Privacy Policy

At SPLIT PAYMENTS, S.L. we are committed to ensuring that your personal data is protected and is not used for purposes other than those indicated in this Privacy Policy. For this reason, in this section we inform users and interested parties of everything concerning the processing of their personal data, thus complying with the data protection regulations applicable in our country: General Data Protection Regulation (EU)2016/679 of 27 April on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter,"GDPR").

This Privacy Policy is applicable to the processing of data that SPLIT PAYMENTS, S.L. carries out through this website: www.flanks.io (hereinafter, the "Website") and/or those others that are indicated. We recommend that you read it carefully before using thisWebsite or providing us with your data through it.

If you have any questions, please contact us at: suportelgpd@flanks.io

0. Table of contents

In this Policy you will find all the information relating to the processing of your personal data and the rights you can exercise to maintain control over them. In this regard, you will find information on:

1. Who is responsible for the processing of your data.
2. What requirements you must meet in order to provide us with your personal data.
3. What data processing we carry out through the Website and what are its main characteristics, explaining to you:
   • What data we collect and how we collect it.
   • For what purposes we collect the data we request from you.
   • What is the legitimacy for its processing.
   • How long we keep them.
4. To which recipients your data is communicated.
5. Existence of international transfers of your data.
6. What your rights are and how you can exercise them.
7. How we protect your personal information.
8. Changes to this policy.

1. Who is responsible for the processing of your personal data?

Your personal data will be processed bythe company SPLIT PAYMENTS, S.L. ("FLANKS"), with NIF B67332775 andwhose contact details are as follows:

• Address: Calle del Sol, nº55, 08840,Viladecans, Barcelona, Spain
• Contact telephone number: (+34) 930 40 05 44
• Contact email: suportelgpd@flanks.io

1.1 Our data protection officer

At FLANKS, we provide you with the contactdetails of our Data Protection Officer, to whom you can address any queries youmay have in relation to this Privacy Policy or the processing of your personaldata.

E-mail: suportelgpd@flanks.io.  

2. What requirements do you have to meet in order to provide us width your personal data?

• Minimum age: In order to provide us with your personal data, you must be at least 18 years of age and/or have sufficient legal capacity to use this Website.
• Truthfulness: When you provide us with your data to use our services, you guarantee that the data and information provided is real, truthful, updated and also belongs to you and not to third parties. Furthermore, you must notify us of any modification that may occur in the data provided, and you are responsible in any case for the truthfulness and accuracy of the data provided at all times.
• Verification of age and truthfulness: FLANKS reserves the right to verify yourage and identifying information at any time, if necessary, including by requiring an official proof of age or equivalent procedure and, in the event of fraud detection that proves or is suspected that you are under the age indicated, to delete, temporarily disable and/or terminate your account.

3. What data processing do we carry out through the website and what are its main characteristics?

Below, we explain how we treat your personal information and provide you, in detail, with all relevant information regarding your privacy:

3.1 When you contact us through our channels (contact form or email)

• What are the data collection routes?
  • Contact form
  • Sending e-mails to hello@flanks.io or other FLANKS e-mail addresses.
• What data do we collect?

Identifying and contact  information. We  collect your identifying information (name and surname), your telephone  number, e-mail address and the name of the company where you work, as well as  any other information that you voluntarily include in the communications you  send us.

We may request additional  information from you if necessary to comply with your request or requirement.

• What are the purposes of the processing of you personal data?

To answer your requests. The main purpose of the processing of this data  will be to answer your requests, resolve your queries and/or provide you with  the required information, as well as, where appropriate, to follow up on your  requests.

Improving customer service. All the information derived  from the doubts, queries, and advice offered to interested parties, as well  as the way in which requests are resolved, allows us to know how we provide  our own customer service, enabling us to improve its quality.

Likewise, all the information collected, once the retention period indicated below has expired, is anonymised and used for the purposes of analysing the most frequently asked questions via the chat and automating the most frequently asked questions, creating FAQS or being kept for statistical purposes in order to develop commercial strategies.[1]

• What is the basis of legitimacy that allow us to process your data? Is the provision of this data obligatory?

Consent. The data provided for the above purposes will be  processed on the basis of your consent, given when you voluntarily contact us  through the means made available to you to request information or make a  request.

Legitimate interest. All information collected by the customer  service department will be processed by us for statistical purposes which  will help us to improve the quality of the customer service provided. You can  request more information about the weighting of our legitimate interests by  contacting us at suportelgpd@flanks.io.

The information that you are required to  provide will be indicated by an asterisk or similar. Without this information  it will not be possible to deal with your enquiries or requests.

How long do we keep  your information?

We will process all of your personal  information for the time that your requests are being processed and, if  necessary, to follow up on them. At the end of this period, FLANKS will keep  this information, blocked, for the periods provided for by law in order to  meet any liabilities and to demonstrate compliance with our obligations. From  this point onwards, FLANKS will only process the information in an anonymised  form, so it will not be possible to link the statistical information to the  specific users to whom it refers.

Who do we give your  personal information to?

We do not make any additional transfers  to carry out this processing other than those indicated, in general terms, in  point 4. To whom do we transfer your  personal information? In this regard, some of the channels through which  you can contact us are managed by service providers, who act as Processors.  You will find more information about how these service providers operate in  section 4 above.

3.2.      If you have a contractual relationshipwith us (provision of services)

What are the data  collection routes?

Maintaining  a commercial or contractual relationship with FANKS (by signing contracts,  quotations, commercial contact, etc.).

What data do we  collect?

Identifying and contact  information. We  collect your identification data (name and surname), e-mail address and  professional postal address, telephone number, as well as any other data  related to the commercial or contractual relationship.

Employment details: During the contractual  relationship, we may collect data relating to the contact person representing  the client company (first and last name, professional e-mail address,  position and/or department).

What are the purposes  of the processing of your personal data?

Commercial contact. When there is no contractual relationship, the data  will only be processed to maintain relations of any kind with the legal  entity in which the data subject provides his or her services.

To perform and maintain the contractual relationship  between the Parties. Where there is a  contractual relationship, the main purpose of the processing of this data  will be to maintain and execute the contractual relationship between the  parties, which may include: Administrative, fiscal, legal, accounting and  commercial management of customer data.   Drawing up and sending estimates. Carrying out work or services.  Attention to queries and complaints via web, telephone, electronic or in  person. Setting up meetings and client visits.

Sending publications and commercial  communications related to our products/services: We may send you, by electronic means,  our newsletter and other commercial communications related to our products  and services.

What is the basis of  legitimacy that allows us to process your data? Is the  provision of this data obligatory?

Execution of the contract. The processing of data is necessary for the  performance of the contract between the parties.

All data requested and processed by FLANKS for the above purposes will be necessary  for the stated purposes. If they are not provided, it will not be possible to  perform the services and administrative tasks related to them.

Legitimate interest: The contact data for your  professional location will be processed on the basis of the legitimate  interest of the company in accordance with art. 19 of the LOPDGDD.

The sending of commercial communications  is based on our legitimate interest due to the existence of a prior  contractual relationship between the parties in accordance with the  electronic commerce regulations (LSSI).

You may unsubscribe from these  commercial communications at any time through the mechanism indicated in each  e-mail or by expressing your wish to unsubscribe by sending an e-mail to suportelgpd@flanks.io.

You can request more information about  the balancing of our legitimate interests by contacting:  suportelgpd@flanks.io.

How long do we keep  your information?

All personal information will be  processed by us for the duration of the contractual relationship between the  parties. At the end of this period, FLANKS will keep this information,  blocked, for the periods provided for by law in order to meet possible liabilities  and to demonstrate compliance with our obligations.

Who do we give your  personal information to?

We do not make any additional transfers  to carry out this processing other than those indicated, in general terms, in  point 4. To whom do we transfer your  personal information? In this regard, we may use service providers for  the provision of certain ancillary services (e.g. management software), who  act as Processors. You will find more information on how these service  providers operate in point 4 above.

3.3.        When you apply for our job vacancies orsend us your CV

What are the data  collection routes?

●       Work with us form

●       Sending  your CV to FLANKS via email or third party platforms (LinkedIn or others)  where job vacancies are posted.

What data do we  collect?    

Identifying and contact  information. We  collect your identification data (name and surname), e-mail address, your  telephone number, as well as your professional data and the data you include  in your CV and/or cover letter that you wish to send us.

What are the purposes  of the processing of your personal data?

Participate in our selection processes. We will process your personal information  in order to carry out the corresponding selection process for possible  recruitment.

Selection processes may involve face-to-face or  remote interviews and/or job-related practical, knowledge or language tests.

We will also use your contact details to keep you  informed about the status of the selection process and your application.

Participate in our selection processes. We will process your personal information to  carry out the corresponding selection process for an eventual recruitment,  including conducting interviews (face-to-face or online), knowledge or  language tests related to the job position. We will also use your contact  details to keep you informed about the status of the selection process and  your application.

If you give us your consent, we will be able to  include your CV in future FLANKS recruitment processes that match your  professional profile.

What is the basis of  legitimacy that allows us to process your data? Is the  provision of this data obligatory?‍

Performance of a contract, implementation of  pre-contractual measures (Article 6(1)(b) of the GDPR). The processing of the data is necessary for  the implementation, at the request of the data subject, of pre-contractual  measures or the intention to conclude a contract.

All data requested and processed by FLANKS for the  above purposes will be necessary for the stated purposes. If they are not  provided, it will not be possible to carry out the tasks associated with  them.

Consent: Where you send us your CV for use without applying  for a specific vacancy and in the event that you allow us to use your CV in  future recruitment processes, we will do so on the basis of your consent, and  we may keep your CV for this purpose.

How long do we keep  your information?

All personal information will be  processed by us for as long as is necessary to manage the recruitment process  for which you have applied or until you ask us to stop processing it. At the  end of this period, FLANKS will keep this information, blocked, for the periods  provided for by law in order to meet any liabilities and to demonstrate  compliance with our obligations.      

Who do we give your  personal information to?    

We do not make any additional transfers  to carry out this processing other than those indicated, in general terms, in  point 4. To whom do we transfer your  personal information? In this regard, some of the channels through which  you can contact us are managed by service providers, who act as Processors.  You will find more information about how these service providers operate in  section 4 above.

3.4.       Website navigation (cookies)

We use cookies or other tracking andtracing tools on this Website to collect information about how users use theWebsite.

For more information on how we treat youthrough these tracking tools, please visit our CookiePolicy.[2]

3.5.       FLANKS social media profiles.

FLANKS has a profile on severalsocial networks, such as LinkedIn.

When you become a follower of anyof our pages on social networks, the processing of data will be governed by theterms of use, privacy policies and access regulations belonging to thecorresponding social network and previously accepted by the user.

FLANKS, in this sense, will processyour data for the purposes of correctly administering its presence on thesocial network, informing you of its activities, products or services, as wellas for any other purpose that the regulations of the social networks allow.

Please note that we have no influence overthe information that the social network collects or how it processes it, so werecommend that you keep yourself informed of the purpose and extent of thecollection of information through these social networks.

4.   TO WHOM DO WE DISCLOSE YOUR PERSONALINFORMATION?

In general, FLANKS will not disclose yourdata to third parties. However, in addition to the transfers that wespecifically indicate in the section in which we explain the characteristics ofthe different operations (point 3), we inform you of the communications that wemay make, in general, and which affect all of the above processing and itslegitimate basis.

i.              Providers of essential services to carry out the service weoffer you (for example, computer hosting companies or platforms for sendingcommercial communications). Notwithstanding the above, these entities havesigned the corresponding confidentiality agreements and will only process yourdata in accordance with our instructions, and may not use them for their ownpurposes or for purposes other than the service they provide us with.

ii.             Public bodies. We maydisclose to the competent public authorities the data and any other informationin our possession or accessible through our systems when there is a legalobligation to do so, as well as when required, for example, when the purpose isto prevent or prosecute abuse of the services or fraudulent activities throughour Website or web page. In such cases, the personal data you provide to uswill be retained and made available to administrative or judicial authorities.[3]

iii.            In the event of a corporate transaction:In the event of a merger,acquisition, sale of all or part of its assets or any other type of corporatetransaction involving a third party, we may share, disclose or transfer userdata to the successor entity (including during the pre-transaction phase).

iv.           To third parties after aggregation oranonymisation: we maydisclose or use aggregated or anonymised data (i.e. data which cannot be linkedto an identified or identifiable natural person) for any purpose.

v.            To third parties with the user's consentor other legitimate basis: In the event that we wish to share data with thirdparties outside the scope of this Privacy Policy, we will always seek theirconsent or inform them of the sharing and its legitimate basis.

We also inform you that this PrivacyPolicy only relates to the collection, processing and use of information(relating to personal data) by us through your interaction with our Website.Access to third party websites that you may access through links from theWebsite have their own privacy policies over which we have no control.Therefore, before you provide them with any personal information, we recommendthat you inform yourself about their privacy policies.

5.   ARE YOUR PERSONAL DATA TRANSFERRED TOTHIRD COUNTRIES OUTSIDE THE ECONOMIC AREA?

Some of our service providers are locatedin countries outside the European Economic Area ("EEA").

The location of these companies outsidethe EEA implies the existence of an international transfer of your personaldata, which could lead to a lower level of protection than that provided for inthe European regulations. However, FLANKS has implemented measures to ensurethat such transfers do not result in a lower level of protection of yourpersonal data.

In this sense, service providers outsidethe EEA have a valid mechanism to be able to carry out international transfers,either they have signed the corresponding standard contractual clauses approvedby the European Commission ("STC"),an agreement signed between both entities by which the non-EU companyguarantees that it applies European data protection standards or they arecompanies certified by the new EU-US Data Privacy Framework (DPF) compliancedecision, or they are companies certified by the new EU-US Data PrivacyFramework (DPF). (Data Privacy Framework orDPF).

Therefore, the use of these providers doesnot result in a lower level of protection of your personal data than the use ofproviders located in the European Union.

You can consult the content of the TCHsand the Decision on compliance with the EU-US Data Privacy Framework. You canfind the content of the TCHs and the EU-US Data Privacy Framework AdequacyDecision at the following links:

→   https://commission.europa.eu/publications/standard-contractual-clauses-controllers-and-processors-eueea_en

→   https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en

The following are the international transfers that we make from FLANKS:

Name, country, Transfer mechanism, Google, LLC (Workspace, Cloud), USA. USA., Data Privacy Framework, Pipedrive, Inc., USA. USA., Data Privacy Framework, GoHire Technologies Limited, United Kingdom, Decision of 28 June 2021

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6.   WHAT ARE THE RIGHTS YOU CAN EXERCISE AS ASTAKEHOLDER?

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You can exercise the rights guaranteed bylaw in relation to the processing of your personal data by contacting our DataProtection Officer by emailing suportelgpd@flanks.io.

Any rights request we receive will bedealt with as soon as possible and in any event within the maximum time limitset by law from the time we receive it. In some cases, we may need to ask youfor a copy of your identity card or other identification document if we need toverify your identity.

Your rights as a stakeholder are asfollows:

i.              Right to withdraw consent

You may withdraw your consent in relationto all processing based on your consent at any time. However, withdrawal ofconsent will not affect the lawfulness of the processing based on the consentprior to its withdrawal.

ii.            Right of access

You have the right to know what data isbeing processed, if any, and, if so, to obtain a copy of it, as well as toobtain information relating to:

●     the originand recipients of the data;

●     thepurposes for which they are processed;

●     whetherthere is an automated decision-making process, including profiling;

●     the data retention period; and

●     the rightsprovided for in the regulations.

iii.           Right of rectification

You have the right to obtain therectification of your personal data or to complete them when they areincomplete.

iv.           Right of suppression

You have the right to request the deletionof your personal data if they are no longer necessary for the purpose for whichthey were collected or, as the case may be, if we are no longer authorised toprocess them.

v.            Right to data portability

You have the right to request dataportability in the case of processing of your data that is based on yourconsent or the performance of a contract, provided that the processing has beencarried out by automated means. In case of exercise of this right, you willreceive your personal data in a structured format, commonly used and readableby any electronic device. However, you may also request, where possible, thatyour data be transferred directly to another company.

vi.           Right to restrict the processing of yourpersonal data

You have the right to limit the processingof your data in the following cases:

a)    When you have requested the rectificationof your personal data during the period in which we verify the accuracy of yourpersonal data.

b)    When you believe that we are notauthorised to process your data. In this case, you can ask us to limit its useinstead of requesting its deletion.

c)    When you consider that it is no longernecessary for us to continue processing your data and you want us to keep themfor the purpose of exercising or defending claims.

d)   Where thereis processing based on our legitimate interest and you have exercised yourright to object to such processing, you may ask us to restrict the use of yourdata during the verification of the prevalence of those interests over yourinterests.

vii.         Right to object

You have the right to object at any timeto the processing of your personal data based on our legitimate interest,including profiling.

Unsubscribe from commercialcommunications: Rememberthat at any time you can object to receiving this type of communication bysending an email to suportelgpd@flanks.io. You may also opt out of this serviceby following the instructions indicated at the bottom of the body of each ofthe electronic communications we send you.

viii.       Right to lodge a complaint with theSupervisory Authority

Remember that, at any time, and in theevent that you consider that we have infringed your right to the protection ofyour data, you may contact the corresponding Control Authority, in the case ofSpain, the Spanish Data Protection Agency (www.aepd.es).

7.   HOW DO WE GUARANTEE THE CONFIDENTIALITY OFYOUR INFORMATION?

The security of your personal data is apriority for us. Therefore, FLANKS has implemented all the necessary securitymeasures to guarantee the effective use and processing of the personal dataprovided by the user, safeguarding the privacy, privacy, confidentiality andintegrity of the same and makes use of the necessary technical means to preventthe alteration, loss, unauthorised access or processing of your data, accordingto the state of technology at all times.

Consequently, we comply with the securitystandards recommended to protect them. However, it is impossible to fullyguarantee their security due to the nature of the Internet and because theremay be malicious acts by third parties beyond our control.

We undertake to act promptly anddiligently in the event that data security is compromised or compromised, andto inform you if relevant.

8.    AMENDMENTS TO THIS POLICY

FLANKS may modify the content of theprivacy policy at any time, especially when there are legislative orjurisprudential modifications or changes in the interpretation of the SpanishData Protection Agency that affect the processing of data carried out by FLANKSthrough this Website. Any new version of this Privacy Policy shall enter intoforce on the published effective date.

We therefore recommend that youperiodically review this Privacy Policy to be informed of how your personaldata is processed and protected, as well as your rights.

This Privacy Policy was amended on 29September 2023.

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WARNING: this must be complied with. After the required retentionperiod has elapsed, if the information is to be stored for the purpose ofproducing FAQs, the personal information MUST BE ANONYMISED.

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