Privacy Policy

Last updated: December 24, 2023

  • Flexify is dedicated to providing you with the highest level of transparency and control over the use of your data. In order for us to provide you with our services we are required to collect, process and protect certain personal information about you and your activity.

    By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information. We encourage you to review the following information carefully.

    We value your trust and are committed to ensure proper protection of your personal data. We respect your privacy and pledge to process and protect your personal data in a fair and lawful way in accordance with the applicable legal requirements of the European Union (General Data Protection Regulation 2016/679) (hereinafter referred to as the “GDPR”).

    This Privacy policy explains how we collect and process the personal data about people who use our payment initiation and account information services. This Privacy policy provides information about the scope of processing personal data, the purposes, sources, recipients, and other important aspects of personal data processing.

    In this Privacy policy, we describe what personal data we collect and process about people who use our payment services, clients, visitors of this website, people that consented to receive direct marketing messages.

    We may process your personal data for purposes other than those described in this Privacy policy. If this is the case, we will provide you with a separate privacy statement informing you about such processing.

    Please note that additional information might be provided in applicable terms and conditions, contracts, and other documents provided by us.

    We may change this Privacy policy at any time at our sole discretion, therefore, you have a responsibility to make sure that you are familiar with the latest version of the Privacy policy.

  • Personal data

    Processing of your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you, for providing you with our services and the operation of our website(s) (the “Website” and “Service” respectively), to protect our legitimate interests and for compliance with legal and regulatory obligations. When you use our Service, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Privacy Policy.

  • Personal data processing

    Personal data processing means any operation or set of operations which is performed on personal data or on sets or personal data, whether or not by automated means.

  • How do we receive data about you?

    We receive your Personal Data from various sources:

    01 Registration information – When you voluntarily provide us your personal details in order to create an account or register to our Service (for example, your name, your email address, your telephone number, bank account details and credit card number, date of birth, and your country.);

    02 When you communicate with us – For example when you send us an email or contact us through the “contact us” form on our Website, we collect the Personal Data you provided us with.

    03 Technical information – When operating our Services, we use various technological tracking tools to collect information regarding your use of the Website (for example, this category includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, referral URL, time zone, network connection type, and cookie information).

    04 Third party information – We may receive your data from third party providers who help us with the provision and maintenance of our Services, such as analytics vendors and others.

    05 Social networks ? we will have access to basic information from your social network account, when you choose to connect our Services to your social network account (such as your name, birthdate, profile picture and friends’ list, as well as information you made publicly available on such account).

    06 Non-Personal Data ? we collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it.

  • Prevention of money laundering and terrorist financing

    If necessary to comply with applicable laws and regulations, such as anti-money laundering and anti-terrorist financing laws and regulations, we may verify your information and collect it from publicly available sources, credit reporting agencies or fraud prevention agencies, and check against government sanctions lists directly or through identity verification service providers or due diligence and screening information providers.

    This means that for this purpose we may process personal data of our client's representatives, directors and shareholders and/or other persons.

    The personal data is collected and processed on the basis of a legal obligation imposed on the payment initiation service provider, i.e. us. Your biometric data (image) is processed on the basis of your consent (if the image is processed for identification purposes). If you do not agree to the processing of your biometric data, please contact us (the service provider that provides the Company with the identification platform) to obtain another way to identify your identity.

    We will process personal data for as long as we need to achieve the purpose for which it was collected.

    Personal data will be stored for 3 years after the termination of business relations with the Client.

  • Tracking technologies

    We and our trusted partners use cookies and other technologies in our related services, including when you visit our Website or access our services. A “cookie” is a small piece of information that a Website assign to your device while you are viewing a Website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier.

  • Turning off cookies via your web browser

    Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.

  • How do we use the data we collect?

    Provision of service – for the provision and improvement of our Services, including for support and to respond to your queries.

    Service announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.

    Marketing purposes – we may use your Personal Data (such as your email address or phone number). For example, by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, by building an automated profile based on your Personal Data, for marketing purposes. You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us. Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us.

    Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Service and think of new and exciting features for our users.

    Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud and money laundering, protect the security or integrity of our services.

    Enforcing of policies – we may use your Personal Data in order to enforce our policies, including but not limited to our Terms of Use.

    Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

  • How we protect your information

    We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

    While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.

  • Data processors. data recipients

    Moreover, we can disclose information about you:
    If we must do this under the law (state institutions, law enforcement institutions and other persons in accordance with the applicable procedure;
    In order to protect our rights or interests (including the provision of your data to third parties in order to recover your debts to us);

  • Retention

    We will retain your Personal Data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

  • User rights

    01 Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

    02 Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.

    03 Request rectification of your Personal Data that is in our control.

    04 Request erasure of your Personal Data.

    05 Object to the processing of Personal Data by us.

    06 Request to restrict processing of your Personal Data by us.

    07 Lodge a complaint with a supervisory authority.

  • Privacy policy review

    We may update or amend this Privacy policy at any time. Such an updated or amended Privacy policy will come into effect as of its publication on our website. You should check it from time to time and make sure that you find the current version of the Privacy policy acceptable.

    After making an update to the Privacy policy, we will notify you about any changes that we consider material by publishing them on our website.

  • Client support

    We value your feedback and we want to understand what we can do to improve our services. Therefore, you can contact us in order to receive assistance on your question or concern as well as any time that you are seeking to implement your rights.

    If you contact us, we will process your personal data by collecting your contact details through the source you chose to contact us (via e-mail, post or any other way).

    All personal data will be processed on the basis of your consent which is expressed by your actions by sending us a question, concern or request.

    Your personal data will be stored for 1 year after certain question, concern or request was sent to us. In some individual cases, in accordance with the applicable legal requirements, your personal data might be stored longer.

  • How to contact us?

    If you wish to exercise any of the aforementioned rights, ask us a question or receive more information, please contact us via e-mail: [email protected]