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// Regenerate with scripts/build-legal-content.py when counsel revises copy.
import type {LegalDocument} from './types';
export const security: LegalDocument = {
"slug": "security",
"title": "Security & Data Protection Statement",
"version": "1.0",
"effectiveDate": "July 7, 2026",
"lastUpdated": "July 7, 2026",
"blocks": [
{
"type": "heading",
"level": 1,
"text": "1. PURPOSE AND SCOPE"
},
{
"type": "heading",
"level": 2,
"text": "1.1 Purpose of this Statement"
},
{
"type": "p",
"text": "FlowState Flow State Capital LLC (\"FlowState,\" \"Company,\" \"we,\" \"us,\" or \"our\") is committed to maintaining a security and data protection program designed to safeguard business information, personal information, customer records, platform activity, and related information processed in connection with the FlowState website, platform, treasury tools, onboarding workflows, lending-support workflows, partner banking coordination, and related business services."
},
{
"type": "p",
"text": "This Security & Data Protection Statement describes FlowState's general approach to protecting information and supporting operational resilience. It is intended for customers, prospective customers, vendors, financial partners, and other stakeholders who want to understand how FlowState approaches security, confidentiality, data handling, vendor oversight, incident response, employee training, and business continuity."
},
{
"type": "heading",
"level": 2,
"text": "1.2 Scope of Covered Information"
},
{
"type": "p",
"text": "This Statement applies to information that FlowState collects, receives, stores, transmits, processes, or otherwise handles in connection with the website, platform, and services, including personal information, business information, account onboarding records, identity verification materials, financial information, compliance documents, communications, usage data, and other customer-submitted information."
},
{
"type": "p",
"text": "This Statement is intended to supplement, and not replace, FlowState's Privacy Policy, Terms of Use, Cookie Policy, applicable product agreements, customer agreements, partner disclosures, and any specific contractual security or data protection terms that may apply to a particular customer relationship or product."
},
{
"type": "heading",
"level": 2,
"text": "1.3 Relationship to Banking Partners and Third Parties"
},
{
"type": "p",
"text": "Certain services made available through or in connection with FlowState may be provided by banks, trust companies, custodians, payment processors, identity verification providers, cloud service providers, compliance vendors, data providers, software vendors, lenders, loan servicers, or other third-party providers. Those third parties may maintain their own security programs, data protection practices, privacy notices, service terms, and incident response obligations."
},
{
"type": "p",
"text": "FlowState seeks to work with third-party providers that support commercially reasonable security and data protection standards. However, unless expressly stated in a written agreement, FlowState does not control and is not responsible for the independent security programs, systems, outages, incidents, acts, omissions, or compliance obligations of third-party providers."
},
{
"type": "heading",
"level": 1,
"text": "2. SECURITY PROGRAM OVERVIEW"
},
{
"type": "heading",
"level": 2,
"text": "2.1 Risk-Based Security Framework"
},
{
"type": "p",
"text": "FlowState seeks to maintain a risk-based security program appropriate to the nature of its business, the sensitivity of information it handles, the services it provides, and the evolving threat environment. The security program is designed to reduce the risk of unauthorized access, data loss, misuse, alteration, disruption, and improper disclosure."
},
{
"type": "p",
"text": "FlowState's security program may include administrative, technical, physical, and organizational safeguards designed to protect information and systems. These safeguards may evolve over time as FlowState's products, banking relationships, vendor environment, technology stack, regulatory obligations, and operational risk profile change."
},
{
"type": "ul",
"items": [
"Administrative safeguards, including policies, procedures, governance, training, vendor review, and access approval processes.",
"Technical safeguards, including encryption, access controls, authentication, monitoring, logging, secure configuration, and vulnerability management.",
"Physical safeguards, including reasonable controls over offices, devices, equipment, and paper records where applicable.",
"Organizational safeguards, including role-based responsibilities, escalation procedures, approval workflows, and oversight processes."
]
},
{
"type": "heading",
"level": 2,
"text": "2.2 Governance and Accountability"
},
{
"type": "p",
"text": "FlowState seeks to assign responsibility for security and data protection to appropriate personnel and leadership functions. Security governance may include management oversight, periodic review of security practices, vendor risk review, incident escalation procedures, and coordination among technology, operations, legal, compliance, and customer-facing teams."
},
{
"type": "p",
"text": "As FlowState matures, the Company may adopt additional written policies and procedures covering information security, acceptable use, access management, incident response, vendor management, business continuity, data retention, privacy, employee onboarding and offboarding, change management, and related areas."
},
{
"type": "heading",
"level": 1,
"text": "3. ENCRYPTION AND PROTECTION OF DATA"
},
{
"type": "heading",
"level": 2,
"text": "3.1 Encryption in Transit"
},
{
"type": "p",
"text": "FlowState seeks to use industry-standard encryption protocols to protect information transmitted between users and FlowState systems, and between FlowState and approved service providers, where technically feasible and appropriate. This may include transport layer security for websites, portals, application interfaces, and other online communications."
},
{
"type": "p",
"text": "Users should access the FlowState website and platform only through secure connections and should avoid submitting sensitive information through unsecured channels, unencrypted email, or unauthorized communication methods unless expressly instructed by FlowState through an approved process."
},
{
"type": "heading",
"level": 2,
"text": "3.2 Encryption at Rest"
},
{
"type": "p",
"text": "FlowState seeks to use encryption at rest or equivalent protective measures for sensitive information stored within approved systems, databases, document repositories, cloud environments, or vendor platforms where technically feasible and appropriate. The level and method of encryption may vary based on data type, storage location, system architecture, vendor capabilities, legal requirements, and operational needs."
},
{
"type": "p",
"text": "Encryption is one layer of protection and is not a substitute for appropriate access controls, authentication procedures, monitoring, vendor oversight, data minimization, employee training, and other safeguards."
},
{
"type": "heading",
"level": 2,
"text": "3.3 Secure Transmission and File Handling"
},
{
"type": "p",
"text": "FlowState may provide secure document upload workflows, encrypted portals, electronic signature tools, or other approved methods for submitting sensitive documents. Users should submit sensitive information only through approved FlowState channels or other secure channels authorized by FlowState."
},
{
"type": "p",
"text": "Sensitive documents may include identity records, financial statements, bank statements, beneficial ownership information, tax information, organizational documents, lending materials, collateral documentation, compliance certifications, and other records used for onboarding, treasury services, lending support, or partner bank review."
},
{
"type": "ul",
"items": [
"FlowState may restrict use of email for highly sensitive records where a secure upload method is available.",
"FlowState may require additional verification before accepting or acting on sensitive account, payment, wire, or ownership instructions.",
"FlowState may retain transmission logs, upload logs, access logs, and audit records as appropriate for security and compliance purposes."
]
},
{
"type": "heading",
"level": 1,
"text": "4. ACCESS CONTROLS AND MULTI-FACTOR AUTHENTICATION"
},
{
"type": "heading",
"level": 2,
"text": "4.1 Role-Based Access Controls"
},
{
"type": "p",
"text": "FlowState seeks to limit access to sensitive systems and information based on role, responsibility, business need, and least-privilege principles. Access may be granted, modified, reviewed, or revoked based on job function, customer relationship, vendor role, security status, and operational need."
},
{
"type": "p",
"text": "Internal access to sensitive information should be limited to personnel or authorized vendors who require access to perform their duties. FlowState may maintain logs, permissions records, approval workflows, or other controls to support access governance."
},
{
"type": "heading",
"level": 2,
"text": "4.2 Multi-Factor Authentication"
},
{
"type": "p",
"text": "FlowState may require or support multi-factor authentication for access to certain systems, administrative tools, vendor platforms, customer portals, email systems, cloud environments, or other sensitive resources. Multi-factor authentication is designed to reduce the risk of account takeover resulting from compromised passwords or credentials."
},
{
"type": "p",
"text": "Where multi-factor authentication is available or required, users and employees are expected to maintain control over authentication devices, one-time codes, hardware keys, authenticator applications, and recovery methods. FlowState may restrict access where multi-factor authentication is not properly configured, unavailable, or suspected to be compromised."
},
{
"type": "heading",
"level": 2,
"text": "4.3 Account Lifecycle Management"
},
{
"type": "p",
"text": "FlowState seeks to maintain account lifecycle controls for employees, contractors, vendors, and authorized users. These controls may include onboarding review, access approval, permission assignment, periodic access review, access changes when roles change, and prompt termination or restriction of access when a person is no longer authorized."
},
{
"type": "p",
"text": "Customers are responsible for managing their own authorized users, internal approvals, account administrators, credential security, and access permissions where the platform allows customer-managed access."
},
{
"type": "heading",
"level": 1,
"text": "5. VENDOR OVERSIGHT AND THIRD-PARTY RISK MANAGEMENT"
},
{
"type": "heading",
"level": 2,
"text": "5.1 Vendor Due Diligence"
},
{
"type": "p",
"text": "FlowState may rely on third-party providers for cloud hosting, software, banking coordination, identity verification, compliance screening, customer relationship management, analytics, communications, electronic signatures, document storage, payments, lending support, and other operational functions. FlowState seeks to evaluate vendors based on the nature of the services provided, the sensitivity of information handled, the importance of the vendor to operations, and the risk associated with the vendor relationship."
},
{
"type": "p",
"text": "Vendor review may include evaluation of security documentation, privacy practices, service descriptions, contract terms, data handling commitments, incident notification obligations, business continuity capabilities, compliance certifications, financial services experience, and operational dependencies."
},
{
"type": "heading",
"level": 2,
"text": "5.2 Contractual Controls"
},
{
"type": "p",
"text": "FlowState seeks to include appropriate contractual protections in vendor agreements where feasible and appropriate. Such protections may include confidentiality obligations, data protection requirements, restrictions on use of information, incident notification requirements, audit or review rights, service levels, subcontractor controls, termination rights, and obligations to comply with applicable law."
},
{
"type": "p",
"text": "The specific controls applicable to a vendor relationship may vary based on vendor type, bargaining position, materiality, information sensitivity, regulatory requirements, banking partner expectations, and available contract terms."
},
{
"type": "heading",
"level": 2,
"text": "5.3 Ongoing Vendor Oversight"
},
{
"type": "p",
"text": "FlowState may periodically review material vendors and third-party providers to assess continued suitability, performance, security posture, service availability, and risk. Ongoing oversight may include review of updated security reports, incident history, service outages, policy changes, privacy updates, performance issues, and customer impact."
},
{
"type": "heading",
"level": 1,
"text": "6. EMPLOYEE TRAINING AND INTERNAL CONTROLS"
},
{
"type": "heading",
"level": 2,
"text": "6.1 Security Awareness Training"
},
{
"type": "p",
"text": "FlowState seeks to provide appropriate security awareness training to employees, contractors, and relevant personnel. Training may address phishing, social engineering, password security, multi-factor authentication, device security, data handling, incident reporting, confidentiality, privacy, acceptable use, and customer information protection."
},
{
"type": "p",
"text": "Training may be provided during onboarding and periodically thereafter. FlowState may supplement training with policy reminders, targeted security notices, simulated phishing exercises, role-specific guidance, or incident-driven updates."
},
{
"type": "heading",
"level": 2,
"text": "6.2 Confidentiality and Data Handling Expectations"
},
{
"type": "p",
"text": "FlowState personnel are expected to handle customer and business information in accordance with applicable policies, contractual obligations, privacy notices, confidentiality obligations, and legal requirements. Personnel should access, use, disclose, and retain information only for authorized business purposes."
},
{
"type": "p",
"text": "FlowState may require employees, contractors, and vendors to agree to confidentiality obligations and may restrict access to sensitive information based on job responsibilities and business need."
},
{
"type": "heading",
"level": 2,
"text": "6.3 Internal Controls for Sensitive Instructions"
},
{
"type": "p",
"text": "Because FlowState may support treasury, lending, onboarding, account coordination, and financial workflows, FlowState seeks to maintain internal controls designed to reduce the risk of unauthorized instructions, account takeover, business email compromise, payment fraud, and document manipulation."
},
{
"type": "ul",
"items": [
"Additional verification may be required for changes to bank instructions, authorized signers, ownership information, payment details, or sensitive account information.",
"Sensitive instructions may be subject to call-back procedures, dual review, supervisory approval, partner bank verification, or delayed processing.",
"FlowState may decline to process instructions that appear suspicious, inconsistent, incomplete, unauthorized, or inadequately verified."
]
},
{
"type": "heading",
"level": 1,
"text": "7. INCIDENT RESPONSE AND SECURITY EVENT MANAGEMENT"
},
{
"type": "heading",
"level": 2,
"text": "7.1 Incident Response Program"
},
{
"type": "p",
"text": "FlowState seeks to maintain an incident response process designed to identify, evaluate, escalate, contain, investigate, remediate, and document security incidents. The process may vary depending on the nature, severity, scope, and customer impact of an incident."
},
{
"type": "p",
"text": "Security incidents may include unauthorized access, credential compromise, malware, ransomware, phishing, business email compromise, data loss, system intrusion, vendor incident, accidental disclosure, payment fraud, suspicious activity, or other events affecting the confidentiality, integrity, or availability of information or systems."
},
{
"type": "heading",
"level": 2,
"text": "7.2 Incident Escalation and Investigation"
},
{
"type": "p",
"text": "When FlowState identifies or receives notice of a potential security incident, FlowState may take steps to assess the event, preserve relevant information, restrict access, involve appropriate personnel, engage third-party experts, contact vendors, notify banking partners, and take other actions designed to contain or mitigate risk."
},
{
"type": "p",
"text": "FlowState may maintain records of incident reports, investigation steps, findings, customer impact assessments, remediation actions, legal analysis, regulatory considerations, and communications as appropriate."
},
{
"type": "heading",
"level": 2,
"text": "7.3 Notification and Communication"
},
{
"type": "p",
"text": "If FlowState determines that a security incident requires notice to customers, regulators, law enforcement, banking partners, vendors, or other parties, FlowState will seek to provide such notice in accordance with applicable law, contractual obligations, and operational considerations. The timing and content of notice may depend on investigation status, legal requirements, law enforcement guidance, partner obligations, and the risk of further harm."
},
{
"type": "p",
"text": "FlowState may be unable to provide detailed information about certain security events where doing so could compromise security, interfere with an investigation, violate legal restrictions, reveal confidential third-party information, or increase risk to customers or systems."
},
{
"type": "heading",
"level": 1,
"text": "8. BUSINESS CONTINUITY AND RESILIENCE"
},
{
"type": "heading",
"level": 2,
"text": "8.1 Business Continuity Planning"
},
{
"type": "p",
"text": "FlowState seeks to maintain business continuity and operational resilience practices designed to support continued availability of key business functions during disruptions. Business continuity planning may address system outages, vendor failures, personnel unavailability, severe weather, cyber incidents, office disruptions, financial partner disruptions, telecommunications failures, and other operational events."
},
{
"type": "p",
"text": "Business continuity practices may include identification of critical systems and vendors, backup communication methods, remote work capabilities, escalation procedures, data backup strategies, recovery priorities, customer communication procedures, and periodic review of operational dependencies."
},
{
"type": "heading",
"level": 2,
"text": "8.2 Backup, Recovery, and Availability"
},
{
"type": "p",
"text": "FlowState may use cloud-based systems, secure backups, vendor recovery tools, redundant infrastructure, or other measures to support resilience and recovery. Recovery capabilities may vary by system, vendor, data type, product, and operational dependency."
},
{
"type": "p",
"text": "FlowState does not guarantee uninterrupted access to the website, platform, services, banking partner systems, payment networks, data providers, or third-party integrations. Availability may be affected by maintenance, outages, cyber incidents, vendor failures, regulatory requirements, force majeure events, or other conditions outside FlowState's control."
},
{
"type": "heading",
"level": 2,
"text": "8.3 Partner and Vendor Dependencies"
},
{
"type": "p",
"text": "Certain FlowState services may depend on the availability and performance of banking partners, financial institutions, payment processors, identity verification providers, cloud providers, software vendors, and other third parties. FlowState seeks to understand and manage these dependencies but cannot guarantee third-party availability, processing times, account decisions, payment settlement, or system performance."
},
{
"type": "heading",
"level": 1,
"text": "9. DATA HANDLING PRINCIPLES"
},
{
"type": "heading",
"level": 2,
"text": "9.1 Data Minimization and Purpose Limitation"
},
{
"type": "p",
"text": "FlowState seeks to collect and process information that is reasonably necessary for legitimate business purposes, including providing services, operating the platform, onboarding customers, verifying identity, supporting treasury and lending workflows, communicating with users, managing risk, complying with law, maintaining records, improving services, and protecting the security of systems and information."
},
{
"type": "p",
"text": "FlowState seeks not to collect highly sensitive information unless it is necessary for a legitimate business, compliance, underwriting, customer support, partner, regulatory, or security purpose."
},
{
"type": "heading",
"level": 2,
"text": "9.2 Classification and Handling of Sensitive Information"
},
{
"type": "p",
"text": "FlowState may classify or treat certain information as sensitive based on its nature, including identity documents, tax identification numbers, bank account information, beneficial ownership records, financial statements, investment-related records, account applications, loan documents, security credentials, compliance materials, and confidential business information."
},
{
"type": "p",
"text": "Sensitive information may be subject to additional controls, such as restricted access, secure transmission, encryption, audit logging, retention controls, confidentiality obligations, and additional verification before disclosure or processing."
},
{
"type": "heading",
"level": 2,
"text": "9.3 Data Retention and Disposal"
},
{
"type": "p",
"text": "FlowState seeks to retain information for as long as reasonably necessary to provide services, administer customer relationships, comply with legal and regulatory obligations, resolve disputes, enforce agreements, maintain audit records, support accounting and tax requirements, manage risk, detect fraud, and operate its business."
},
{
"type": "p",
"text": "When information is no longer reasonably needed and retention is not required or permitted by law, contract, legal hold, regulatory requirement, or legitimate business purpose, FlowState may delete, de-identify, archive, or dispose of information in accordance with applicable policies and technical capabilities."
},
{
"type": "heading",
"level": 2,
"text": "9.4 Privacy, Security, and Legal Alignment"
},
{
"type": "p",
"text": "FlowState's data handling practices should be read together with FlowState's Privacy Policy and applicable customer agreements. Where specific privacy rights, contractual terms, product agreements, banking partner requirements, or regulatory obligations apply, those terms may supplement or control the handling of particular information."
},
{
"type": "heading",
"level": 1,
"text": "10. CUSTOMER RESPONSIBILITIES"
},
{
"type": "heading",
"level": 2,
"text": "10.1 Customer Security Practices"
},
{
"type": "p",
"text": "Security is a shared responsibility. Customers and authorized users are responsible for maintaining appropriate safeguards for their own systems, devices, personnel, credentials, internal approvals, bank instructions, email accounts, and business processes."
},
{
"type": "ul",
"items": [
"Use strong, unique passwords and enable multi-factor authentication where available.",
"Limit platform access to authorized personnel with a legitimate business need.",
"Promptly remove access for employees, contractors, or representatives who are no longer authorized.",
"Verify bank instructions, wire instructions, payment requests, and changes to account information through trusted channels.",
"Maintain secure email practices and train personnel to recognize phishing and social engineering.",
"Promptly notify FlowState of suspected unauthorized access, credential compromise, fraud, or suspicious activity."
]
},
{
"type": "heading",
"level": 2,
"text": "10.2 Submission of Sensitive Information"
},
{
"type": "p",
"text": "Customers should submit sensitive information only through approved FlowState channels or other secure methods authorized by FlowState. Customers should not send highly sensitive documents, bank credentials, passwords, authentication codes, or confidential information through unsecured channels unless expressly directed and appropriate under the circumstances."
},
{
"type": "p",
"text": "Customers remain responsible for the accuracy, completeness, authority, and lawfulness of information they submit to FlowState, banking partners, partner financial institutions, or third-party providers."
},
{
"type": "heading",
"level": 1,
"text": "11. LIMITATIONS AND NO ABSOLUTE SECURITY GUARANTEE"
},
{
"type": "heading",
"level": 2,
"text": "11.1 No System Is Completely Secure"
},
{
"type": "p",
"text": "Although FlowState seeks to maintain reasonable security and data protection safeguards, no website, platform, system, network, database, communication method, vendor platform, or storage method is completely secure. Unauthorized access, cyberattacks, system failures, data loss, human error, vendor incidents, phishing, malware, business email compromise, and other security events may occur despite reasonable safeguards."
},
{
"type": "p",
"text": "This Statement does not create a guarantee that information, systems, services, accounts, or transactions will be secure, uninterrupted, error-free, or immune from attack, loss, misuse, or unauthorized access."
},
{
"type": "heading",
"level": 2,
"text": "11.2 No Expansion of Contractual Obligations"
},
{
"type": "p",
"text": "This Statement is intended to provide a general overview of FlowState's security and data protection approach. It does not create contractual commitments, warranties, service levels, representations, or obligations beyond those expressly stated in applicable written agreements, privacy notices, product terms, or legal requirements."
},
{
"type": "p",
"text": "FlowState may update, modify, replace, suspend, or discontinue any security practice, technology, control, vendor, process, or statement described herein as business needs, technology, law, risk, vendor arrangements, or security threats evolve."
},
{
"type": "heading",
"level": 1,
"text": "12. CONTACT INFORMATION"
},
{
"type": "p",
"text": "Questions regarding this Security & Data Protection Statement may be directed to:"
},
{
"type": "p",
"text": "Flow State Capital LLC\nAttn: Privacy / Legal Department\n383 W Lakeview Rd\nLindon UT 84042\nadmin@flowstatecapital.ai\nflowstatecapital.ai"
}
]
};
|