Privacy Statement

Version 1.2 | October 1, 2019

You must be curious how we handle your data. We applaud you for checking this. We believe it is important to understand our statement. Read this carefuly before using our services. Any questions left? Reach out out to us via privacy@flowyour.money

To be clear and to prevent misunderstandings about how we handle your personal data, we shall:

1. Introduction

This is the Privacy Statement of Flow Money Automation B.V. In this statement we describe what personal data we process and why we need those. Flow is actively working to ensure your privacy. We shall, among others:

For all questions regarding this Privacy Statement you can reach out to privacy@flowyour.money

Times change and the same may apply to our Privacy Statement. We have the right to amend our Privacy Statement. You may not be able to use Our Services until you have accepted the latest version of our Privacy Statement. These Privacy Statements were published on October 1, 2019 but the latest version can always be viewed at: https://flowyour.money/privacy. A new version is valid from the moment it is published on the Website, unless you have previously accepted it in another way.

2. About us

Flow is responsible for processing your personal data. We take this job very serious. And of course you want to know who we are. Here you have our data:

Flow Money Automation B.V.
Riperwei 54
8406 AK Tijnje
Chamber of Commerce: 72829796
E-mail: privacy@flowyour.money

3. Cookies

Read our Cookie Statement.

4. Type of data we collect

We collect and proces the following data:

  • i) Marketing data
  • ii) User data
  • iii) Transaction data
  • iv) Technical data

Below an explanation of what, why and how long we store your data:

i) Marketing data

What data do we need?
  • Your name
  • Your e-mail
Why do we need this?

We use this data to communicate with you. For example when we launch a new version of the app or if we want to send a promotional message.

How do we get this?

It could be that you share this data with us (“Sumbitted data”) by filling in forms in our App or Site, or by corresponding with us via e-mail, chat or social media.

When do we delete this?

We store this data until a maximum of 1 year after terminating your account. The storage of data is done within the GDPR guidelines, only within the EU. We only work with parners who meet the security requirements and comply with our Privacy Statement.

ii) User data

What data do we need??

  • Your name
  • Your e-mail
  • Your phonenumber
  • Your username
  • Similar registration data
  • Data from your monetary account, including:
    • Name
    • Account number(s)
    • Balances
Why do we need this?

To make sure you can do payments via Flow with your monetary account. We need to know for sure who you are and what monetary accounts belong to you when using Flow. That is why your register with a unique account, phonenumber and password.

Next to this we have to obey to our legal obligations, for example reporting unusal transaction to the authorities. And we want to be able to verify your identiy so we can protect you against fraud, money laundring or other criminal affairs.

How do we get this?

By completing the registration form in our App we receive most of this information. And when you connect your monteray account to Flow we get your account data.

When do we delete this?

We store this data until a maximum of 1 year after terminating your account. The storage of data is done within the GDPR guidelines, only within the EU. We only work with parners who meet the security requirements and comply with our Privacy Statement.

iii) Transaction data

What data do we need?

  • Date and time
  • Transaction amounts
  • Description(s)
  • Account number(s)
  • Transaction attachments
  • Counterparties
Why do we need this?

To make sure you can issue payments via Flow. The moment we receive the message that a transaction activated a trigger we will step into action. That is why we need to see what's in the description. Besides this, we want you to be able to trace back why we did a certain payment and thus we need to record this.

How do we get this?

When you connect your moneteray account with Flow we can receive this data.

When do we delete this?

We store this data until a maximum of 1 year after terminating your account. The storage of data is done within the GDPR guidelines, only within the EU. We only work with parners who meet the security requirements and comply with our Privacy Statement.

iv) Technical data

What data do we need?

  • A unique identification number (e.g. IMEI-or phonenumber)
  • IP adress
  • Time zone settings
  • Operating system and platform
  • Device information
  • Session data
  • URL’s you are visiting on our Site
  • Errors
  • Duration of your visit
  • Page interaction data (scroll behaviour, mouse clicks)
Why do we need this?

Simple: To keep Flow operating without technical issues. It enables us to get a better picture of the functioning of our products which helps us to optimize the App and Site and helps us keep the security of our products conform our standards. We shall process this data anonymized and not share it with third parties.

How do we get this?

We use analytical cookies to track your behaviour within our App and Site. Next to this, our system keeps a log with technical data.

When do we delete this?

We store this data until a maximum of 1 year after terminating your account. The storage of data is done within the GDPR guidelines, only within the EU. We only work with parners who meet the security requirements and comply with our Privacy Statement.

5. Marketing

We find it important to explain how we use your data for marketing purposes and to mention you have the right to unsubscribe. At any given moment you can unsubscribe from our mailings or contact us telling to do so via privacy@flowyour.money.

We may use your data (Submitted data, device data) to think of a way how you could use Flow. Based on this we could send you a suggestion on how to use Flow at best.

6. Sharing your data

There are certain situation in which we have to share your data with a third party. Do you transfer money to a different financial party? Then we have to process some of your data. Or for example the cloud provider that has our software installed. We share personal data with the following parties in order to operate our business:

Fraud detection agencies

To verify your identity and to protect you against fraud, money laundring or other criminal activities. We have to comply to the regulations by reporting unusual transcations to the authorities. As a result, we may prevent or restrict you from using Flow.

Banks and financial service providers

We could collaborate with these parties to offer our services. Our job is to protect your personal data and to protect you, that is why we shall never share your data without legitimate reason. Your data will only be transfered when you have asked us to use that service.

Advertising and analysis service providerss

We use a third party to do analysis over the App (Amazon) and Site (Google Analytics) usage. We do not share personal data. We do create a generic profile to recognise different behaviour.

7. Storing your data

The data we collect (Submited data, Device data) is send to, and stored at, a location in the European Economic Area ("EEA"): Amazon Web Services in Frankfurt, Germany. Storing your data is done within the guidelines of GDPR, only within the EEA. We only work with partners that match our security standards and Privacy Policy.

  • We store data on secured servers and send encrypted data using Secured Sockets Layer technology (“SSL”).
  • We have taken approapriate (technical and organizational) measures and use advance techniques to protect your data. We protect our devices with passwords, security procedures such as two-step verification and encryption of the storage medium.
  • You have the obligation to secure access to the App or Site with a chosen password. Do not share this password with third parties.

As you can see, we will do our utmost best to protect your personal data. We have internal procedures and policies reagarding the security of our product to prevent unwanted access. Unfortunately, sending data via the internet is not completely secure. That is why we cannot guarantee the safety of data sent to our App and Site.

The moment you do not longer want to use your account you can contact us via privacy@flowyour.money and request to delete your personal data from our systems.

8. Your rights

Of course you have rights regarding your data collection. You can contact us via privacy@flowyour.money to submit your request.

The right to view

You have the right to request access to the personal data that we process. We will provide a copy of the personal data that is being processed.

The right to rectification

If your details are incorrect, you can request us to adjust the details. We will then correct this.

The right to data erasure

Because you are using our services we collect data.You have the right to ask us to remove this data from our systems. We will meet this requirement without unreasonable delay and when it is reasonably within our control.

The right to transferability (data portability)

You can request us to transfer your personal data in a structured, common and machine-readable form. That way you can transfer your data to a new service provider without any obstacles.

We will try to comply with legitimate requests within one month. Exceptionally it can take us longer than a month, we ask for your understanding.