SETROASFLOW — TERMS OF SERVICE
Version: Draft — 25 August 2026
IMPORTANT STATUS
This document is a legal draft prepared from the current SetRoasFlow product brief and user-confirmed operating rules. It is not legal advice and must be reviewed by qualified counsel before publication or use.
1. ABOUT SETROASFLOW
SetRoasFlow is a server-side conversion tracking, customer data infrastructure, CDP, audience activation and analytics service operated by Matteo De Giuseppe, an individual established in Italy. The only public contact address is [email protected].
The Service is currently provided in private beta and without active billing. The Service is currently provided in private beta and without active billing. The Service will move to paid operation only after SetRoasFlow is transitioned to the appropriate company/business structure. Paid plans may then be introduced through a Merchant of Record. The Service is intended for business customers and professionals who have or manage a website; it is not offered as a consumer service. The current private beta is free of charge.
2. ACCEPTANCE
By creating an account, accessing the dashboard, connecting a website or integration, or otherwise using the Service, the Merchant agrees to these Terms.
3. THE SERVICE
The Service may include server-side event collection and forwarding, unified customer profiles, identity resolution, segmentation, audience activation, attribution, acquisition analytics, LTV/cohort/churn analytics, on-site personalization, warehouse exports, AI-assisted features and advertising-spend ingestion from supported accounts.
Available integrations may include JavaScript, WordPress/WooCommerce, Shopify and connected advertising, analytics and CRM platforms. Integrations may be beta features.
4. MERCHANT RESPONSIBILITIES
The Merchant is responsible for:
(a) determining the lawful basis for its processing;
(b) obtaining and maintaining required consent and privacy choices;
(c) configuring consent signals correctly;
(d) providing appropriate privacy notices to visitors and customers;
(e) ensuring that its use of the Service complies with applicable law and third-party platform terms;
(f) ensuring that data supplied to SetRoasFlow is lawful and accurate;
(g) responding to data-subject requests where the Merchant is controller.
The Merchant must not submit special categories of personal data or criminal-offence data to the Service.
SetRoasFlow provides technical compliance-support functionality but does not guarantee that the Merchant's overall processing is legally compliant.
5. PRIVACY AND DATA PROCESSING
For personal data processed on behalf of a Merchant, the Merchant generally acts as controller and SetRoasFlow as processor. The DPA governs that relationship.
SetRoasFlow may also act as an independent controller for its own website, account, security, support, operational and business records. The Privacy Policy governs those activities.
6. CONSENT SIGNALS
The Service supports geo-aware consent handling. For EU/EEA/UK/Swiss traffic, the current architecture requires an affirmative consent signal before identified personal data is processed beyond the edge. For US and other traffic, the architecture supports applicable opt-out signals including Global Privacy Control.
The Merchant remains responsible for its consent mechanism.
7. THIRD-PARTY DESTINATIONS
The Merchant may configure advertising, analytics, CRM and other destinations. SetRoasFlow may transmit data to those destinations as necessary to provide the configured functionality.
A destination's inclusion in the Service does not itself determine whether the destination is a processor, independent controller, joint controller or another recipient. The applicable legal classification depends on the destination's service and relationship with the parties.
8. AI FEATURES
AI features are on-demand and not used for every event. They may process merchant-entered free text, segment rules, truncated platform error text and aggregate statistics.
The Service is designed not to submit end-customer personal data to AI features; merchant-provided free text is forwarded as typed and may contain personal data if the Merchant enters it.
SetRoasFlow does not use Merchant or end-customer data to train AI models. Aggregated, non-personal operational statistics may be used to improve the Service.
9. ADVERTISING ACCOUNT DATA
Where enabled, SetRoasFlow may read aggregated daily spend from a connected Meta advertising account to calculate ROAS. The Merchant authorizes this access and remains responsible for the permissions it grants.
10. DATA ACCESS BY SETROASFLOW
Authorized SetRoasFlow personnel may have technically possible administrative access to production data stores when necessary to operate, maintain, debug or support the Service. Such access is organizationally and contractually restricted and is not performed routinely.
11. DATA RETENTION AND DELETION
CDP profiles remain while the applicable Merchant account/project exists unless the Merchant requests deletion earlier. Event records are retained for a rolling period of 24 months.
Upon project deletion, SetRoasFlow deletes applicable live project data within 24 hours.
Residual copies may remain temporarily in provider disaster-recovery systems and expire automatically according to provider retention mechanisms. Such copies are not accessible through normal operations and are not used for ongoing processing.
Data already transmitted to third-party destinations is outside SetRoasFlow's direct control and remains subject to the applicable destination's policies, retention and deletion mechanisms.
12. PROHIBITED USES
The Merchant may not use the Service for unlawful surveillance, unlawful discrimination, unlawful tracking, special-category data processing, credential abuse, malicious activity, circumvention of platform restrictions or other prohibited uses listed in the Acceptable Use Policy.
13. INTELLECTUAL PROPERTY
The Service, software, documentation and underlying technology remain the property of SetRoasFlow or its licensors. The Merchant retains rights in data it supplies.
14. CUSTOMER REFERENCES
Unless the Merchant opts out, SetRoasFlow may identify the Merchant by name and use its logo in customer lists, on the SetRoasFlow website and in marketing materials.
The Merchant may opt out at any time by emailing [email protected]. An opt-out will apply prospectively and SetRoasFlow will stop new uses within a reasonable period.
15. SECURITY
SetRoasFlow uses technical and organizational safeguards described in its Security Overview. No system can be guaranteed completely secure.
16. BETA SERVICE
The Service is provided as a beta service. Features may change, be suspended or be removed. No uptime, SLA or particular performance level is promised.
17. DISCLAIMER
To the maximum extent permitted by law, the Service is provided on an “as available” basis. SetRoasFlow does not provide legal, tax or regulatory advice.
18. LIMITATION OF LIABILITY
[LAWYER REVIEW REQUIRED: insert commercially appropriate limitation, exclusions, caps and mandatory-law carve-outs.]
19. TERMINATION
Either party may terminate use of the Service subject to these Terms. SetRoasFlow may suspend or terminate access where reasonably necessary for security, unlawful use, material breach or protection of the Service.
20. GOVERNING LAW
The parties intend Italian law to govern these Terms, subject to any mandatory rules that cannot lawfully be excluded or limited.
[LAWYER REVIEW REQUIRED: finalize forum, jurisdiction and mandatory-law treatment.]
21. CHANGES
SetRoasFlow may update these Terms as the Service, business model or legal requirements change. Where required, material changes will be notified through an appropriate channel.