Effective Date: 1 March, 2018
Flexpat, B.V., its subsidiaries and affiliates (collectively, “we”, “us”, “our” or “Flexpat”) respect the privacy of our customers and partners and we are committed to informing you about how we collect, use, and share Personal Information
INFORMATION PROCESSED BY FLEXPAT
who is identified in that data or who is, together with other data, identifiable; and (ii) “Other Information” is any additional information that Flexpat collects about our users that is not Personal Information.
- Personal Information we collect: we may combine Personal Information collected through the Flexpat Platform with Other Information that we or third parties collect about you in other contexts—such as our communications with you via email, phone
- Other Information we collect: each time you use the Flexpat Platform, we may, in some cases automatically, collect the following information:
- Through your device: we may collect information from or through the device you use to connect to the Flexpat Platform, including, for example, the type of device, the IP address, the approximate location derived from an IP address, the mobile
network, the operating system and version, the browser and version or the time zone setting or unique device identifiers.
- Log information: we automatically receive and record certain details about your use of the Flexpat Platform, including but not limited to, web traffic data, web logs and communication data, information about your activity on the Flexpat Platform.
- Other information from other sources: we work with third parties (including, for example, providers in technical, payment services, advertising networks, analytics providers and search information providers), and we may receive, collect, store,
and use information about you from them. We may partner with certain third parties to collect the Other Information and to engage in analysis, auditing, research and reporting or for use in providing online interest-based advertising on our behalf.
These third parties may use web logs or web beacons, and they may set and access cookies or similar technologies on your device. They may also use information about your use of the Flexpat Platform to help target non-Flexpat advertisements based on
your online activity in general. Additionally our website is hosted on the Google Cloud Platform (GCP) and uses GCP Cloud CDN and AWS CloudFront. We are using Cloud storage (object storage) to store all our data, which is encrypted.
- Information from email communications: we may communicate with you via email, SMS, MMS or other text message (collectively, “Text Message”) or push notifications (to the extent you permit us to do so), and we may collect information regarding
such communications, such as confirmation when you open an email. We use this information to improve the Services, including without limitation our customer service.
- Financial information: financial information, such as your payment method, valid credit card number, type, expiration date or other financial information, is collected and stored by our third party payment processing company (the “Payment
- Aggregate information: we collect statistical information about how both unregistered and registered users, collectively, use the Flexpat Platform (“Aggregate Information”). Some of this information is derived from Personal Information. This
statistical information is not Personal Information and cannot be tied back to you, or your web browser.
USE OF PERSONAL INFORMATION
Flexpat may use the information that we collect from you:
- To provide services to you: we use Personal Information to provide our services to you through the Flexpat Platform, Flexpat trips and events, to process and complete payments or transactions and to provide customer support. We may use the
information we collect from you in the following ways: to personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested; to improve our website in order to better serve you; to
allow us to better service you in responding to your customer service requests; to administer a contest, promotion, survey or other site feature; to quickly process your transactions; to send periodic emails regarding your order or other products and
services; to follow up with them after correspondence (live chat, email or phone inquiries). We also may use Personal Information to improve the Flexpat Platform and to improve Flexpat trips.
- To contact you: subject to applicable law, we or our third-party service and business providers may send you communications. Such communications are designed to make your Flexpat experience more efficient and may include, but are not limited to:
notifications about the Flexpat Platform and services (including important news that could affect your relationship with us), communications about our services, promotions and our mobile application features. These types of communications may also
contain commercial messages, such as banner ads and special offers. By using the Flexpat Platform, you consent to the receipt of such communications and marketing information.
- For legal purposes: we may use and share Personal Information for legal purposes, including as described below in the section titled “How We Share Information with Third Parties” (including the transfer of such Personal Information to third
parties in countries outside your country of residence where data protection laws may be less adequate compared to your own country’s data protection laws).
- For our business purposes: we may use Other Information to help us efficiently operate Flexpat and the Flexpat Platform, to count and recognise visitors to the Flexpat Platform, to enable certain features on the Flexpat Platform and for other
purposes related to managing our business.
- For other purposes: subject to applicable law, we may use Other Information for additional purposes in connection with the Flexpat Platform, including any purpose for which we may use Personal Information, as described above.
- Flexpat may link Other Information with Personal Information. In those circumstances, we will treat the combined information as Personal Information.
The information that we collect from you may be transferred to, and stored at, a destination (a “third country”) outside the country or region in which you are resident or use the Flexpat Platform, including in the United States of America where
data protection laws are not deemed to be as adequate as other regions (e.g. Europe). The data protection laws in these third country countries may be less adequate compared to your country of residence. By using the Flexpat Platform, you agree to
this transfer, storing or processing of your laws in such third countries.
We are using GCP europe-west3 and europe-west4 regions, which means that the data is under German and/or Dutch law.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users:
using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
ACCESSING AND EDITING YOUR INFORMATION
Flexpat provides you with the ability to view, update, access, edit and correct your Personal Information by contacting a member of our onboarding team. Personal Information transmitted through boards, chats, polls or any other means may remain in
our databases, except to the extent prohibited under applicable law. You may have additional rights under applicable law to access information we hold or share about you but any access request may be subject to a reasonable fee, to the extent
permissible under applicable law, to meet our costs in providing you with details of such information.
SHARING INFORMATION WITH THIRD PARTIES
Subject to applicable law, we may share your Personal Information and Other Information:
- With partners and other third-party service providers: to operate Flexpat trips and the Flexpat Platform, including processing your transactions and supporting your activities on a Flexpat trip or the Flexpat Platform, we may share your Personal
Information with our partners and other service providers. These service providers may provide us with support services such as origination of communications, receipt or support services, customer relationship management services and order
disclosure of such Personal Information.
- With third-parties through their websites: the Flexpat Platform may enable you to share information directly on or through websites or online services operated by third parties. For example, the Flexpat Platform may contain links to third-party
websites. If you choose to browse such websites, you may disclose your Personal Information to those third-party websites. Flexpat is not liable for the content or action of such third-party websites.
- For legal purposes: we may disclose your Personal Information and Other Information for Flexpat’s legitimate business interests or to comply with applicable law, investigate, prevent, or take action regarding illegal activities, suspected fraud,
violations of our terms and conditions, or to cooperate with regulatory authorities or law enforcement, to establish, exercise or defend our legal rights or defend against legal claims.
- Aggregated information: From time to time, Flexpat may also share anonymized and aggregated information about users of the Flexpat Platform, such as by publishing a report or providing information to our business partners on trends in the usage
of the Flexpat Platform and demographic of users.
You may, under applicable law, have the right to ask us not to process your Personal Information for marketing purposes. If you do not wish to receive marketing communications from Flexpat, please follow the opt-out instructions contained in each
such communication or any time by contacting us at firstname.lastname@example.org. Please note that you may not be able to opt-out of certain non-marketing communications about your account or communications that are reasonably necessary to provide services to
you, and that opting-out of receiving text messages or other communications, as applicable, may impact your use of the Flexpat Platform or may limit Flexpat’s ability to provide services to you.
Please note that it may take up to 30 days for your withdrawal to be reflected in our systems following confirmation of your request to opt-out. Therefore, you may still receive certain communications during this period.
OUR SECURITY PRECAUTIONS
Flexpat uses commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information against loss or unauthorized access, use, modification or deletion but no security program can be guaranteed to be 100%
secure. As a result, Flexpat cannot guarantee the security of any information obtained or processed by Flexpat or its service providers, and you use the Flexpat Platform at your own risk. Your personal information is contained behind secured networks
and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer
(SSL) technology. We implement a variety of security measures when a user places an order to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.
The Flexpat Platform and Flexpat trips are designed for adults only and are not available to children (i.e. persons who are under 18 years of age) or users who have had their user account temporarily or permanently deactivated. By becoming a user,
absolute discretion not to provide any Services to you if we are not satisfied that you are an adult. If a child has provided us with Personal Information, a parent or legal guardian of that child may contact us as described below. Upon confirmation,
we will then make reasonable efforts to delete the child’s Personal Information from our applicable database.