- Information and Data
- How we collect your information
- How we use your information
- Disclosure of your information to third-parties
- Third Party Sites and Services
- Updating, Accessing, and storing your information
- Privacy Rights
- California Specific Privacy Rights
- Information obtained from third-parties
- Special Notice to California Residents
- Special Notice to Vermont Residents
- Contact information
2. Information and Data
Personal information is data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
A. Information you provide to us:
To establish an account and access our Services, we’ll ask you to provide us with some important information about you. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide at least three (3) months of bank statements), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information. Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us. Any information you provide to us that is not required is voluntary.
B. Information we collect:
- Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, IP Address, social security number, and/or email.
- Formal Identification Information: Government issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial, consumer protection, and commercial lending laws.
- Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
- Financial Information: Bank account information, Tax return information, Federal and State Tax ID, Profit and Loss Statements, Average monthly sales revenue, Income statements, Credit Score, Business Invoices, and Wire Instructions.
- Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
- Employment Information: Office location, job title, and/or description of role.Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
- Correspondence: Survey responses, information provided to our support team or user research team.
- Business Information: Business legal entity, NAICS code, business description, list of officers, members, or managers of the business, articles of incorporation, certificates of good standing, ownership structure (including percentage of ownership of each owner), number of employees, date of incorporation, primary business address, PO box address, state of incorporation, legal business name and business website.
- Funding information: Requested funding amount, purpose of funding, funder name and balance of all current outstanding working capital loans.
The documents and information collected are securely stored and safeguarded. At your request and with your permission, these documents may be shared with certain lenders.Under no circumstances will we disclose, transmit, or share in any way, these documents without your permission.
C. Information we collect from you automatically
We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
- Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
- Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
For example, we may automatically receive and record the following information on our server logs:
- How you came to and use the Services;
- Device type and unique device identification numbers;
- Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
- How your device interacts with our Sites and Services, including pages accessed and links clicked;
- Broad geographic location (e.g. country or city-level location); and, other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third-party site.
D. Information collected from third parties
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include:
- Public Databases & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law.
- Credit Bureaus: With your consent, we obtain information from credit bureaus, including your credit report. However, we will not disclose your credit report without your explicit permission. We obtain your credit information to better provide services to you, to match you with appropriate lenders, to ensure your identity, and to avoid fraud.
- Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you
- Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation.
E. Data Anonymization and Data Aggregation
Flychain may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.
Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators. Moreover, should you request that your information be deleted in accordance with the policies set forth more fully below, your information will be anonymized or aggregated, which complies with applicable law regarding deletion of personal information.
3. How we collect your information
- Log Files: Any time you visit any of our websites, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This gives us an idea of which parts of our site users are visiting. We do not share the log files externally.
- Web Beacons: ”Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers. We do not link the web beacons to any personally identifiable information.
- Sign-Up Information: To process sign-ups, we may require your name, address, phone number, email address and other personal information. Such information is used primarily to process your order or as otherwise described herein. This is information you provide to us.
- Application: To access our services, we require your name, address, phone number, email address, and other personal information. We also require the name of your business, its address, its federal and state tax ID, the type of business, business location, average monthly sales, state of incorporation, name of Landlord (if applicable), credit card transactions per month, purpose of the loan, and current outstanding loans.
- Emails and Telephone Calls: We require an email address from you when you register for our services. We use your email for both transactional (e.g., order confirmation, refund and renewal processing) and promotional (e.g., newsletters, new product offerings, special discounts, event notifications, special third-party offers) purposes. Email messages we send you may contain code that enables our database to track your usage of the emails, including whether the email was opened and what links (if any) were clicked. If you would rather not receive promotional emails from us, please see the section below labeled “Choice/Opt-Out”. We reserve the right to send you certain communications relating to the Flychain services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. We may also contact you by telephone or text message (including to any wireless number you may provide to us) solely in connection with Flychain’s services. If you would rather not receive telephone calls or text messages from us, you may change or delete your number from your account preferences page(s), or ask to be removed from our contact list if you receive a call or text message from us. We fully comply with the requirements of the U.S. CAN-SPAM Act.
- Other Sources. We may obtain information about you from third parties such as credit reports. We do not pull a credit report without your permission.
4. How we use your information
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.
We may use this information in the following ways:
1. To maintain legal and regulatory compliance
Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Flychain must identify and verify customers using our Services in order to comply with commercial lending laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your Flychain Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we reserve the right to close your account.
2. To enforce our terms in our user agreement and other agreements
Flychain handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services.
3. To detect and prevent fraud
We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or information loss.
4. To provide Flychain’s Services
We process your personal information to provide the Services to you. For example, when you wish to seek a loan from one of our lending partners, we require certain information such as your identification, contact information, and income information. We cannot provide you with Services without such information.
5. To provide Service communications
We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
6. To provide customer service
We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
7. To ensure quality control
We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services.
8. To ensure network and information security
We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.
9. For research and development purposes
We process your personal information to better understand the way you use and interact with Flychain’s Services. In addition, we use such information to customize, measure, and improve Flychain’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.
10. To enhance your experience
We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
11. To facilitate corporate acquisitions, mergers, or transactions
We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.
12. To engage in marketing activities
Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
13. For any purpose
We may disclose your personal information for any purpose you consent to. The following chart summarizes how we use the categories of personal information we collect from consumers:
• Lending partners
• Service providers
• Professional advisors
• Lending partners
• Service providers
• Lending partners
• Service providers
• Lending partners
• Service providers
• Professional advisors
• Service providers
• Professional advisors
• Service providers
• Lending partners
• Service providers
• Professional advisors
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or Flychain Services may not be available to you.
5. Disclosure of your information to third parties
i. Disclosure By Law:
You acknowledge and agree that we may disclose information you provide if required to do so by law, at the request of a third party, or if we, in our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law) and (2) protect or defend Flychain’s, or a third party’s, rights or property.
ii. Lenders and/or brokers:
By signing up for our services or submitting a request for a business loan product or service as offered on the Websites, you signify your agreement to proceed and that you are consenting, acknowledging and agreeing to the disclosure of your information with lenders and/or brokers within our network. We will not perform a credit check without your authorization. Please be aware that the lenders, brokers, and/or other service providers with whom you are matched and with whom your information is shared may retain your information, even if you do not enter into an agreement for their products or services. Please contact each such party directly regarding their privacy and information policies. Also, if you enter into an agreement with a lender, broker, or other service provider through the Flychain service and make changes to the information you have provided to us, we may share the updated information with such lenders, brokers, and/or service providers.
iii. Disclosure to Trusted Third Parties By Us:
iv. Service Providers:
With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
- Network infrastructure
- Cloud storage
- Payment processing
- Transaction monitoring
- Document repository services
- Customer support
- Internet (e.g. ISPs)
- Data analytics
- Information Technology
v. Other Companies
- With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
- With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
6. Information obtained from third parties
We purchase marketing data about our customers from third parties and combine it with information we already have about you, to create more tailored advertising and products. If you provide information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Any information obtained from a third-party will be used to assist matching your business with various lenders.
The Websites contain links to other websites that are maintained by third parties. These third parties are solely responsible for their own websites and we encourage you to reach out to such third parties for copies of and information regarding their security practices. We do not control, and are not responsible for, the privacy and security practices of these third parties.
7. Third Party sites and services
If you authorize one or more third-party applications to access your Flychain Services, the information you have provided to Flychain may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using Flychain Services. Please note that third parties you interact with may have their own privacy policies, and Flychain is not responsible for their operations. Information collected by third parties, which may include such things as contact details, or other personal information, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
Examples of account connections include:
- Lenders: If you use your Flychain account to conduct a transaction with a third-party merchant, the merchant may provide data about you and your transaction to us.
- Your Financial Services Providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Please review the privacy notice of any third-party that will gain access to your personal information.
8. Updating, accessing, and storing your information
You may update or access your profile information at any time by logging into your account and making any change or update. Any changes made will be updated immediately. If you want to stop using your account you may deactivate it or delete it. When you deactivate an account, your information will not be sent to any further lenders, brokers, or other third parties, but the information will not be deleted. By deactivating your account you will have the ability to restore the account in its entirety.
You may delete your account from Flychain. If you choose to delete your account it will be permanently deleted from Flychain. You should only delete your account if you are certain you never want to reactivate it again.
Upon deletion of your account, data you provide to Flychain will be retained by Flychain in a commercially reasonable manner and to comply with relevant lending laws. Once your account is deleted, Flychain will not share your information, and will only use your data for internal research and Flychain marketing. Data that is retained by Flychain will be retained for a commercially reasonable period of time as determined by Flychain in conformance with applicable law.
We store your personal information securely throughout the life of your Flychain Account. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.
- Personal information collected to comply with our legal obligations under financial, consumer protection, and commercial credit laws may be retained after account closure for as long as required under such laws.
- Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
- Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).
- Recording of our telephone calls with you may be kept for a period of up to six years.
- Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
9. Privacy Rights
Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Flychain has absolute discretion in providing you with those rights.
our rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
i. Access and portability
You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
ii. Rectification of incomplete or inaccurate personal information
You may request us to rectify or update any of your personal information held by Flychain that is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
iv. Withdraw consent
To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Flychain’s processing based on consent before your withdrawal.
v. Restriction of processing
In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
vi. Automated individual decision-making, including profiling
Flychain relies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
vii. How to make a privacy request
You can make privacy rights requests relating to your personal information by contacting us at firstname.lastname@example.org. When we receive an individual rights request via other intake methods, we may take steps to verify your identity before complying with the request to protect your privacy and security.
viii. How to lodge a complaint
If you believe that we have infringed your rights, we encourage you to contact us at email@example.com.
10. California Specific Privacy Rights
In addition to the rights provided for above, if you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties’ direct marketingpurposes. To the extent we share your personal information in this way, you may receive the following information:
- a) the categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and
- (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights section.
- For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. Flychain will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.
- To the extent we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. Please note that the only time personal information is sold is when you decide to apply for, and fund, business loans through the Flychain marketplace. Otherwise, your information is maintained by Flychain, but is not sold.
Should Flychain engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you in your account settings. You can exercise your rights by contacting us at firstname.lastname@example.org so that we may consider your request.
If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent’s request if they submit proof that they are registered with theCalifornia Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.
In the event there is a data breach at Flychain, Flychain will notify you within 45 days. We will notify you that a breach occurred, what type of information was breached, when the breach occurred, what steps you can follow to further protect your information, what actions we are taking regarding the breach and what steps we are taking to ensure the breach does not happen again. Do not share your account login and/or password with any other individual. Your account login and/or password is sensitive and your sharing of your account information may lead to additional exposure to your account.
You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instruction included in these emails or you can contact us at email@example.com. You can choose not to provide us with certain information, but this will likely result in the inability to use certain features of the Websites and to obtain the services and products you are seeking. As a general matter, do not post personal information on public forums. You are solely responsible for the posting of any personal information on public forums. If, after signing up for our services, you decide you no longer wish to receive our services or future contact from lenders, brokers, or other third parties to which your information has been referred, you may cancel your account as discussed herein. Upon canceling your account, your information will no longer be sent to lenders, brokers, or other third parties. This does not guarantee that these lenders, brokers, or other third parties will cease contacting you or using your information. Please be sure to reach out to all lenders, brokers, and/or other third parties to ensure they cease contacting you. Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from our database until the time requirements of these regulations have expired.
13. Special notice to California residents.
- We will not share any personal information about you with third parties to the extent prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law; and
- You have the right to request information from us regarding the manner in which we share certain categories of information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive the following information:
- the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- the names and addresses of the third parties that received that information; and
- if the nature of the third party’s business cannot be determined from their name, examples of products or services marketed.
We may provide this information in a standardized format that is not specific to your situation. Requests may be sent to firstname.lastname@example.org.
14. Special notice to Vermont residents.
Vermont law places additional limits on sharing information about Vermont residents so long as they remain residents of Vermont. In accordance with Vermont law, we will not share information we collect about Vermont residents to companies outside of Flychain except: (1) As permitted by law; (2) To companies that perform marketing or other services on our behalf; (3) Name, contact and transaction and experience information to other financial institutions with which we have joint marketing agreements; or (4) With the authorization or consent of the Vermont resident. We also will not share non-transactional information about Vermont residents received from others within the Flychain family of companies except with the authorization or consent of the Vermont resident.
17. Contact Information