OVERVIEW AND POLICY STATEMENT
It is the policy of Flexia Payments, LLC (“Flexia” or “the Company”) to safeguard consumer data. While Flexia’s business activity does not fall within the scope of the Gramm-Leach-Bliley Act (“GLBA”), the Company is committed to maintaining the privacy and confidentiality of consumer personal information in accordance with applicable state laws and regulations, including the California Consumer Protection Act (“CCPA”), and that is consistent with industry standards and best practices.
Both Flexia’s Privacy Notice and California Consumer Privacy Statement are publicly available on the Company’s website, mobile app, and other online properties.
Flexia will maintain all documentation related to its Privacy Notice and California Consumer Privacy Statement for a period of 5 years, including all policies, procedures, and communications.
The Compliance Officer, or qualified designee, is responsible for the administration, revision, interpretation, and application of Flexia’s Privacy Notice and California Consumer Privacy Statement. These notices will be reviewed at least annually and/or revised as required.
V1.0 January 2022
Effective Date: January 25, 2022
OUR COMMITMENT TO PRIVACY
This website is developed and maintained by Flexia Inc. (hereinafter “Flexia,” “we,” or “us”). The data controller is Flexia and can be contacted as explained below in the How to Contact Us section.
- Flexia Customers – When you sign up for an account with Flexia, we may collect and use your personal information on behalf of our issuing bank (Flexia’s “Bank Partner”) to facilitate the provision of banking services pursuant to the MVB Privacy Notice as
applicable. Federal law requires our Bank Partner to provide notice to certain consumers to explain what personal information they collect, how they share it, and how consumers may limit our Bank Partner’s sharing of the information. The privacy practices of our Bank Partner are subject to their privacy notice, which we strongly suggest you review. Flexia is not responsible for our Bank Partner’s information practices or privacy notices.
- Notice to California Residents – If you are a resident of California, please see our California Consumer Privacy Statement.
INFORMATION WE COLLECT
INFORMATION YOU PROVIDE TO US
Flexia collects information about you when you interact with our Sites and Services. When you use our Sites and Services, we collect information about one or more devices associated with you that you use to access the Sites, such as a computer, mobile phone, or tablet. We collect, store, and use information you provide to us from one or more devices associated with you when you use our Sites, including when you log into the Sites or Services from one or more of your devices, register for an account, complete a web form, add or update your account information, apply for a job at Flexia, or otherwise correspond with us regarding the Sites. Information that we collect may include:
- Identifiers such as name, email address, phone number, date of birth, physical address, and country of residence, when you create an account to log in to our Platform;
- Login credentials, including username and password, for your Flexia Account;
- When you request Services on our Sites, open an Account, conduct a transaction, or use our Sites for any reason, we may collect information you provide, including as necessary to complete the transaction, including your name, legal address, last four digits of your SSN, and credit or debit card billing information;
- Biometric information (such as a facial image collected for identity verification);
- Social media handles;
- Voice recordings (such as when you call Flexia’s Customer Service);
- If you use our Application on your mobile device, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device, device information, default device language, the location of your device, and app usage information;
- Information you provide through customer service interactions and that you provide about your experience with Flexia, including responses to surveys offered by the Company;
- If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply;
- If you tell us where you are by allowing your mobile device to send us your location (geolocation data), we may store and use that information for fraud prevention purposes.
- Your subscriptions to our newsletters;
- In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you. If requested for compliance reasons, providing this information is mandatory to use our Service:
- Valid government issued identification such as a passport or driver’s license;
- Other identification documents as deemed appropriate;
- Tax-related information such as a tax identification number (“TIN”) or social security number (“SSN”); and/or
- Any other information as may be required to verify your identity in accordance with applicable laws and regulations;
- We may also collect information at other points in our Sites and Services where it is clear we are collecting such information; and/or
- Other information you choose to provide, such as through our “Contact Us” feature, emails or other communications (such as with customer service), referrals, on social media pages, or in registrations and sign-up forms.
INFORMATION COLLECTED VIA TECHNOLOGY
Information We Automatically Collect
We automatically collect information about the devices you use to interact with our Sites. We automatically collect your device identifier, web browser type and version, IP address, precise geolocation, and browsing information collected through cookies and beacons. We also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal information you have provided.
We collect certain information by automated means when you visit our Sites, such as how many users visited our Sites and the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors. We collect this information through various means such as “cookies” and “web beacons.”
in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website.
Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of the features and functionality of the Sites.
Certain pages on our website contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information, such as the IP address of the computer that downloaded the page on which the beacon appears; the URL of the page on which the beacon appears; the time the page containing the beacon was viewed; the type of browser used to view the page; and the information in cookies set by the third party.
An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our website, we view the IP address of the device you use to connect to the Internet. We then use this information to determine the general physical location of the device and understand the general locations of our website visitors. We also use this information to enhance our Sites.
Collection of Data in Connection with Advertising
We may also collect non-personal information from your mobile device if you have downloaded our mobile app. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the mobile app, and information about the type of device you use. In addition, in the event our mobile app crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, that allows us to identify and fix bugs and otherwise improve the performance of our mobile app.
If you have enabled location services on your phone, tablet, or other mobile device, we may collect your location information including for the purpose of verifying whether you are eligible to participate in a channel, service, or promotion.
Information Collected from Other Sources
We may also collect information about you from third parties, such as marketing partners, identity verification services, anti-fraud services, and other service providers. We may also supplement the information we have about you with information received from other sources such as commercially available sources (e.g., data brokers and public databases). The information we receive may include demographic data such as age, gender, and income level, your interests and purchase data and other information that is necessary or useful to assist our marketing efforts or for user verification, authentication, fraud detection or to comply with regulatory requirements.
HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU
We may use your information for the following purposes:
TO COMMUNICATE WITH YOU
- To provide you with customer support;
- To communicate with you about our products and services, including promotions and offers; or
- To send you further notices, financial news notifications, promotions, solicitations, brochures, or other marketing materials regarding our Sites, our products, and the services of our businesses, affiliates, business partners or authorized dealers.
TO MANAGE AND IMPROVE OUR BUSINESS OPERATIONS
- To tailor specific promotions according to your preferences;
- To provide you with access to the Services;
- To serve the functions of the Sites;
- To manage everyday business needs, such as administering and improving the Sites;
- To analyze the performance and functioning of the Sites;
- To analyze how you use the Sites and to perform other market research;
- For internal operations, including troubleshooting, testing, and analytics; and
- To assist us in developing new products and improving our Services.
TO ENSURE A SECURE ONLINE ENVIRONMENT AND COMPLY WITH LEGAL OBLIGATIONS
- Protect against and detect fraud, abuse, or other unlawful activity;
- Enforce our Terms and Conditions, other corporate policies, and industry standards; and
- Comply with all applicable laws and reporting obligations.
WE MAY SHARE YOUR INFORMATION WITH THIRD PARTIES
- To help us operate our business and the Sites or administer activities on our behalf, such as sending out newsletters or surveys for those limited purposes provided that you have given us your permission;
- To verify your eligibility for a credit card or other services; and
- To provide you with offers and marketing that may be of interest to you.
If you notify us that you do not wish to be contacted for marketing purposes, we will not send you marketing information.
THIRD-PARTY ANALYTICS SERVICES
DO NOT TRACK
Our Sites do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.
BUSINESS STRUCTURE CHANGES
We reserve the right to disclose and transfer all information related to our Sites, including personal data:
- To a subsequent owner, co-owner, or operator of one or more of the Sites; or
- In connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our ownership interests and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.
INFORMATION WE SHARE
We share your information with third-party service providers who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services or communicating with you. These third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. These third parties have no independent rights to the data.
In addition, we will disclose information about you:
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials, as necessary;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or suspected or actual illegal activity;
- If necessary to protect the vital interests of a person;
- To enforce our Terms and Conditions;
- To protect our property, services, and legal rights;
- To prevent fraud against Flexia, our affiliates, business partners, or authorized dealers;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
In certain situations, Flexia may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Flexia does not retain your username or password for social networking platforms for any longer than is necessary to complete an interaction. If you would like to disconnect a social media account from Flexia, please refer to the settings of that social media account and its provider.
LINKS TO OTHER WEBSITES
Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from our Sites. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of this website, we are not responsible for their content, any use of the websites, or the privacy practices of any of those websites.
HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information, and other data stored on our Sites. Sensitive and private data exchange between the Sites and its Users happens over a Secure Socket Layers (SSL) secured communication channel and is encrypted and protected with digital signatures.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical, and physical safeguards to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using the Sites.
RETENTION OF INFORMATION
Flexia retains all personal information for the duration of the relevant business relationship or, where required, in accordance with its information management policies and schedules, subject to applicable laws. When deleting personal information based on a request from the individual
to whom the information relates, Flexia will make reasonable attempts to ensure that all instances of the information are deleted in their entirety.
HOW TO CONTACT US
If you would like to update your contact information or preferences, have your information removed from our mailing lists, or no longer receive marketing e-mails that we may send based on information collected via product registration cards or other sources, you may do so by:
- Adjusting the settings in an account you created through the Sites; or
- Unsubscribing via the links contained in emails from us.
CALIFORNIA CONSUMER PRIVACY STATEMENT
Last Updated: January 25, 2022
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION
We may collect the following categories of personal information about you:
- Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information.
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status.
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
- Biometric Information
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements.
- Geolocation Data
- Sensory Information: audio, electronic, visual, and similar information.
- Employment Information: professional or employment-related information.
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
SALE OF PERSONAL INFORMATION
We do not sell personal information.
CALIFORNIA CONSUMER PRIVACY RIGHTS
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and, (2) the identity of those third parties.
How to Submit a Request
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your Flexia account, one or more recent transactions, and the last four digits of one or more Flexia- branded cards associated with your account. If you have never had an account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that Flexia does not maintain information about non-accountholders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.