Privacy Policy

Flipful SIA (hereinafter referrred to as Flipful, we, us or our) respects your privacy and is commited to protecting your Personal Data. This Privacy Policy describes how we collect and process your Personal Data in connection with the provision of our services, Flipful mobile app and/or Flipful web platform.

Flipful ensures that your rights are respected in accordance with the provisions of the General Data Protection Regulation (hereinafter referred to as “GDPR”) and that the processing of personal data is only for the purposes for which the Personal Data is collected.

This Privacy Policy explains:

  1. Who is data controller?
  2. What kind of personal data do we process?
  3. How do we collect personal data?
  4. Why and on which legal basis do we process personal data?
  5. For how long do we store your data?hy
  6. Do we share personal data with third parties?
  7. Do we transfer personal data to third countries?
  8. Automated data processing
  9. What rights do you have?
  10. Amendments

By using Flipful services, you acknowledge and agree to the Flipful Privacy Policy.

1. Who is data controller?

Insofar as we are processing personal data we obtain from you as a data subject, the personal data controller is:

Limited liability company “Flipful”
Registration number 40203200098
Legal address: Volguntes street  7, Riga, LV-1046, Latvia

Contact details for data protection issues: dpo@flipful.eu

In order to provide our services, we work closely with your employer on behalf of whom we process the data. With respect to employment data and transaction data , Flipful acts as a data processor. For these types of data the data controller is considered your employer. Accordingly, if you have any questions regarding the processing of transaction data, please contact your employer.

2. What kind of personal data do we process?

In order to provide you our services, we need to process your personal data. The following types of personal data are processed by Flipful:

Registration data: When you create an account to receive our services, we process the personal information you provide to us during registration process. Registration data can include your name, surname, e-mail address and telephone number and other information you have provided us.

Employment data: To facilitate the provision of Flipful services, we need to register you in the system and process specific information to assess the possibility of providing you our services. Employment data includes the following information – your name, surname, job title, email address and phone number, employer name, payroll data and other information we have received from your employer (for the employment data, the data controller is your employer) .

Transaction data: We process the information needed to provide our services. Transaction data may include your name, bank account information, and transaction details. Transaction data is processed in order to ensure provison of our service.

Correspondence data: In cases when you contact us for any question/-s you may have, we can process the information you have sent to us. Correspondence data may include your name, e-mail, message content, and other information related to the message.

Representation data: If you represent a legal entity, Flipful will process your name, surname, representation rights. If you are appointed as a contact person for a legal entity, we will process your name, surname, email address and phone number.

Audit trails data: Flipful is committed to safeguarding the usage of our services, thus we will process the data about audit trails. Audit data may include, inter alia, processing of login data, IP addresses and other necessary audit trails data.

Technical data: By using our services, Flipful can process technical data that may include processing of IP address, information about browsers used, pages visited, site usage information, and other information.

3. How do we collect personal data?

In most cases, we collect your personal data from your employer, according to the data processing agreement concluded between Flipful and your employer, subject to the requirements of Article 28 of GDPR. In certain cases, personal data may also be obtained directly from you.

In addition in order to ensure provision of our services and operation Flipful website, we may obtain information from cookies placed on your browser. For more information on how Flipful website uses cookies, please see our Cookie Policy.

4. Why and on which legal basis do we process personal data?

We process registration data to facilitate the provision of Flipful services and operation of our website, ensuring the security of website and services, for example by identifying you. The processing of this data is based on the fulfillment of a reciprocal agreement (Article 6 (1) (b) of the GDPR).

Employment data and Transaction data are being processed in order to allow you and your employer to use the services provided by Flipful. The processing of this personal data is based on a data processing agreement between Flipful and your employer (Article 28 of the GDPR).

In addition Flipful stores Transaction data to be able to prove the fact of providing a service in the event of a dispute. The legal basis of storing Transaction is legitimate interests of Flipful, namely, for dispute resolution (Article 6 (1) (f) of the GDPR).

Correspondence data is processed to communicate with you and keep a record of our communication. The legal basis of processing Correspondence data is the legitimate interests of Flipful, namely, the provision of quality consultancy practices and the resolution of potential disputes (Article 6 (1) (f) of the GDPR).

In order to proceed with a business relationship with a legal entity ensuring required commencement and execution of a business relationship and the performance of our contractual obligation, Flipful processes Representation data to verify the representative’s right to enter into a contract on behalf of the company, register the contact persons in the Flipful system, and contact for the performance of the service contract. The legal basis for the processing of data is the legitimate interest of Flipful, namely, to ensure execution of a business relationship and the performance of a service contract with a legal entity (Article 6 (1) (f) of the GDPR).

In order to ensure the protection of Flipful’s legitimate interests and the service provided, we process Audit trail data. The legal basis for processing of audit data is the legitimate interests of Flipful, namely, to ensure the safety of the services provided and to resolve any disputes (Article 6 (1) (f) of the GDPR).

In order to ensure that services are aligned to your usage habits, perform error investigation, analysis, compilation of statistics, Flipful processes Technical data. The legal basis for the processing of technical data is the legitimate interests of Flipful, namely to prevent and correct service errors (Article 6 (1) (f) of the GDPR).

5. For how long do we store your data?

Your Registration data will be processed as long as you have an account with us or until there is a valid agreement between Flipful and your employer.

Employment and Transaction data will be stored by Flipful in accordance with a data processing agreement between Flipful and your employer. Additionally, Transaction data may be stored by Flipful for 3 (three) years from the date of provision of the service.

Representative data is stored as long as the existing person is considered as a contact person or until a valid service agreement between Flipful and a legal entity is in force, but not longer than 3 years after termination of the contract.

Correspondence data will be stored for a maximum of 3 (three) years after the end of the communication.

Audit trail data is processed for a maximum of 3 (three) years from the date of acquisition.

Technical data is stored for a maximum of 1 (one) year from the date of acquisition.

Regardless of the deadlines specified in this policy, if the data retention periods are subject to legal regulations that are binding on us, data storage will be carried out in accordance with the law.

6. Do we share personal data with third parties?

Flipful may disclose your personal data to our authorized persons and partners who help us to provide our services and act as data controllers , such as IT service providers , servers’ and their maintenance service providers, email service providers and others. By engaging with sub-processors, we will take all necessary steps to ensure that our data controllers ensure the confidentiality of personal data.

In addition, Flipful may disclose your personal data in the following cases:

  • To the persons specified in the regulatory enactments upon a reasoned request thereof in accordance with the procedure and scope specified in regulatory enactments;
  • In certain cases specified in laws and regulations for legal protection of Flipful interests, such as courts, bailiffs or other public authorities when a person has breached Flipful interests;
  • For other Flipful partners: auditors, lawyers and other specialists or consultants, financial institutions, insurers;
  • To the payment service providers to the extent necessary to make a payment to you, handle repayments;
  • Your employer to fulfill an agreement between your employer and flipful regarding the provision of Flipful services.

We will not transfer your personal data to third parties unless we have a legal basis for such transfer.

In certain cases, in cooperation with third parties (for example, using third-party cookies or financial services providers), the data processing is subject to the privacy policy of those third parties. Flipful invites you to familiarize yourself with the privacy policies of the individuals concerned and is not responsible for these privacy policies.

7. Do we transfer personal data to third countries?

We process your personal data only in the European Union (EU) or member states of the European Economic Area (EEA), as well as in countries where an adequate data protection framework is introduced.

8. Automated data processing

Flipful processes your data using various methods that are partly or wholly automated, or non-automated as part of Flipful services.

9. What rights do you have?

You have the right to access and modify or delete personal data, to restrict or object to the processing of personal data, and to receive personal data concerning yourself and / or to request it to be transferred to another data controller (data portability), when permitted by the General Data Protection Regulation.

Likewise, if you believe that your rights regarding the processing of personal data have been violated, you have the right to file a complaint with the Latvian Data State Inspectorate (DVI), address: Blaumaņa iela 11/13-15, Riga, LV-1011, Latvia (www.dvi.gov.lv).

If you would like to use your rights described above, please address your requests to our postal address or email address stated above.

In cases where you use your rights according to stated above, we may need to request additional information from you to confirm your identity and to ensure that personal information is disclosed only to you.

For the personal data we receive from your employer, the data controller is your employer. To use your rights as a data subject or to find out about the processing of such data, you should contact your employer.

10. Amendments

Flipful reserves the right to unilaterally update this Privacy Policy at any time. The current version of the Privacy Policy is available on our website www.flipful.eu.

This privacy policy is effective from May 1, 2019.