Last updated: January 09, 2026

Privacy Policy

Introduction

FLOW WITH ME PTE. LTD. trading as Flow with Mira (“we,” “our,” “us,” “the Company”) values and respects your privacy. This Privacy Policy describes our practices regarding the collection, use, and disclosure of your information through our secure member platform, accessible via studio.flowwithmira.com and our mobile applications (collectively, the “Platform” or “Service”).

Important: This privacy policy specifically covers our member area at studio.flowwithmira.com and the Flow with Mira mobile app. For information about our marketing website (flowwithmira.com), please see our main privacy policy.

This policy complies with Singapore’s Personal Data Protection Act (PDPA), the EU’s General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy laws.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

You/Member: The individual accessing or using the Service
Account: A unique account created for You to access our Service
Affiliate: An entity that controls, is controlled by or is under common control with a party
Application: The software program provided by the Company named Flow with Mira Online
Company: FLOW WITH ME PTE. LTD. trading as Flow with Mira
Country: Singapore
Device: Any device that can access the Service (computer, phone, tablet, TV via Chromecast/AirPlay)
Health Data: Information related to your physical condition, fitness goals, injury history, and exercise preferences
Membership Data: Information related to your subscription, access levels, and community participation
Personal Data: Any information relating to an identified or identifiable individual
Service: The dynamic membership platform, Application, or the Website or both
Service Provider: Any person or entity who processes data on behalf of the Company
Usage Data: Data collected automatically during Service use
Website: Flow with Mira Studio, accessible from https://studio.flowwithmira.com/

1. Account & Profile Information

1. Personal Data

When you create or maintain your member account, we collect:

Email address
First name and last name
Phone number (optional)
Address information (for billing)
Payment information (processed securely by our payment providers)
Membership subscription details
Profile information and preferences

2. Health & Fitness Information (Optional)

Through our fitness survey and profile setup, you may voluntarily provide:

Exercise history and experience level
Fitness goals and preferences
Physical condition and limitations
Injury history relevant to exercise
Health concerns relevant to exercise
What you’re looking for from your Pilates practice
How we can best help you
Workout completion records
Progress tracking data (coming soon)

Important: This information is:

Provided voluntarily by you through optional surveys
Used only for customizing your experience and providing appropriate recommendations
Protected with enhanced security measures
Never shared for marketing purposes
Subject to specific retention policies

3. Membership and Community Data

For our dynamic membership platform, we collect:

Membership tier and access levels: Your subscription type and what content you can access
Video viewing history: Which classes you’ve watched, when, and for how long
Video completion rates: Whether you finished a class or stopped partway through
Favorites and bookmarks: Classes you’ve saved for later viewing
Content preferences: Types of classes you search for and watch most
Community participation: Comments you post on classes
Q&A participation: Questions you submit for monthly Q&A sessions (may be included in recorded sessions)
Live class registrations: When you sign up for live classes (we send you a Zoom link but do not track attendance)
Support requests: Messages and forms you submit for help
Subscription management: Upgrades, downgrades, cancellations

Note about Q&A recordings: Our monthly Q&A sessions are recorded and posted as member content. If you participate live on camera or audio, your voice or video may be included. Questions submitted via text may be read aloud during the recording.

4. Usage Data

We automatically collect:

IP address
Device information (type, model, operating system)
Browser type and version
Service usage patterns (pages visited, features used)
Access times and dates
Feature interaction data
Technical diagnostic data (errors, crashes)
Video streaming metrics (buffering, quality, loading times)
Search history within the platform

5. Mobile Device Data

When accessing via mobile devices:

Device type and ID
Operating system and version
Mobile browser type
App version
IP address
Technical and performance data

5. Mobile Device Data

When accessing via mobile devices:

Device type and ID
Operating system and version
Mobile browser type
App version
IP address
Technical and performance data

6. Downloaded Content

PDF downloads: We track when you download class guides and resources
Video downloads (App only): The app allows you to download videos for offline viewing. These are stored locally on your device – we do not track which specific videos you’ve downloaded
Chromecast/AirPlay: You can cast videos to your TV using these features. We do not track when or how you use casting features

How We Use Your Personal Data

We only share your data with trusted partners who help us operate the Service. We never sell your personal information to third parties.

Service Providers

Hosting & Infrastructure

WPEngine: Hosts our member area website (studio.flowwithmira.com)
VidApp: Powers our mobile app infrastructure and delivery
Cloudflare: Provides security and performance optimization

Video & Content Delivery

JW Player: Hosts and delivers video content for smooth streaming

Membership Management

MemberPress: Manages member authentication, subscriptions, and access control

Payment Processors

Stripe: Processes credit and debit card payments
PayPal: Processes PayPal payments
Apple Store In-App Payments: Processes iOS in-app purchases
Google Play In-App Payments: Processes Android in-app purchases

For transaction processing only – Payment processors have access only to information necessary to process transactions. We do not store full credit card numbers.

Communication Tools

FluentCRM: Manages member emails, newsletters, and automated communications
Fluent Forms: Processes support requests, surveys, and form submissions

Analytics & Marketing

Google Analytics: Helps us understand how members use the platform (data anonymized where possible)
Facebook Pixel: Tracks advertising conversions and effectiveness (being implemented)

Facebook
Instagram
YouTube
Pinterest

For content delivery, community building, and marketing purposes

Data Transfer and Storage

International Transfers

Your data may be processed in:

Singapore (our primary location)
United States (where some service providers operate)
Other countries where we operate or our service providers have infrastructure

Transfer Safeguards

We ensure:

Appropriate security measures are in place
Data protection agreements with all service providers
Compliance with local privacy laws
Standard contractual clauses where required by law
Regular security assessments

Data Retention

Active Membership

While you’re an active member, we retain:

Your account and profile information
Video watch history and progress data
Favorites, bookmarks, and preferences
Community posts and comments
Support communications

After Membership Ends

Account Retention: When you cancel or your membership ends, we keep your account profile so you can easily rejoin later with all your preferences, watch history, and favorites intact. You won’t have access to premium content during this time (except free classes), but your account remains ready for reactivation.

Data Retention Periods:

Kept indefinitely: Account information, watch history, favorites, progress (enables easy reactivation)
Kept for 7 years: Payment and transaction records (required by tax and accounting laws)
Kept for 3 years: Support communications and correspondence
Removed immediately: Access to premium member content

Health Data Retention

Specific retention for:

Fitness assessments and surveys
Workout history and completion data
Health and injury information you’ve provided
Progress tracking records

This data is retained to provide you with a seamless experience if you return to the platform.

Complete Data Deletion

If you want us to permanently delete your account and all associated data:

Email [email protected] with subject “Delete My Account”
We’ll verify your identity and process your request within 30 days
We’ll permanently delete your data, except:
- Information we’re legally required to retain (payment records for tax purposes)
- Anonymized analytics data that cannot be linked back to you

Deletion Process includes:

Secure erasure methods that make data unrecoverable
Removal from all backup systems
Notification to relevant service providers
Verification and confirmation to you

Regional Privacy Rights and Compliance

1. Singapore Personal Data Protection Act (PDPA)

Your Rights

You have the right to:

Access your personal data and know how it’s used
Correct inaccurate or outdated data
Withdraw consent for certain processing activities
Request data portability (transfer to another service)
Request deletion of your data

Our Obligations

We commit to:

Obtaining valid consent before collecting data
Ensuring data accuracy and keeping it up to date
Providing access and correction mechanisms
Protecting data during transfers
Implementing appropriate security measures
Being transparent about our data practices

Legal Bases for Processing

We process your data under:

Consent: When you sign up and agree to our terms
Contract performance: To provide your membership services
Legal obligations: Tax reporting, fraud prevention, legal compliance
Legitimate interests: Improving our service, security, analytics
Vital interests: Protecting your safety or health
Public interest: Where applicable to our services

You may request:

Access: Get a copy of all data we hold about you
Rectification: Correct inaccurate or incomplete data
Erasure (Right to be forgotten): Delete your data completely
Restriction: Limit how we process your data
Portability: Transfer your data to another service
Object: Stop certain types of processing (like marketing)
Withdraw consent: Remove permission previously given
Automated decisions: Challenge decisions made solely by algorithms

Data Protection Measures

We implement:

Privacy by design (privacy built into everything we build)
Data protection impact assessments for new features
Detailed record keeping of processing activities
Breach notification procedures (72-hour reporting)
Regular staff training on GDPR compliance

3. CCPA Compliance (For California Residents)

Categories of Personal Information We Collect

Identifiers:

Name, email address, phone number
IP address, device ID
Account name and membership ID

Personal Information Categories (as defined by California law):

Financial information (payment methods, transaction history)
Health information (fitness level, injuries, goals)
Purchase history (membership subscriptions)
Fitness data (workout preferences and completion)
Membership data (tier, access level, community participation)

Internet Activity:

Browsing history on our platform
Search history within our service
Video viewing history and engagement
Service interaction patterns

Health and Fitness Data:

Exercise preferences and experience
Physical condition and limitations
Fitness goals and progress
Workout history and completion

Your CCPA Rights

California residents have the right to:

Know: What personal information we collect, use, and share
Delete: Request deletion of your personal information
Opt-out: Stop the “sale” of your personal information (note: we do not sell your data)
Non-discrimination: Exercise your rights without penalty or different service
Access: Receive a copy of your specific pieces of information

How to Exercise Your CCPA Rights

Request methods:

Email: [email protected] with subject “CCPA Request”
Through your account settings (for some requests)
Via authorized agent with proper documentation

We will:

Verify your identity before processing requests
Respond within 45 days (with possible 45-day extension if needed)
Provide information free of charge (up to twice per year)

4. Additional Regional Requirements

Australia Privacy Act

We comply with Australian Privacy Principles including:

Collection notification and consent
Use and disclosure limitations
Data quality and accuracy standards
Security safeguards
Access and correction rights

Canada PIPEDA

We ensure:

Meaningful consent for collection and use
Limited collection to necessary purposes
Limited use, disclosure, and retention
Accuracy of personal information
Appropriate security safeguards

Brazil LGPD

We maintain:

Lawful processing principles
Clear legal bases for processing
Data subject rights (similar to GDPR)
Appropriate security measures
Data protection officer availability

Security and Data Protection

1. Security Measures

Technical Protection

We implement:

Encryption: All data encrypted in transit (HTTPS/SSL) and at rest
Secure servers: Industry-standard infrastructure with automatic security updates
Firewall protection: Multi-layer network security
Access control: Strict authentication and authorization systems
Regular security updates: Continuous patching and improvement
Secure video streaming: Protected delivery of video content
Payment security: PCI DSS compliant payment processing

Organizational Measures

We maintain:

Comprehensive employee training on data protection
Strict access restriction policies (need-to-know basis)
Regular security audit procedures
Documented incident response plans
Clear data handling protocols
Confidentiality agreements for all staff and contractors

Health Data Security

Enhanced protection for sensitive health information:

Separate, encrypted storage systems
Extremely limited access (only staff who need it to help you)
Never used for marketing or advertising
Clear retention and deletion policies
Additional security audits

2. Data Breach Procedures

Notification Process

In the unlikely event of a data breach, we will:

Immediately investigate and contain the breach
Assess the impact and affected data
Notify affected members within 72 hours (or as required by law)
Report to relevant authorities if legally required
Take immediate remedial action
Document the incident thoroughly
Implement additional safeguards to prevent future breaches

Response Timeline

Immediate internal notification and containment
72-hour authority notification (GDPR requirement)
User notification as required by law and circumstances
Regular status updates throughout the resolution process

3. Your Role in Security

Help us protect your account:

Strong password: Use a unique, complex password for your account
Don’t share: Never share your login credentials with anyone
Secure devices: Log out when using shared or public devices
Email security: Keep your email account secure (we use it for password resets)
Report issues: Notify us immediately of any suspicious activity
Update software: Keep your devices and apps up to date

Cookies & Tracking Technologies

What Are Cookies?

Cookies are small text files stored on your device that help websites remember you and provide a better experience. We use cookies and similar technologies to make our platform work and improve your experience.

Types of Cookies We Use

Essential Cookies (Always Active)

Required for the platform to function properly:

Keep you logged into your account
Remember your session as you navigate
Maintain security and prevent fraud
Process payments securely
Remember your language and region preferences

You cannot opt-out of these cookies as the platform won’t work without them.

Functional Cookies

Enhance your experience and remember your preferences:

Video player settings (quality, volume, autoplay)
Your saved favorites and bookmarks
Where you left off in videos
Your content filters and search preferences
Display preferences (dark mode, layout options)

Analytics Cookies

Help us understand how members use the platform:

Google Analytics: Tracks page views, popular classes, user flow, and engagement patterns
Video analytics: Monitors playback quality, buffering issues, completion rates
Performance monitoring: Identifies technical issues and slow-loading pages

This data is anonymized where possible and helps us improve the service.

Marketing Cookies (Coming Soon)

May be used for:

Facebook Pixel: Tracks advertising effectiveness and conversions
Retargeting: Shows relevant ads to members who’ve visited certain pages
Campaign tracking: Measures success of marketing campaigns

Managing Cookies

You can control cookies through:

Browser settings: Most browsers let you block or delete cookies (note: this may affect platform functionality)
Google Analytics opt-out: Use the Google Analytics opt-out browser add-on
Do Not Track: We respect browser DNT (Do Not Track) signals where technically feasible

For more detailed information, see our full Cookie Policy.

Children’s Privacy

Age Restrictions

Our Service is designed for adults and is not intended for children under 13 years old.

We do not knowingly collect personal information from children under 13
If we discover we’ve collected data from a child under 13, we’ll delete it immediately
Parents: If you believe your child has provided information to us, please contact [email protected] immediately

Teen Members (Ages 13-17)

If you’re between 13-17 years old:

You may use the platform with parental consent
Your parent or guardian is responsible for managing your account
We may request parental verification before providing access
Special care is taken with your data

Verification

We may:

Request age verification during signup
Ask for parental consent for users under 18
Remove accounts that violate age requirements
Block registration attempts from underage users

Third-Party Links and Services

Our platform may contain links to third-party websites or services, such as:

YouTube (for tutorial or promotional videos)
Social media platforms
Product recommendations or equipment suppliers
Partner services or resources

Important: This Privacy Policy does not apply to third-party websites or services. Each has its own privacy practices and policies.

Our recommendation: Review the privacy policy of any third-party site before providing personal information.

We are not responsible for the privacy practices or content of external sites.

Changes to This Privacy Policy

1. Update Procedures

We may update this Privacy Policy to:

Reflect changes to our platform, features, or services
Comply with new legal or regulatory requirements
Improve protection of your personal data
Enhance clarity and transparency
Add new functionalities or integrations

2. How We’ll Notify You

For significant changes, we will notify you through:

Email: To your registered email address
Platform notice: Prominent banner in the member area
App notification: Push notification in the mobile app
Service announcement: Message upon next login

3. Prior Notice Period

Material changes: 30 days advance notice
Minor updates: Notification upon next visit
Legal requirements: Immediate effect if required by law
Review period: Clear communication of what changed and why

4. Your Options

If you don’t agree with changes to this Privacy Policy:

Contact us with your concerns before the changes take effect
Cancel your membership per our Terms of Service
Request deletion of your data

Continued use of the platform after changes take effect means you accept the updated Privacy Policy.

Contact Information

Privacy Questions or Requests

For any privacy-related questions, concerns, or to exercise your rights:

Email: [email protected]
Subject Line: “Privacy Request” or “Data Protection Inquiry”

What to include in your request:

Your full name and email address associated with your account
Clear description of your request
Any relevant details or documentation

Company Details

FLOW WITH ME PTE. LTD.
Trading as Flow with Mira
Singapore

Data Protection Officer

For specific data protection concerns, GDPR-related requests, or to reach our Data Protection Officer, use the same email address above with subject “Data Protection Officer”.

Regional Contacts

Singapore (Primary): [email protected]
EU Representative: Available upon request
UK Representative: Available upon request
California Representative: Available upon request

Response Times

We aim to respond to:

General privacy questions: Within 5 business days
Access/deletion requests: Within 30 days (or as required by law)
GDPR requests: Within 30 days (with possible 60-day extension)
CCPA requests: Within 45 days (with possible 45-day extension)
Urgent security issues: Within 24 hours

Legal Framework

Governing Law

This Privacy Policy is governed by the laws of Singapore. Any disputes arising from this policy will be subject to the exclusive jurisdiction of Singapore courts, except where:

EU/UK law applies to EU/UK residents (GDPR jurisdiction)
California law applies to California residents (CCPA jurisdiction)
Other local laws mandate different jurisdiction
Specific regulations require alternative dispute resolution

Severability

If any provision of this Privacy Policy is found to be invalid, unlawful, or unenforceable:

That provision will be modified to the minimum extent necessary to make it enforceable
If modification is not possible, the provision will be severed
All other provisions remain in full force and effect
The overall purpose and intent of the policy remains intact

Language

This Privacy Policy is written in English. Any translations are provided for convenience only.

In case of conflict between versions, the English version prevails
Translations are not legally binding
Interpretation is based on English text

Entire Agreement

This Privacy Policy:

Constitutes the entire agreement regarding privacy practices
Supersedes all prior versions and communications
Should be read together with our Terms of Service
Incorporates all amendments and updates

By creating an account and using our Service, you acknowledge that you have:

Read this Privacy Policy in its entirety and understand it
Understood how we collect, use, protect, and share your data
Consented to the data practices described (where consent is the legal basis)
Understood your privacy rights and how to exercise them
Agreed to updates to this policy as described above

If you do not agree with this Privacy Policy, please do not use our Service.

You can withdraw your consent at any time by:

Canceling your membership
Requesting account deletion
Contacting us with specific objections

Last Updated: January 09, 2026
Effective Date: January 09, 2026