Flexe Privacy Policy has been modified and published: 08.09.2021
Please read this document carefully to understand our position and policy regarding your Personal Data and how we will use it.
Flexe thanks you for your interest in the Services we provide. The protection of your Personal Data is very important to us, therefore we pay special attention to the protection of data that are collected and processed when providing Services specified on the Flexe Website.
This Flexe Privacy Policy (hereinafter referred to as the “Privacy Policy”) describes our policy regarding the privacy of Personal Data for the online Flexe Platform.
References to the words “we”, “our” or “us” (or similar words within the meaning) mean the Flexe Platform.
References to the words “you”, “you” or “your” (or similar words within the meaning) mean our User. That is, an individual whose Personal Data we collect, use and process.
The Privacy Policy describes the types of Personal Data that we collect, store and process on the Platform server.
The Privacy Policy applies only to Personal Data, which is collected by the Platform.
When collecting, processing, storing Personal Data, Flexe makes every effort to adhere to the rules and requirements of the General Data Protection Regulation (Regulation (EU) 2016/679 of April 27, 2016), known as the “GDPR”.
We are grateful to you for using the Flexe Platform.
Definitions
Controller – means a natural or legal person, public authority, agency or other body that independently or jointly with others determines the purposes and means of processing Personal Data.
Cookie – means files that store information about your previous actions on the Platform. For example: date and time of site visit, clicks and transitions.
Cryptocurrency – is a type of digital currency, the issue and accounting of which is based on asymmetric encryption and the use of various cryptographic protection methods, such as Proof-of-work and/or Proof-of-stake.
Flexe Platform (hereinafter referred to as the Platform or Flexe) – is a marketing service for promoting and advertising products on the Cryptocurrency market.
Flexe Website (hereinafter referred to as Website) – means a web page or a group of web pages on the Internet through which the User receives the Services and uses the Services of the Flexe Platform, which are posted on the Internet at the following address: https://flexe.io/.
GDPR (General Data Protection Regulation) – means a regulation within the framework of European Union legislation on the protection of personal data of all natural persons who are citizens of the European Union.
Listing – the process of placing a Cryptocurrency on an exchange to start trading with other assets.
Messenger – means an instant messaging system for communication between the User and the Platform.
Partner – means a legal entity (crypto exchange) through which the Platform provides Listing.
Personal Data – means any information related to the User that is processed, stored, protected and transmitted in accordance with the GDPR.
Processor – means a natural or legal person, public authority, institution or other body that processes Personal Data on behalf of the Controller.
Services – it is analytical work using advertising platforms, buying traffic, SEO promotion, using analytics systems and advertising models, social networks, Cryptocurrency media and forums, providing listing using partner’s services, video marketing, developing White Paper documentation, working for White Label concept.
Third party – means a natural or legal person, public authority, institution or body other than the User, Controller, Processor and persons who are authorized by the Controller or Processor under their direct supervision to process Personal Data.
User – means a natural or legal person who receives the Services and Personal Data, whom we process.
User’s Consent (hereinafter referred to as Consent) – means a voluntary, specific, informed and unambiguous expression of will, in which the User, by means of a statement or a clear affirmative action, consents to the processing of his Personal Data.
General Provision
We process and keep records of Personal Data based on the principles of legality, fairness and transparency, in accordance with Article 5 “Principles relating to processing of personal data” GDPR.
The information we receive when you use Flexe Website is stored by us, and we act as the information Сontroller.
The Privacy Policy applies to Personal Data that the Platform User provides in different ways.
The Privacy Policy describes the rules for the processing, presentation, storage and protection of Personal Data obtained when using the Platform and providing Services .
Flexe is not responsible for the actions of other companies that are not owned or controlled by the Platform.
Personal Data
We distinguish the following categories of Personal Data:
- Sensitive data – means information, unauthorized disclosure, modification or concealment of which may lead to tangible loss or material damage. For example: race, religious and political beliefs, income information, gender – anything that, if disclosed, could violate privacy and cause moral harm to an individual;
- Statistical data – means information that rarely changes over time or is not subject to change. For example: phone number, email, IP, passport data, Cookie;
- Biometric data – means unique biological and physiological characteristics that allow you to identify a person. For example: fingerprint, face, voice, iris, palm and finger veins.
When providing the Services, we can collect the following types of User’s Personal Data:
- name and surname;
- IP;
- residence address and citizenship;
- gender;
- passport data;
- data about User’s company;
- tax residency;
- phone number and email address;
- bank details, including account numbers and payment details;
- sources and amounts of income;
- information on the status of your accounts opened with banks and / or payment services;
- location information;
- website data.
Users voluntarily provide us with Personal Data using the Platform Services, consulting with support staff, sending us email messages, or cooperating with us in any other way.
During your interaction with the Platform, we automatically receive and record Personal Data about your actions. For example: the history of the pages viewed, the time and date of the visit, the browser used.
The collection of Personal Data may be carried out using log files, Cookies and other tracking technologies.
The Platform may receive/transmit Personal Data using Messengers.The platform communicates with the User using the following messengers: Telegram, WhatsApp, Facebook.
When processing Personal Data using Messengers, the Platform is guided by the privacy policy of the respective Messenger.
You can familiarize yourself with the privacy policies of messengers in more detail using the internal link:Telegram, WhatsApp, Facebook.
Flexe is not responsible for the security of Personal Data while using instant messengers.
Flexe does not collect or process sensitive Personal Data of Users, such as race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, information about health, sex life or sexual orientation.
The Platform may receive/transmit Personal data using additional services. You may familiarize yourself with such services on the Platform’s Website page: Services.
Every time you visit our Website, we may collect about you (including automatically), for example, the following information:
technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, the type and version of your browser, time zone settings, types and versions of the browser plug-in, operating system;
data about your visit to the Website, including full information about the unified resource locator (URL), the route of transitions to the Website and when switching to/leaving the Website (including date and time), page response time, data loading errors, duration of stay on certain pages, activity on the page (information such as scrolling and mouse movements, clicks), the methods used to exit the page, and the phone numbers that were used to contact the customer support center;
geolocation information, we may collect real-time location information from your device at any time when downloading or using our Services; we may use this information to optimize our Services.
The Platform can receive/transmit your Personal Data during cooperation with Partners, for the provision of Listing, cooperation in the White Label concept.
Personal Data Of Minors
The Platform is not intended for persons under the age of eighteen.
We do not knowingly collect or process Personal Data from individuals under the age of eighteen using the Platform. If you are under the age of eighteen, do not use the Services of the Platform.
In the event that we become aware of the use of the Platform by such a person, we will delete the collected information about him. If you have information that such a fact took place, please contact the support service by sending an email to: [email protected].
Purposes Of Using Personal Data
We will use your Personal Data for the following purposes:
- provision of services;
- for transferring to Partners for the purpose of Listing;
- for communication using Messengers;
- video creation;
- writing marketing materials “White Paper”;
- to fulfill the obligations stipulated by any agreements concluded with you, as well as to provide you with the information you requested;
- to ensure the security of our Website, as well as your account;
- to administer our Website and conduct internal operations, including troubleshooting, data analysis, testing, statistics collection and for conducting surveys;
- to provide support, respond and resolve your complaints and the capabilities of our Website;
- to improve our Website and to make sure that our content is as convenient as possible for your computer’s operating system;
- to evaluate and understand the effectiveness of advertising materials that we provide to you and other Users, as well as to provide you with the advertising information you need;
- to ensure the most efficient presentation of the content of our Site and its use from your computer;
- for internal business and research purposes, such as communicating with you;
- to respond to inquiries from law enforcement agencies;
- to initiate and respond to legal claims;
- to investigate or resolve disputes with you;
- to verify and verify the identity of the User;
- to notify our Users, for example, in the event of a change in the policies and rules of our Platform.
Third Party Access
We have the right to disclose Personal Data in the following cases:
Third parties. The Owner has the right to sell, disclose or transfer information about Users as part of a corporate business transaction such as an acquisition or merger, financing, corporate reorganization, joint venture, including the sale of company assets, or in the event of bankruptcy or insolvency, in which such the information may be disclosed to any third parties as a business asset in a transaction. For example, in the event of a merger of the Platform with another similar service, your Personal Data may be transferred to such a service. The Owner has the right to disclose your Personal Data if he believes that this is necessary to protect his legal rights and interests. For example: in the case of protecting your rights in court, in disputes with third parties.
User’s Consent. With the written or online consent of the User, the Owner may disclose personal information to third parties. For example: e-mail from the User, check-box confirmation.
Partners. The Owner has the right to transfer Personal Data to Partners for Listing or work on the concept White Label.
All Third parties with whom the Owner exchanges Personal Data are obliged to use the Personal Data of Users in accordance with the General Data Protection Regulation.
User Rights
The right to access. The Privacy Policy lists the User Personal Data. The User may contact us directly to request access to the Personal Data that we hold about him, as well as to any information in accordance with Art. 15 GDPR.
The right to be forgotten. The User has the right to delete Personal Data about himself, in accordance with Art. 17 GDPR. Personal data and, in this case, will be deleted forever.
Right to rectification. The User has access to Personal Data, which must be updated, corrected, supplemented at any time. The user may also contact the support of the Platform in order to access his Personal Data in order to correct, change or delete it, in accordance with Art. 16 GDPR.
Portability. We may transfer the User Personal Data to third-party organizations, at any time and at the request of the User, in accordance with Art. 20 GDPR.
Right to object. The User has the right at any time to object to the processing of his personal data, in accordance with Art. 21 GDPR.
The right not to be subject to automated decision making in individual cases, including profiling. The User has the right not to be subjected to a decision that is based solely on automated processing, including profiling, which causes its legal consequences or is similar to it, according to Art. 22 GDPR.
If the User believes that during the processing of Personal Data his rights have been violated or he is concerned about the methods and methods of processing Personal Data by Flexe, then he has the right to file a complaint with the data protection supervisory authority.
The User, depending on the circumstances, submits a complaint to the supervisory authority at the place of his registration, location, employment or to the supervisory authority of the country in which he is a resident.
To familiarize yourself with the supervisory authorities, use the list provided.
Storage Of Personal Data
We apply security measures to ensure the confidentiality of the Personal Data of the User and to protect it from loss, misuse, alteration or destruction. Only authorized personnel Flexe has access to the Personal Data of the User, and these employees are required to treat the Personal Data of the User as confidential. The existing security measures will be reviewed from time to time in accordance with new legislation and technical innovations.
The Personal Data we collect from you may be transferred and stored outside the European Economic Area (“EEA”) for the purpose of providing you with our Services.
Your Personal Data may be processed by our employees or employees of service provider companies located outside the EEA. When storing or otherwise processing your Personal Data by such Third Parties outside the EEA, we guarantee that we will notify such Third Parties of our obligations under this Privacy Policy and enter into a relationship with them, provided that they will be obliged to act with respect to your Personal Data at least as strictly than this Privacy Policy obliges us. These employees may, among other things, process your requests, billing information and provide technical support.
By providing us with your Personal Data, you consent to the transfer, storage and processing of Personal Data. In turn, we will take all necessary measures to ensure that your Personal Data is processed in compliance with the security rules and in accordance with the provisions of this Privacy Policy.
Personal Data stored on the server of the Platform is considered the property of the User.
We have the right to use and disclose the Personal Data only for the purposes specified in the Privacy Policy.
In the event of a change in Personal Data, the User is responsible for notifying the Platform of such changes. For example: The User has changed the Personal Data (account number, bank details), information that is necessary for the correct provision of the Services and did not notify the Platform support service about this fact. In the event of such failure to notify, Flexe will not be liable to the User for the quality of the Services provided.
At the request of the User, we provide information about the fact of the processing of Personal Data by a Third party.
The Personal Data of the User is stored on the Platform Website until it is deleted.
By deletion of Personal Data, we mean the deletion of all Personal Data from the Servers and/or from written media.
Flexe deletes Personal Data in the following cases:
upon receipt of a request for deletion;
the end of the relationship with the User, except for the cases specified in clause 8.12. this Policy;
expiration of the storage period provided for in clause 8.12. this Policy;
expiration of the validity period for the storage of Personal Data.
Flexe has the right to store the Personal and statistical data of Users for 5 (five) years after the end of the relationship, in the following cases:
- for maintaining statistical records;
- for accounting;
for maintaining personnel records; - if applicable law requires their storage;
- if they are necessary for doing business.
Flexe does not store the User’s Personal Data in the event of a request for deletion on his behalf, in accordance with the right to delete, as provided for in Art. 17 “Right to erasure” GDPR.
The process of deleting Personal Data is performed by a Flexe employee.
Flexe has the right not to delete Personal Data in the event of a company reorganization, Flexe merger with another company, or any other change in the Flexe structure.
Flexe does not delete Personal Data in the event of a server change.
Protection Of Personal Data
We take all reasonable and appropriate measures to protect Personal Data from loss, misuse and unauthorized access and disclosure, modification and deletion, taking into account the risks associated with the processing and the specifics of Personal Data.
Although laws to protect the rights and privacy of Personal Data may differ from those in your country, we do our best to provide adequate measures to protect your Personal Data.
We may use the following methods to protect Personal Data, in accordance with Article “Security of processing” 32 GDPR:
pseudo-anonymization and encryption of Personal Data;
the ability to ensure the continued confidentiality, integrity, availability and resilience of processing systems and services;
regular testing, assessment and measurement of the effectiveness of technical and organizational measures to ensure the security of the processing of Personal Data.
Flexe makes every effort to ensure that any activity related to Personal Data is in full compliance with the provisions of the General Data Protection Regulation.
Basis For Processing Personal Data
We collect and process your Personal Data only when we have a legal basis for such processing.
Legal bases include:
- consent (where you give it);
- contract (where processing is necessary to fulfill the terms of agreements between you and Flexe);
- fulfillment of obligations required by law (in cases where Flexe is obliged to request/receive and process and store your Personal Data in order to comply with the requirements of applicable law, for example, legislation related to legalization (laundering) of proceeds from crime and financing of terrorism, in accordance with a legitimate interest ( for example, in cases where processing is necessary to protect you or us from certain threats: fraud, security threats, etc.);
- to comply with the provisions of applicable law, for the proper level of conduct of our business, the conclusion and execution of corporate transactions (sale of shares / shares, mergers, acquisitions).
In cases where the basis for the processing of Personal Data is your consent, you have the right to withdraw it at any time.
Disclaimers
The Flexe Platform notifies the User that his Personal Data may be used to provide services, and in case of disagreement, the User must leave the Website.
The Flexe Platform has the right to collect Personal Data from Users in order to obtain statistical data.
Unfortunately, the transmission of information via the Internet may not be completely secure. Although we make every effort to protect your Personal Data, we may not guarantee a secure process for transferring your Personal Data to our Website. In this regard, you are solely responsible for possible failures in the transfer of your Personal Data to the Website. Upon receipt of your Personal Data, we undertake to follow strict procedures and all necessary technical and security measures to prevent unauthorized access to your Personal Data.
Amendments To The Privacy Policy
We have the right to periodically make changes to the Privacy Policy to ensure the safety of Personal Data and compliance with legal requirements.
We notify the User of such changes by posting news on the Website, sending an e-mail newsletter, or using other means.
In the event that the User has unsubscribed from emails in which we inform about all changes in the legal documentation, the User is still responsible for familiarizing with them.
Flexe, after making changes to the Privacy Policy, has the right to request the User’s repeated consent with the Privacy Policy, if the User has refused the information e-mail newsletter.
Our electronic or otherwise stored copies of the Privacy Policy are deemed to be genuine, complete, valid and enforceable versions of this Privacy Policy in effect at the time of your visit to the Platform.
Contacts
If you would like to ask questions, provide feedback, update the Personal Data stored on the Flexe Platform, or are concerned about privacy issues, please contact support at: hello@flexe.io.