In this AP Privacy Policy, "we", "us" and "our" refers to Prex Technologies (BVI) Ltd (“Prex”).
Prex is committed to protecting the privacy of our customers and stakeholders, and we take our data protection responsibilities with the utmost seriousness.
This AP Privacy Policy sets out what Personal Data we collect, how we process it and how long we generally retain it, along with details of your rights as a data subject.
To the extent that you are an applicant to our Affiliate Program, this AP Privacy Policy applies together with the Affiliate Program Terms and other contractual documents (if any) we may have with you. This AP Privacy Policy applies to you in your capacity as an applicant of our Affiliate Program (and if you are successful in your application, as a Flipster Affiliate). Prior to becoming a Flipster Affiliate, you would also have to be a user of the Flipster Trading Platform (the “Platform”) whether through the Site or the mobile application. As a user of the Flipster Trading Platform, you are bound to the Flipster Terms of Use and Flipster Privacy Policy which may be found at https://flipster.io/policies/terms and https://flipster.io/policies/privacy respectively.
We reserve our right to issue separate policies in respect of other relevant stakeholders such as our employees, connected persons and/or our business partners.
In this AP Privacy Policy, “Personal Data” means any information relating to you as an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
For the avoidance of doubt, Personal Data does not include data from which you cannot be identified (which is referred to simply as data, non-personal data, anonymous data, or de-identified data).
In this AP Privacy Policy, “processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
This AP Privacy Policy is issued by Prex as data controller, and shall serve as a notice to you in your capacity as Data Subject.
- Personal Information We Collect
We collect information about you when you:
- Submit an application for the Affiliate Program through flipster.io (the “Site”)
- visit the Site;
- contact us either through the Site, the Platform, or through other direct means of electronic communication including social media engagement;
- interact with us or Flipster’s services including account (“Account”) creation on the Platform or through the Site, or use or interaction through the Platform;
- enter into any other relationship with us or interact with us through any means.
- The type of information we collect
The personal information we collect may include your:
Name; address; email address; telephone number; date of birth; gender; nationality; identification number; employment details; social media account details; aliases and details about your online personas; information about your social media activity; financial details including salary and employer details; residential address; location; device information; cryptographic wallet address; electronic signature; and information about how you use our Site or Platform.
If you sign up for an Account as a user of the Platform, the Flipster Privacy Policy will apply to you. Please refer to the Flipster Privacy Policy for the types of information that we will collect from you in your capacity as a user of the Platform.
We may also automatically collect the following information when you visit our Site:
Your internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after you visit the Site, information about the links you click, and other information about how you use the Site.
We, as well as third parties that provide content, advertising, or other functionality on the Site, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Site. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Site.
We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on the Site. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
- Purpose and legal basis for the use of your personal information
We use personal information about you in connection with the following purposes:
- to administer and operate the Affiliate Program and your participation in the Affiliate Program as a Flipster Affiliate;
- to complete any arrangement you have with us under or in connection with the Affiliate Program;
- to perform any contractual obligation we have to you; and/or
- to meet a legal or regulatory obligation.
In order for you to join the Affiliate Program, you would first need to have an Account on the Platform. If you sign up for an Account as a user of the Platform, the Flipster Privacy Policy will apply to you. Please refer to the Flipster Privacy Policy for further details regarding the purpose and legal basis for the use of your personal information as a user of the Platform.
We may also use your personal information for direct marketing to you. More specifically, we may use your personal information:
- to provide you with information about the services or products offered by the Platform, or the events or promotions offered through the Platform; and/or
- to provide you with other marketing material related to the Platform.
By agreeing to this AP Privacy Policy you understand that you are giving us explicit consent for the processing of your Personal Data for direct marketing purposes. If you do not want your personal information to be used for marketing purposes, please contact us using our contact information as set out in the section titled “Contact and further information” below.
- How we share your Information
Why and when we share your information
We may share your Personal Data with third parties (including entities of the wider group of companies to which we belong) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process.
We may also be required by law or by a Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to public, regulatory and/or other competent authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights.
In addition, your Personal Data may also be shared and processed by us and/or other members of the of the wider group of companies to which we belong, our affiliates, agents, vendors, consultants or suppliers, as well as any other third party service providers who are performing certain services on our behalf (for example, outsourced service providers, external Counsel, financial institutions, etc.). Such third parties will have access to your Personal Data solely for the purposes of performing the services specified in the applicable engagement, or to comply with applicable laws and not for any other purpose. These third partied are not permitted to use your personal information for their own purposes, and rather can only process in accordance with our instructions. We require these third parties to undertake security measures consistent with the protections specified in this AP Privacy Policy and applicable law.
In addition, we may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
[Where applicable] Transferring your information outside of the European Economic Area
Sometimes our business partners, third party service providers, agents, subcontractors and other associated organisations may be located outside of the European Economic Area (EEA). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.
We share your personal data with these third parties outside of the EEA where we have a legal basis for doing so such as to provide you with our services or because we ourselves use service providers outside of the EEA in order to operate our business. If we transfer your information outside of the EEA to third parties we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).
- Automated decision-making
We do not use automated-decision making methods (including profiling) in connection with the Affiliate Program. However, please note that in order for you to join the Affiliate Program, you would first need to have an Account on the Platform. If you sign up for an Account as a user of the Platform, the Flipster Privacy Policy will apply to you. Please refer to the Flipster Privacy Policy for further details.
- How long do we keep your information
We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this AP Privacy Policy. Records can be held on a variety of media (physical or electronic) formats.
In addition, we may retain your personal data for a period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so.
- Security Measures
We have appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have taken substantial precautions to ensure the security of your data. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality and a duty to comply with data protection procedures. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Your Data Rights
In accordance with applicable law, you may have the:
Right to Information and access
You have a right to be informed about the processing of your Personal Data (and if you did not give it to us, information as to the source) and this AP Privacy Policy intends to provide the information.
Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information.
The accuracy of your information is important to us. If you do not want us to use your Personal Data in the manner set out in this AP Privacy Policy, or need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and use your Personal Data, please contact us using our contact information as set out in the section titled “Contact and further information” below.
Right to erasure (right to be ‘forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:
- the personal information is no longer necessary for the purpose for which it was collected;
- you withdraw your consent to consent based processing and no other legal justification for processing applies;
- you object to processing for direct marketing purposes;
- we unlawfully processed your personal information; and
- erasure is required to comply with a legal obligation that applies to us.
We will proceed to comply with an erasure request without delay and to such extent we are able to do so, unless continued retention is necessary for:
- exercising the right of freedom of expression and information;
- complying with a legal obligation under EU or other applicable law;
- the performance of a task carried out in the public interest;
- archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
- the establishment, exercise, or defence of legal claims.
Right to restrict processing and right to object to processing
You have a right to restrict processing of your personal information, such as where:
- you contest the accuracy of the personal information;
- where processing is unlawful you may request, instead of requesting erasure, that we restrict the use of the unlawfully processed personal information;
- we no longer need to process your personal information but need to retain your information for the establishment, exercise, or defence of legal claims.
You also have the right to object to processing of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent. This may impact the arrangement we have with you in relation to the Affiliate Program and we will explain this to you if you decide to exercise this right.
If you would like to exercise any of these rights, please log into your account or contact us using our contact information as set out in the section titled “Contact and further information” below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
[Where applicable] Right to lodge a complaint with a relevant supervisory authority
You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.
- Changes to Our AP Privacy Policy
We may revise this AP Privacy Policy from time to time in our sole discretion. If there are any material changes to this AP Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated AP Privacy Policy if you continue to participate in the Affiliate Program after the new Privacy Policy takes effect.
- Contact and further information
If you would like a copy of the Personal Data or wish to exercise any of your Data Subject Rights as set out in this AP Privacy Policy, or if you have any questions regarding this AP Privacy Policy or generally about the way we handle your Personal Data please contact support@flipster.io.