Privacy Policy

Official PolicyVersion 1.0Last updated 24 October 2026

1. Who we are

In short: APEXi Digital Limited runs APEXi Flow. This policy is about the people who use Flow, not the candidates the training organisations look after.

1.1 APEXi Flow is a trading name of APEXi Digital Limited ("we", "us", "our"), a company registered in England and Wales under company number 17290313. Our registered office is Ingleby Road, Messingham, North Lincolnshire, DN17 3SS. We are not registered for VAT.

1.2 We are registered with the Information Commissioner's Office (ICO), registration number ZC276689.

1.3 To contact us about anything in this policy, write to support@apexiflow.com or to the address above. Enquiries and requests for a demonstration go to info@apexiflow.com, which is also the address our website's demonstration form uses. We have not appointed a Data Protection Officer because the law does not require one for us; privacy matters are dealt with by our Director.

1.4 We run the APEXi Flow website and application at apexiflow.com and app.apexiflow.com (the "Service").

2. What this policy covers, and what it does not

In short: it covers you if you hold an account with us. If you are a candidate on a course, the training organisation is responsible for your data, and you should read its notice.

2.1 This policy covers personal data about people who use Flow as, or on behalf of, a training organisation: account owners, administrators, trainers and anyone we deal with about billing or support. It also covers anyone who contacts us or asks for a demonstration, including through our website. For that data we decide how and why it is used, so we are the "controller".

2.2 Training organisations also store information about their own candidates in Flow: registrations, results, signatures, identity checks, certificates and course records. The training organisation decides what is collected and why, so the organisation is the controller of that information and we are its "processor", acting only on its instructions and under the data processing terms in our Terms and Conditions (Schedule 1). If you are a candidate, please read the privacy notice of the organisation that registered you, and contact it, not us, to use your rights. If you contact us about candidate data, we will pass your request to the organisation concerned.

2.3 The Service may link to other websites, including Stripe's payment pages and the websites of training organisations. We do not control them. Please read their privacy notices.

3. What is personal data?

In short: any information that identifies a living person.

3.1 Personal data is any information about an identifiable living person, as defined by the UK GDPR and the Data Protection Act 2018 (together, the "Data Protection Legislation"). It covers obvious details such as a name and email address and less obvious ones such as an online identifier or an IP address.

4. What data we collect and how

In short: account and contact details, how you use the Service, billing details, and what you send us.

4.1 We collect the following, depending on how you use the Service:

DataWhat it includesHow we get it
Identity and contactname, email address, telephone number, job title, the organisation you belong to and your role in ityou, or the person who invited you
Sign-inyour email, a protected (hashed) password if you use one, passkey details if you set one up, and the identifier from Google if you choose to sign in with Googleyou, and Google if you use it
Agreementswhich version of our Terms and Conditions and Privacy Policy was agreed, by whom and whenyou, when you set up an organisation
Profileyour preferences, and for trainers any qualifications and supporting documents you or your organisation uploadyou or your organisation
Billingthe organisation's legal name and address, plan and invoices, and the brand and last four digits of a payment card. Full card numbers are held only by Stripe, never by usthe organisation, and Stripe
Communicationswhat you send us (support messages, issue reports, files), and a record of the emails Flow sends and whether they were deliveredyou, and our email provider
Enquiriesyour name, organisation, email address, telephone number and message, if you contact us or ask for a demonstrationyou
TechnicalIP address, device and browser type, sign-in times, and error reportsyour device, automatically

4.2 We do not intentionally collect special category data (such as health information) about account holders. If an organisation chooses to record such information about its candidates, that is its decision and its responsibility as controller.

4.3 You may choose not to give us some information, but you cannot use the Service without the details needed to create and secure your account.

5. How we use your data, and why

In short: to run your account, take payment, keep the Service secure, and meet legal duties.

5.1 We must have a lawful basis for each use of personal data. These are ours:

What we doDataLawful basis
Create and run your account and give you the Serviceidentity and contact, sign-in, profileContract, or steps before a contract
Bill the organisation and take paymentbillingContract; legal obligation (tax and accounting records)
Send you messages needed to use the Service (invitations, sign-in and security notices, billing notices, reminders you have set up)identity and contact, communicationsContract; legitimate interests
Keep the Service secure, prevent fraud and abuse, and find and fix faultstechnical, sign-in, error reportsLegitimate interests: keeping a service that holds other organisations' records safe and working
Give support and handle complaintsidentity and contact, communicationsContract; legitimate interests
Reply to your enquiry or demonstration request, and arrange the demonstrationenquiriesLegitimate interests: answering people who ask about our service; and steps you ask for before a contract
Understand how the Service is used so we can improve ittechnical (aggregated where we can)Legitimate interests
Meet legal duties and respond to lawful requestsanyLegal obligation
Send the account owner and administrators updates about the Service: new and changed features, improvements, maintenance and tips on using itidentity and contactContract (these are part of the service we provide) and legitimate interests (keeping our customers informed about software they use). These are not marketing: they never promote offers, discounts or upgrades. Every one has a link to manage or stop them, and you can object at any time. We never send them to candidates, bookers or trainers whose details are held for an organisation
Send you marketing (offers, promotions, events or other products) by emailidentity and contactConsent. We send this only if you have asked for it, by a box that is never ticked for you, and you can withdraw at any time using the unsubscribe link in every such email

5.2 We do not make decisions about you based only on automated processing that have a legal or similarly significant effect.

5.3 We will only use your data for the purpose we collected it for, unless we reasonably believe another purpose is compatible, in which case we will tell you. Where the law allows or requires, we may process data without telling you, for example in response to a court order.

6. How long we keep your data

In short: for as long as the account exists and the law requires, then it is deleted.

6.1 We keep personal data no longer than is needed for the reasons we collected it:

DataHow long
Your own sign-in, identity, contact and profile detailswhile you belong to at least one organisation on Flow. If you belong to none and have not signed in for 12 months, we email you and, if you do not sign in after that email, delete them. You can ask us to delete them sooner
An organisation's records, including its candidatesuntil the organisation's account is finally closed, then deleted, except the certificate verification records and our billing records described in section 12 of the Terms and Conditions
Billing records (invoices and payment records)6 years from the end of the financial year in which they were issued, as tax and company law require
The record of who agreed to our Terms and Conditions and Privacy Policy for an organisation, which version and whenwhile the organisation's account exists, then 6 years after it closes, as evidence of the contract
Support messages and issue reports2 years after the matter is closed
Enquiries and demonstration requests that do not lead to an account2 years after our last contact with you
Error reports90 days
Sign-in and security logs12 months
Backups7 days: data deleted from the live system disappears from backups within 7 days

6.2 When an organisation closes its account, the closure process in our Terms and Conditions applies, including how it can export its data first and when everything is permanently deleted.

7. Where we store and send your data

In short: mainly within the UK and Europe, with safeguards for anything sent further.

7.1 We store your data with the providers listed in section 8. The main database is held in the United Kingdom (London). Uploaded files are stored in Cloudflare R2 in the EU. Emails are sent from Ireland, but our email provider stores its account data and logs in the United States. The application itself runs on Cloudflare's global network, close to the visitor, and stores nothing there beyond what is needed to deliver each page.

7.2 Some providers are based in, or can access data from, the United States. Where personal data goes outside the UK we rely on one of: an adequacy decision (the EEA and the UK–US Data Bridge for certified companies), or the ICO's International Data Transfer Agreement or UK Addendum to the EU standard clauses. Contact us if you want to see the safeguard used for a particular provider.

7.3 We protect your data with, among other measures: encrypted connections (HTTPS) everywhere; sessions that expire after inactivity; a session cookie that scripts on a page cannot read; passkey sign-in as an option; storage that keeps each organisation's data separate; private file storage with time-limited access; and limiting staff access to people who need it, all under a duty of confidentiality. We have a procedure for personal data breaches, and will tell the ICO and anyone affected where the law requires. No online system is completely secure, so we cannot promise absolute security.

8. Who we share your data with

In short: only the providers that run the Service for us, and where the law requires.

8.1 We use these providers to run the Service. Each acts as our processor and may use your data only to provide its service to us:

ProviderWhat it does for usWhere
Supabasedatabase and sign-inUnited Kingdom (London)
Cloudflarehosting the application and storing uploaded files (R2)Cloudflare's global network; uploaded files stored in the EU
Resendsending the emails Flow sends and recording deliveryemails sent from Ireland; account data and logs stored in the United States
Stripetaking and managing payments, and card storageStripe's global network, including the United States
Cloudflare Turnstilechecking that a visitor to a sign-in, sign-up or forgotten-password form, or about to make a paid booking, is a real person, to stop automated abuse.Cloudflare's global network
Sentryrecording technical errors so we can fix them (personal details are removed before sending where we can)EU (Germany)
Googleoptional sign-in with GoogleUnited States

8.2 We may also share personal data with professional advisers (lawyers, accountants and insurers) under duties of confidentiality, and with the police, courts, regulators or other public authorities where the law requires.

8.3 If we sell or merge our business, your data may pass to the new owner, who must keep using it as this policy says.

8.4 We do not sell your personal data.

9. Cookies and similar technologies

In short: we only use the cookie and browser storage needed to keep you signed in and remember your settings. No advertising or tracking cookies, so there is no cookie banner.

9.1 A cookie is a small file a website places on your device. We also use your browser's local and session storage in the same way. We use them under the Privacy and Electronic Communications Regulations 2003 (PECR). Everything below is strictly necessary to provide the Service you ask for or to remember choices you make, so the law does not require your consent.

9.2 What we use:

NameTypeWhat it doesHow long
apexi-refreshfirst-party cookie, HttpOnlykeeps you signed in on this deviceup to 30 days, or until you sign out
Selected organisation and rolelocal storageremembers which of your organisations you are working inuntil you clear browser data
Screen settings (for example menus folded away, notices already seen, setup guides finished)local storageremembers how you left the screenuntil you clear browser data
Page history within a sessionsession storagemakes the Back button workuntil you close the tab
Cloudflare Turnstile (on sign-in, sign-up, forgotten-password and paid-booking pages)third-party, set by Cloudflarechecks the visitor is a real person, to stop automated abuse; needed to keep the Service securefor the visit, or as Cloudflare's notice says
Stripe (only on pages that take a payment)third-party, set by Stripedetecting and preventing fraud on paymentsas Stripe's notice says

Cloudflare and Stripe set these cookies themselves and may change them, so we describe what they do instead of listing their names. See Cloudflare's and Stripe's own cookie and privacy notices for details. Both are strictly necessary for security and fraud prevention, so the law does not require your consent for them.

9.3 We do not use analytics, advertising or tracking cookies. If we add any, we will update this policy and ask for your consent first.

9.4 You can block or delete cookies in your browser settings, but you will not be able to stay signed in.

10. Your rights

In short: you can ask to see, correct, delete or move your data, object to its use, and complain.

10.1 Under the Data Protection Legislation you have the right to: be informed about how we use your data; access it; have it corrected; have it erased; restrict how it is used; object to its use; withdraw consent where we rely on it; receive it in a portable form; and not be subject to certain automated decisions. These rights have conditions, and we will tell you if one stops us acting on a request.

10.2 To use a right, contact us as in section 1.3. We may ask for proof of identity first and will keep you informed.

10.3 It is important that the data we hold is accurate. Please tell us if your details change.

11. Seeing the data we hold about you

In short: ask us in writing; there is normally no charge, and we reply within a month.

11.1 You can ask us for a copy of the personal data we hold about you (a "subject access request"). Please write to the contact in section 1.3. A form is not required, but giving us enough detail helps us reply quickly.

11.2 There is normally no charge. If a request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse it, and we will explain why.

11.3 We will reply within one month of receiving the request and your identity being confirmed. If your request is complex or you have made several, we may extend this by up to two further months, and we will tell you within the first month. If we need to ask you for more detail to find your information, the time limit pauses until you answer. We carry out reasonable and proportionate searches for the information.

12. Complaints

In short: tell us first and we will acknowledge within 30 days; you can also go to the ICO.

12.1 If you are unhappy with how we have used your data, please tell us as in section 1.3. We will acknowledge your complaint within 30 days, look into it without undue delay, and tell you the outcome.

12.2 You also have the right to complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113).

13. Children

In short: accounts are for adults.

13.1 The Service is for business use and its account holders must be over 18. We do not knowingly collect account data from children. Information about candidates, who may be younger, is recorded by the training organisation as controller.

14. Changes to this policy

In short: we will tell you about important changes.

14.1 We may change this policy, for example if the law changes or we change the Service. The current version is always on this page with its version number and date. For a significant change we will email the account owner before it takes effect. Please check this page from time to time.

15. Contact

In short: how to reach us.

15.1 APEXi Digital Limited (trading as APEXi Flow), Ingleby Road, Messingham, North Lincolnshire, DN17 3SS. Email support@apexiflow.com (or info@apexiflow.com for enquiries and demonstrations).

Versions