Privacy Policy
Effective date: September 2023
Freepass Inc. (the "Company", "us", "we", or "our") respects your privacy and takes your personal data seriously. Please read the following to learn about our practices in processing personal data we receive through our platform including any subdomains at www.fluxir.com (the "Website"). We believe that You have a right to know our practices regarding the information we may collect when you use the Website and/or use the services offered thereon. The guidelines contained herein apply to your visit or use of the Website and/or Service (as defined in the Terms & Conditions for Users published on the Website (the "Terms"). BY ENTERING AND/OR USING THE WEBSITE AND/OR VIEWING OR USING ANY OF THE SERVICES THEREON, YOU AGREE TO THIS PRIVACY NOTICE, INCLUDING THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA (DEFINED BELOW). IF YOU DISAGREE TO ANY TERM UNDER THIS NOTICE, YOU MAY NOT USE THE WEBSITE OR THE SERVICE. YOUR CONTINUED USE OF THE WEBSITE AND/OR THE SERVICE SHALL BE DEEMED AN ACCEPTANCE BY YOU OF THE TERMS OF THIS NOTICE. The use of the Website is subject to the Terms. The Website offers Users (as defined in the Terms) automated end-to-end Visa application services and other ancillary services and/or products. Users may access the Website at any time and apply for a Visa for and on behalf of their customers and/or employees and/or service provider for any country they select, available via the Website (the "Application"). The Website may be used by Users who are either (i) natural persons, or (b) legal entities (eg. companies). Users are solely responsible for ensuring that all individuals whose personal data may be included in the customer data processed through the Website, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Service are fully met by Users. This Policy applies to all information about you that we collect in connection with the Website throughout the world, and explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below) under the applicable privacy laws such as the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA").
1. What Personal Data We Collect, How, and How is it Being Processed 1.1. During your access or interaction with the Website, we may collect from you individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual ("Personal Data"). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below.
| Instance in which data is collected | Categories of personal data that are processed\ | Purposes of processing | Lawful Basis for Processing |
|---|---|---|---|
| When an Application is submitted on your behalf by a User and is being processes through the Website | Your first and last name; passport number; Date of birth; country of birth; gender; passport issue date; passport expiry date; country of issue; passport type; bank statement; proof of work; and all other data required for successful Visa Application. | To submit and process the Visa application and/or any other ancillary process in connection with such application. | Processing is necessary for the performance of a contract to which the data subject is party. Where the Application data includes any personal data constituting or revealing racial or ethnic origin or biometric data, such data is processed strictly subject to your consent. |
| When you subscribe to join our mailing list on our "join our mailing list" form available on the Website | first and last Name and email address. | contact you occasionally with communications to send newsletters and event invitations subject to applicable laws (for example, where required, subject to your consent). | process such contact information subject to your consent. You may withdraw consent at any time through the "unsubscribe" link within the email or by contacting us directly. |
| that you provide passively (by using the Website, by navigating the screens, clicking on buttons etc.) information. This data is collected using third party services by means of placing cookies, pixels or web beacons. For more information, please look at the Cookies section. | Your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. | prove, modify and update services and content offered on the Website; To monitor and ensure the orderly and proper operation and development of the Website and associated services; To improve and customize the user experience and the content that is presented on the Website; To support our marketing efforts and to allow providing you with customized content. | Strictly necessary cookies which are required for the proper operation of the website will be processed in our legitimate interest. Other cookies will be processed based on your consent which we will obtain through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings. |
1.2. You are not obliged under any applicable law to provide us any of the above information and you may be able to opt not to disclose your personal data to Fluxir. However, not providing Fluxir with certain data may mean that we cannot provide you with certain functionalities, process any requests or allow you to use the Services.
1.3. In addition to the above uses of your personal data, we may also process your personal data for the following purposes, subject to our legitimate interest:
1.3.1. We use certain personal data to operate, maintain, and provide to you the Website features and functionality and to provide you with the services as requested by you and/or on your behalf.
1.3.2. To prevent, detect and fight fraud or other illegal or unauthorized activities, including misappropriation, infringements, identity thefts, and any other misuse of the Website.
1.3.3. To enforce the Terms, as well as to protect the security or integrity of our databases and the Website, and to take precautions against legal liability.
1.3.4. To ensure legal compliance - from our side (to legal requirements that apply to us) and from your side (compliance with legal requirements applicable to you).
1.4. We will not use your personal data for any personal profiling and automated decision making regarding you based on such profiling.
1.5. We limit access by our employees to your information only to those who were specifically authorized by Fluxir to access your information, as part of their job.
1.6. Subject to our legitimate interest, we may use anonymized, aggregated, non-personal and non-identifiable data, which may be made available or gathered via your access to and use of the Website ("Non-Personal Data"). We are not aware of the identity of the user from which the Non-Personal Data is collected. We may use such Non-Personal Data in order to gain insight on how you and other users use the Website, and our social media accounts and try and improve it, as well as to plan our marketing and advertisements. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
2. How we Share Your Personal Data
2.1. Visa Applications: We will transfer your personal data to the applicable Diplomatic Service (as defined in the Terms), including embassies, consulates and/or other governmental authorities as part of your application for a Visa while providing our services through the Website.
2.2. Insurance providers: We may transfer your personal data to insurance agents and/or insurance companies should you apply for an insurance product through the Website in connection with your and/or your customers/employees' travels.
2.3. Service Providers: we employ other companies and people to perform tasks on our behalf and need to share your information with them in order to provide the services to us. The categories of third-party recipients of the personal data from us are as follows: Cloud hosting services, email campaign automation, communication automation, social media advertisement, web page building tools and payment gateway services, analytics service providers and insurance companies. Our service providers do not have any right to use your personal information collected from our Website beyond what is necessary for the purpose of facilitating our operation of the Website and provision of Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations.
2.4. Compliance with the Law: We may disclose your information if we believe it's necessary in order to comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a government request, to address fraud or security issues, to protect the safety of any person, to enforce our agreements with you; to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing or to protect our own rights or property. This includes sharing such information with our legal counsels.
2.5. Business Transfers: If we are in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be transferred as part of that transaction to a successor in interest and to the applicable legal authorities as well as legal counsels and other professional counsels involved such as accountants, and other officers of the government or of the applicable judiciary instance.
2.6. Anonymized Information: We may provide third parties with aggregated but anonymized information and analytics about our customers however, before we do so, we will make sure that it does not identify you.
3. Data Transfers and Global Processing
3.1. The Website may be operated in countries other than your own location, and your personal data may be accessed and/or processed from and/or transferred to countries other than your own location. We may do this where data is accessed/processed:
3.1.1. by Fluxir and its affiliates for operational, administrative, compliance purposes or customer support teams in our various locations;
3.1.2. By our service providers, for the purposes we specified under the section "Service Providers" (above).
3.2. If you are located outside of United States, and choose to provide information to us, please note that we transfer the data, including personal data, to Fluxir offices located in United States and process it there.
3.3. In the event that Fluxir needs to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union.
4. Data Subject Rights
4.1. If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR, the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), or the Colorado Privacy Act (CPA)), such rights may include - to the extent applicable to you - the right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination and the right to cease "sharing" or "selling" your information - please contact us by email at hello@fluxir.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.
4.2. It is your responsibility to ensure that all personal data submitted to Fluxir is correct.
4.3. If allowed by applicable laws, you have the right to withdraw your consent at any time when Fluxir processes your personal data based on your consent on any of these rights. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another lawful bases other than your consent.
4.4. You may exercise these rights to the extent these rights apply to you by emailing Fluxir to: hello@fluxir.com. We will undertake to respond to your request within the applicable time frame prescribed by applicable law. Although we will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law. In such instances we reserve the right to refuse your request. We shall require, as prerequisite to fulfilling any request, to verify your identity which we may do by asking you to provide certain information or identification to ensure that all data subjects' privacy is protected.
5. Cookies & Similar Technologies
5.1. A cookie is a small text file that is stored in your web browser that allows Fluxir or a third party (such as third-party service providers) to recognize you. Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies.
5.2. Cookies that we may use can generally be categorized as follows:
5.2.1. Necessary Cookies: These cookies are necessary to load the Website or to allow users to use Website's certain features.
5.2.2. Analytics Cookies: These cookies track information about how the Website is being used so that we can make improvements and report on our performance.
5.2.3. Preference Cookies: These first party cookies store your Website preferences.
5.2.4. Marketing Cookies: These are usually third party cookies by advertising platforms or networks in order to: (i) deliver ads and tracks ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities.
5.3. We may use additional tracking technologies to help understand user activities and preferences. For example, we use web beacons (also known as clear gifs, pixel tags or web bugs) to track user activities and communicate with cookies. You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only.
5.4. We use the following cookies and other tracking technologies. We will update this list from time to time depending on the cookies we will be using.
| --- | Name of cookie | Source (if third party cookies) | Purpose - what this cookie is doing | Expiration (lifetime of cookie) | Type (e.g., http, html, pixel |
|---|---|---|---|---|---|
| Necessary | |||||
| Analytics | Google Analytics | ||||
| Preference | |||||
| Marketing | Facebook pixels, Twitter Post | ||||
| Functionality |
5.5. We may set cookies that monitor links to our Website that we send to you (if you have consented to receiving emails from us). These cookies are used to track visitors to our Website sourced from these emails. To avoid these types of cookies, please follow the explanation below on how to change your browser cookies settings.
5.6. In addition, we may use tracking technology (pixels) in emails to understand how often our emails are opened and clicked on by our customers. If you do not wish this tracking to be effected, please change your email software or service (such as outlook, Gmail etc.) settings to not automatically download images (to the extent it is not already your default). In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you have added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information on this.
5.7. You can change your browser's settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
6. Security of Processing
6.1. We use appropriate physical, management, and technical measures to protect your data from unauthorized access, disclosure, use, modification, damage, or loss. Such measures include encryption using SSL, minimization of the amount of data that we store on our servers, restricting access to Personal Data to Company employees, contractors, and agents. However, please note that no security measure is perfect, therefore, you should take special care in deciding what information you disclose. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
7. Data retention
7.1. We will retain your personal data for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary with scenario, product, and service.
7.2. The standards Company uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the Website; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention.
7.3. Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
8. Changes to This Privacy Notice
8.1. We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page. We may notify you through different channels, for example, posting a notice on our Website or sending you direct notification.
8.2. You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.
9. Requirements under US Privacy Laws
9.1. This Privacy Notice describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 7) and deletion (Section 4) practices. We also included information about how we may process your information, which includes "business purposes" under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and similar state laws, as applicable. We do not "sell" or "share" your personal information for the intentions and purposes of the CCPA or CPRA, nor disclose personal information that we "control" to any third party for their direct marketing purposes. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Sections 1 and 2 above, if those third parties have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data (other than Diplomatic Services). You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. We will not discriminate against you by withholding our services from you or providing a lower quality of service to you for requesting to exercise your rights under the law. If you have any questions or would like to exercise your rights under any applicable US State privacy laws, you can contact hello@fluxir.com.
10. General
10.1. If you have any questions or suggestions, to exercise any of your rights, or if you have any other questions or complaints about our use of your personal data and your privacy please contact us at [hello@fluxir.com].
10.2. Our Website includes links to third party websites and services. Such websites and services, and any information you process, submit, transmit or otherwise use with or to such websites and services, are governed by such third parties' terms and privacy practices and policies, and not by this Privacy Notice. We encourage you to carefully read the terms and privacy policies of such websites and services.
10.3. Our Website is not directed to children under the age of 18. If we learn that a person under the age of 18 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at hello@fluxir.com.
10.4. Where your personal data is processed by Fluxir in accordance with this Privacy Notice, Fluxir, is the controller of the related personal data. Whereas Fluxir processes any third party personal data submitted by you to Our Website, You shall be deemed the data controller and Fluxir shall be the processor of such data on your behalf.
10.5. If you have any comments or questions regarding our privacy policy or practices, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Fluxir, please contract us at hello@fluxir.com.
