what we are doing about it.
9. Your rights and how to use them
Under the GDPR you have the rights below. They apply to every person whose data we process, in the EU or outside it.
| Right | What it means | In our product |
|---|---|---|
| Access (Article 15) | To know whether we process your data and to get a copy, with the purposes, the kinds of data, the recipients (the specific ones, if you ask), how long we keep it and where it came from. | Ask by email. In the MVP you can already see your profile and your tests, and download your PDF report. |
| Correction (Article 16) | To have inaccurate data corrected and incomplete data completed. | Edit your profile in the MVP (the email address and the activity level cannot be changed there; ask us). |
| Erasure (Article 17) | To have your data deleted, for example when you withdraw consent or the data is no longer needed. It does not apply where the law makes us keep it. | In the MVP you can delete a blood test, a meal entry or a saved plan yourself; ask us to delete the rest or the whole account. |
| Restriction (Article 18) | To have us stop using your data, apart from storing it, for example while we check a dispute about its accuracy or an objection. | Ask by email. |
| Portability (Article 20) | To receive the data you gave us, including what your use of the service recorded, in a structured, commonly used, machine-readable format, and to have it sent to another service where that is technically possible. It covers data we process on your consent or for your contract. | Ask by email; we send a file (for example CSV or JSON). |
| Objection (Article 21) | To object, on grounds relating to your situation, to processing based on our legitimate interest. We stop unless we show compelling legitimate grounds that outweigh your interests, or we need the data for legal claims. | It covers the website logs and the handling of your emails. Ask by email. |
| Withdrawing consent (Article 7(3)) | To withdraw consent at any time, without affecting the lawfulness of processing done before. | Ask by email today. A way to do it inside the MVP and the app is coming (section 4). |
| No solely automated decisions (Article 22) | Not to be subject to a decision based solely on automated processing with legal or similarly significant effects. | We make no such decisions (section 6). |
How to make a request
- Write to admin@infiniflow.me from the address of your account, or tell us which account is yours, and say which right you want to use. You do not need a reason or special words.
- We may ask you to confirm who you are, but only with what is needed (Article 12(6)). We will not ask you for more health data to do so.
- We reply within one month. If your request is complex, or we have many, we may extend this by up to two more months; we tell you within the first month and say why.
- It is free. If a request is clearly unfounded or excessive, we may charge a reasonable fee or refuse it, and we tell you why (Article 12(4) and (5)).
- When we correct, delete or restrict data, we tell each recipient we gave it to, unless that is impossible or takes disproportionate effort (Article 19).
- If we say no, we tell you why and that you may complain to the authority and go to court (section 10).
10. Complaints and the supervisory authority
If you think we have handled your data unlawfully, please write to us first so that we can put it right. You may also complain, free of charge, to the supervisory authority (Article 77 GDPR) and go to court (Articles 78 and 79); if you have suffered damage you may claim compensation (Article 82).
- Authority
- Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), the Romanian data protection authority
- Website
- www.dataprotection.ro (the complaint form is on the site)
- anspdcp@dataprotection.ro
- Post
- B-dul G-ral. Gheorghe Magheru nr. 28-30, sector 1, București, cod poștal 010336
You can also complain to the authority of the country where you live or work, or where the problem happened. The authorities are listed on the website of the European Data Protection Board.
11. What the law asks of us, and where we stand
The GDPR makes us accountable for more than answering requests. These are the duties that matter most for a product that handles health data, and where we are with each. The MVP is a prototype shown for evaluation, and we ask people who try it to use sample documents; we complete the steps below before the app is opened to other people and before the MVP is used with real health data. Whenever we add a new kind of data or a new provider, for example when we start taking payments, we update this page and the privacy policy before it applies.
| Duty | Where we stand |
|---|---|
| Processing agreements with our providers (Article 28) | The providers in section 5 publish processing terms. Before the app is opened to other people, we will have signed or accepted them in the company’s own accounts for every provider that handles health data. |
| Record of processing activities (Article 30) | Companies with fewer than 250 employees are exempt only if their processing is occasional, unlikely to put people at risk and free of special-category data. Ours is not, so the duty applies to us. We will have the record in place before the app is opened to other people. |
| Impact assessment (Articles 35 and 36) | Required before processing that is likely to result in a high risk (Article 35(1)), and always for large-scale processing of health data (Article 35(3)(b)). Because we use AI on health data to build profiles, we expect it to be required. We will carry out and document one before the app is opened to other people and before the MVP is used with real health data, and consult the authority if a high risk remains. |
| Data protection officer (Articles 37 to 39) | Required when the core activities are large-scale processing of special-category data, or large-scale regular and systematic monitoring of people (which wearable data can be). We have not appointed one: today we process the data of a very small number of people, which we do not consider large scale. We will decide again before the app is opened and before the watch data of other people is connected, and say here what we decided. |
| Legal basis for health data (Article 9) | Explicit consent, as in section 4. We will have this basis reviewed by a specialist before the app is opened to other people. |
| Breach notification (Articles 33 and 34) | As described in section 8. |
12. Children, cookies and marketing
- Children. The MVP and the app are meant for adults, aged 18 or over. The MVP does not check your age yet. In Romania a child can consent to the processing of their data in an online service from the age of 16 (Article 8 GDPR); we ask for 18. We do not knowingly collect children’s data. If you think a child has given us any, write to admin@infiniflow.me and we will delete it.
- Cookies and similar technologies. We add no advertising, analytics or tracking cookies of our own, and our own code sets no cookies in the MVP. The app sets one sign-in cookie, which keeps you signed in and is needed for that. The MVP keeps two small items in your browser’s local storage: your sign-in session and your language choice. Both are stored only when you sign in or choose a language, and are strictly necessary to give you the service you asked for, so Law no. 506/2004 does not require your consent for them. The hosting provider’s script is different. GoDaddy inserts it into every page of infiniflow.me, the presentation page and the MVP alike. When we tested on 30 October 2026 it set three cookies on this domain: _tccl_visitor (a visitor identifier, kept for a year), _tccl_visit (30 minutes) and _scc_session (20 minutes), and it sent GoDaddy a page-view message and the page-loading times of each visit. These cookies are not needed to show you our pages and are set without asking you. You can block or delete the cookies in your browser settings.
- Marketing. We send no marketing messages. If we ever do, we will follow Law no. 506/2004: your consent first, and a simple way to unsubscribe in every message.
13. Changes to this page
We post any change on this page with its date. If a change matters for your data in the MVP or the app, we will tell you by email before it applies. Questions about this page: admin@infiniflow.me. This is draft 1, written on 30 October 2026.