Privacy Policy

Your privacy is important to us. For optimum use of FlexyBank’s services and to get the best of offers, we are required to know each other. Depending on which services you are subscribing to, FlexyBank may request some personal and maybe sensitive information from you. This Privacy Policy (“Policy”) governs the collection, use and disclosure of your Personal Information by FLEXY GROUP (trading as “FlexyBank”). In this Policy, “FlexyBank”, “we”, “us”, or “our” means FLEXY GROUP and any reference to “you” or “yours” refers to you.


1. Your privacy rights

FlexyBank is committed to complying with its obligations under the Privacy Laws of every country or legal jurisdiction where it conducts business when dealing with your Personal Information. Any Personal Information you put at our disposal will be stored, used, and disclosed where necessary by FlexyBank in accordance with these laws.


2. How and what type of information we collect about you

  1. Your Personal Information will be collected and held by FLEXY GROUP.
  2. We collect Personal Information in order to manage, market and conduct our business, to provide our Services, and to meet our legal obligations. Depending upon the nature of your relationship with us, the type of Personal Information we collect, and hold may include:
  3. your name and contact details (including your email address, phone number and postal address).
  4. your payment and purchase history through use of the Services (e.g., merchant name and value of spend).
  5. passport or driver’s license details, including date of birth, to verify your identity for AML compliance purposes.
  6. proof of address, e.g., a utility bill for AML compliance purposes; and
  7. bank account and/or payment card details for the purpose of loading or topping up your flexy wallet (in accordance with your instructions); records of our communications with you, including any complaints, requests, or queries.
  8. any other Personal Information that may be required in order to facilitate your dealings with us and/or to assist us in conducting our business, providing and marketing our Services and meeting our legal obligations; and
  9. information we create in the course of our relationship with you, such as personal preferences and other details or evaluations of your interactions with us and our Services.
  10. for merchants, their business type, business address, company details, and directors and shareholder details (which will include the Personal Information listed above)

3. Who we collect personal information from

  1. We use different methods to collect your Personal Information. We will generally collect Personal Information directly from you (e.g., through information you submit through the Service or through correspondence that you submit to us). However, we may also collect Personal Information:
  2. From third parties and government databases in some instances, for example to verify your identity for AML compliance purposes.
  3. From other third parties that we partner with for marketing and promotional purposes, e.g., event organizers and merchants who use FlexyBank; and/or
  4. From publicly available websites or sources.
  5. If you have provided us with information about another person, you warrant that you have that person’s permission to do so. Your obligations under privacy laws in your country may also warrant that you tell that person about the disclosure and let them know that they have a right to access their Personal Information and that we will handle their Personal Information in accordance with this Policy.
  6. When you access our Services, we may collect information that is sent to us by your device. Generally, this information is not personally identifiable data, but to the extent that it is considered Personal Information for the purposes of the Privacy laws, we will comply with our legal obligations under any such law or regulation when processing that information.
  7. You are not required to provide us with your Personal Information. However, if you choose not to provide Personal Information to us on request, we may be unable to provide certain Services to you or it may affect the functionality of our Services.

4. How we use Personal Information

  1. We collect, hold, use and disclose your Personal Information for the following purposes:
  2. To provide you with our Services.
  3. To send, receive, process, administer, and collect payments from you on behalf of merchants and registered users of the FlexyBank app.
  4. To communicate with you (for example to provide customer support or to ask you for feedback about our Services).
  5. To help provide a more tailored and personalized user experience.
  6. To research and help improve and enhance our Services and to conduct market analysis and perform data analytics on customer behaviors and insights in relation to our Services.
  7. To undertake administrative functions associated with the Services and our business.
  8. To comply with any legal obligations, including our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.
  9. To send you electronic messages and push notifications to promote and market our Services and/or other services we consider you may be interested in, including any promotions and deals available through the FlexyBank App.
  10. You can opt out of receiving marketing material, push notifications and other promotional communications at any time by disabling notifications in the App, notifying us at [email protected] or by clicking the unsubscribe function included in our marketing communications.

5. Who may we disclose your Personal Information to

  1. We may disclose your Personal Information to:
  2. merchants, in order to facilitate payment for the goods or services you purchase from them using our Services.
  3. any third-party service providers that we have engaged to provide a service to us in relation to our Services and/or to carry out functions on our behalf, including those who provide us with IT and marketing servicesiv) financial services dispute resolution providers (where required by law or with your consent).
  4. third party providers of identity verification services to enable us to meet our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
  5. potential investors and/or purchasers of our business.
  6. our professional advisors, including accountants, insurers, and lawyers.
  7. any other person or organization that you have authorized us to disclose your information to; and/or
  8. any other third party where such disclosure is permitted or required under the Privacy Laws of your country and/or any other applicable law.
  9. registered users of the FlexyBank app, to enable them to see your name and phone number in their contacts and transaction information.
  10. If we disclose Personal Information to a third party outside of your country or legal jurisdiction who uses that information for their own purposes, we will ensure that such third party is subject to comparable privacy laws to your country or legal jurisdiction or is required to protect the Personal Information in a way that is comparable to your countries or legal jurisdiction’s privacy laws.

6. Access, Correction, and Retention of your Personal Information

  1. You agree that any information you give to FlexyBank will be accurate, correct and up to date and you will inform Flexy Bank if any of Personal Information changes to ensure that the details we hold about you are up to date and correct. You can update your personal details at any time through your customer account or by contacting us at [email protected]
  2. You are entitled to access the Personal Information we hold about you, and to request that we amend it if it is incorrect. If we are not willing to correct errors that you have identified in your Personal Information, you may request that we take reasonable steps to attach a statement to the Personal Information noting the correction sought.
  3. We will only retain your Personal Information for as long as it is required to achieve the purposes set out in this Policy or as otherwise required by law.

7. Security of Information

  1. FlexyBank take reasonable steps to protect all Personal Information from misuse, loss and unauthorized access, modification, or disclosure.
  2. Although we take reasonable steps to ensure all Personal Information held by FlexyBank (or on its behalf) is protected and held securely, FlexyBank do not make any warranties in relation to the security of any information you disclose or transmit to FlexyBank, and FlexyBank is not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information where her security measures have been breached. Any transmission of Personal Information is conducted at your own risk.

8. Where we hold your Personal Information

We use third party cloud service providers, such as Microsoft Azure, AWS to store data on our behalf. Those providers are global base USA, Europe, Africa, Asia etc.


9. Amendments to the Privacy Policy

FlexyBank may amend and update this Privacy Policy from time to time by posting a revised version on our website or otherwise notifying you through our Services. Any changes will apply from the date we post the updated Privacy Policy on our website or through our Services. If there are any significant changes, FlexyBank will endeavor to provide you with reasonable notice of such changes through our website, or via other means such as email. By accessing or using our Services after such notice period, you will be deemed to have accepted the updates to this Policy. If you do not agree to any change, you must immediately notify us and cease accessing our Services.


10. Cookies

  1. “Cookies” are small files that are placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among its many uses. Like many other websites on the internet, FlexyBank use Cookies and other third-party web tracking and analytic tools to collect and track information about you when you are using our Service for the purposes of:
  2. providing more customized content and material to you through our Services.
  3. improving our Services and your customer experience.
  4. conducting business and marketing analysis; and
  5. If you do not wish to allow Cookies you may change your browser settings to disable Cookies. However, if you disable Cookies some parts of our Services may not function properly.

11. Link to other websites

FlexyBank Services may have links or references to third party websites or material. This Policy does not apply to those websites, and any information collected by such third parties is governed by that third party’s privacy practices or policies. We accept no responsibility or liability for the content or privacy practices of any third-party website or App.


12. How to contact us

If you have any queries or concerns about this Privacy Policy or our handling of your Personal Information please contact our officer at FLEXY GROUP, 410 Avenue LaFleur, Suite 54, Montreal (Quebec) H8R 3H6 or by emailing us at [email protected].

Last updated: March 2022.