Effective as of Jan 1 , 2020
We have implemented various technical and organizational measures to be compliant with applicable personal data, privacy, and data security legislation in the countries where we operate or where the applicable law applies to us.
Contact details and Questions
Our Application is based on principles relating to the processing of the Personal Data and we commit to the following principles relating to the processing of the Personal Data:
– we process Personal Data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed, especially we don’t require you to register or log in, we don’t have access to your funds (private keys), we don’t require your name or email address.
– we collect accurate and, where necessary, kept up to date Personal Data when applicable and relevant;
– we store your Personal Data for no longer than is necessary for the purposes for which the Personal Data are processed;
– we use and ensure appropriate security of the Personal Data
2. Registration/Login Not Required
Flare does not require you to register or log in.
3. Private Keys Stay on Device
Your private keys will stay on your device.
4. Categories of Collected Personal Data
We collect the following categories of your Personal Data:
– Device Information. We may collect information about the device you use to access our Application, including the hardware model, operating system and version, unique device identifiers, and mobile network information. This information will never be communicated to third parties unless you provide prior specific consent.
– Analytical Information that includes information about how you use the Application.
– Information you may provide to us. Your email address, virtual currency addresses, and any other information you choose to provide will never be communicated to third parties unless you provide prior specific consent.
5. Processed Personal Data
We process personal data when you interact with the Application or use our services, especially when:
– you use our services;
– you browse any page or section of the Application;
– you communicate with us or leave a query;
– you subscribe to our newsletters/updates;
– you receive notification from us;
– we measure or analyze the Application’s traffic.
6. Purposes and Legal bases for the Processing of Your Personal Data
We process your Personal Data for the following purposes:
– Providing services. We need to provide services via the Application. Legal basis: contract.
– Performing transactions. Legal basis: contract.
– Providing newsletters/offers/updates which may be interesting to you. Legal basis: consent for newsletters; legitimate interests for offers and updates.
– Compliance with applicable regulatory rules. Legal basis: legal obligation.
– Keeping the Application running (managing your requests, remembering your settings, hosting, and back-end infrastructure). Legal basis: legitimate interests.
– Improving the Application (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Application, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your Personal Data and in some cases using third parties to do this). Legal basis: legitimate interests.
– Customer support (notifying you of any changes to the Application, services, solving issues, any bug fixing). Legal basis: legitimate interests.
7. Blockchain Transactions
Your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems.
8. Secure Communication with our Servers, Confidentiality, and Security Measures
We have security and organizational measures and procedures to secure the data collected and stored and to prevent it from being accidentally lost, used, altered, disclosed, or accessed without authorization. All of our servers support HTTPS. We allow disclosure of your personal data only to those employees and companies who have a business need to know such data. They will process the Personal Data on our instructions and they are obliged to do it confidentially under confidentiality agreements.
You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks. You are responsible for your login information and password. You shall keep them confidential. In case if your privacy has been breached, please contact us immediately. We have procedures in place to handle any potential data breach and we will inform a regulator of a breach if we are legally required to do so.
9. Communication with Third-Party Servers
Exchange rates, balances, transactions, and other blockchain information may be read from or related to third-party servers. We cannot guarantee the privacy of your Internet connection.
10. Location of the Processing of Personal Data and Third-Party Services
The Personal Data is collected and processed by the company incorporated in Estonia.
There are the following third parties:
– third parties providing exchanges services such as Changelly, ChangeNOW, and Simplex
– email service providers to notify you and for direct marketing purposes such as Kickoff and SendGrid;
– website analytics companies to analyze data and improve our services and the Application such as Yandex Metrics and Google Analytics;
– platforms which we use for the support services such as Telegram;
– social media companies to promote and be present in social media such as Twitter, YouTube, Telegram, GitHub, medium.
Our Cookies Policy is available here.
12. Aggregate Usage Statistics
We may collect Flare services usage information in order to improve function or UI, but will only use this information in an aggregated, anonymized fashion, and never in association with your name, email, or other personal data.
13. Optional Extra Personal Data
14. Your Rights as Data Subject
You can exercise the following rights by contacting us.
You have the right to access information about you, especially:
– the categories of Personal Data;
– the purposes of the processing of the Personal Data;
– third parties to whom the Personal Data disclosed;
– how long the Personal Data will be retained and the criteria used to determine that period;
– other rights regarding the use of your Personal Data.
You have the right to make us correct any inaccurate Personal Data about you.
You can object to using your Personal Data for profiling you or making automated decisions about you. We may use your Personal Data to determine whether we should let you know the information that might be relevant to you.
You have the right to the data portability of your Personal Data to another service or website. We will give you a copy of your Personal Data in a readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the Personal Data to the other service for you.
You have the right to be “forgotten”. You may ask to erase the Personal Data about you if it is no longer necessary for us to store the data for purposes of your use of the Application.
You have the right to lodge a complaint regarding the use of your Personal Data. You can address a complaint to your national regulator (the list of the regulators are accessible via https://edpb.europa.eu/about-edpb/board/members_en).
Once we receive any of your requests we will consider and decide on it within one month unless there is a justified requirement to provide such information faster. This term may be extended according to the applicable law.
We may request specific information from you to confirm your identity when necessary and reasonable. This is a security measure to ensure that the Personal Data is not disclosed to any person who has no right to receive it.
You do not need to pay a fee to access information or other rights but we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive or refuse to comply with your request in these circumstances.
15. Support Requests
If you contact support then as part of the support request we may incidentally collect your personal data but we will endeavor to keep that information secure and confidential. Support information may be managed using a third-party service and further terms of that service may apply to your support request.
16. Retention Policy
We store the Personal Data as long as we need it and the retention practice depends on the type of data we collect, regulatory burden, and how we use the Personal Data. The retention period is based on criteria that include legally mandated retention periods, pending or potential litigation, tax and accounting laws, intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.
In some circumstances, we may anonymize your Personal Data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.