At FlexValy, we value your privacy and are committed to safeguarding your personal information. This Privacy Policy describes how we collect, use, store, and protect your personal data in accordance with applicable privacy laws. Please take the time to read through this policy to understand our practices and your rights regarding your data.

Table of contents

1. Types of Personal Information We Collect and How We Collect It: We collect various types of personal information to offer and enhance our services, including:

• Identity Details: Full name, email address, phone number, and any other identifying details.
• Payment and Billing Data: Details about account transactions, payment methods, billing information, and related financial records.
• Technical Data: IP address, browser type, device details, operating system, and usage patterns.
• Usage Activity: Data on how you interact with our website and services, including clicks, views, and order history.
• Communication Records: Emails, phone calls, and chat logs when you contact customer support.
• Marketing Choices: Your preferences for receiving promotional content or updates.
• Support Case Information: Details about your inquiries, any follow-up actions, and the content of your communications (including chats and call recordings).
• Cookies and Tracking Data: As described in our Cookies Policy, we use cookies to monitor your website interactions and improve your experience.

We gather personal data through a variety of methods:
• Direct Input: When you create an account, make a purchase, subscribe to newsletters, or contact customer support.
• Automated Tools: Cookies and similar technologies that collect data about your browsing habits and usage patterns.
• Third-Party Sources: Social media platforms, public databases, and trusted partners that help us supplement and verify the information we hold.

2. Data Controller and How We Use Your Personal Data: Under the GDPR, FlexValy primarily acts as a Data Controller, meaning we determine how your personal information is used and are responsible for protecting it. In some cases, we may act as a Data Processor on behalf of another controller (for example, when handling specific logs or information submitted through integrated services). In those situations, we follow the controller’s instructions and apply strict safeguards to keep your data secure.

You are entitled to certain protections regarding your personal data under applicable EU law. We handle and process personal information, including electronic communications, in accordance with the GDPR (EU 2016/679) and the ePrivacy Directive (2002/58/EC), which establish requirements for the collection, usage, storage, security, and management of personal data and cookies or similar technologies.

We use your personal data primarily for the following purposes:
• Account Management: To provide you with access to our services, manage your profile, and maintain your Membership.
• Transactions: To process payments, complete purchases, and handle billing or account-related issues.
• Customer Service: To respond to your inquiries, resolve issues, and provide support.
• Improvement of Services: To analyse usage data so we can improve our website, apps, and overall services, and to tailor content and features to your needs.
• Marketing and Promotions: To send offers, newsletters, or updates, where you have given consent or where otherwise permitted by law.
• Legal and Compliance: To comply with legal obligations, protect our legal interests, prevent fraud, and safeguard the rights and security of FlexValy and its users.

We will not use your data for purposes outside those described in this Privacy Policy unless required by law or with your explicit consent.

3. Data Security and Retention: FlexValy protects your personal data through suitable technical and organizational security measures against loss, unauthorized access, misuse, alteration, or disclosure. All payment transactions are encrypted, and the service adheres to PCI security standards for confidentiality where applicable. You accept that your personal data may be processed and stored outside the European Economic Area, in which case we ensure appropriate safeguards are in place in line with data protection laws.

Our security measures include, among others:
• Encryption: Data, particularly payment information, is encrypted during transmission to help ensure confidentiality.
• Access Controls: Only authorized staff and service providers, bound by confidentiality obligations, can access your personal information.
• Secure Storage: Your data is stored in secure, access-controlled environments designed to prevent unauthorized access, destruction, or alteration.

We retain your data only for as long as necessary for the purposes described in this Privacy Policy or as required by law. Once your data is no longer needed, we take appropriate steps to securely delete or anonymize it in accordance with our data retention policies and legal obligations.

You are entitled to certain protections regarding your personal data under applicable EU law. FlexValy acts as the Data Controller for most processing activities and handles personal information, including electronic communications, in accordance with the GDPR and the ePrivacy Directive.

4. Sharing and Disclosure of Personal Data: We may share your personal data with third parties in limited circumstances, including:

• Service Providers: Trusted providers that help us operate our services, such as payment processors, IT and hosting providers, analytics tools, and customer support platforms. These parties may only use your data to perform services on our behalf and are required to protect it.
• Legal Requirements: Where necessary to comply with laws, regulations, legal processes, or governmental requests, or to protect our legal rights, enforce our terms, or safeguard our users and the public.
• With Your Consent: In cases where you explicitly agree to share your data, for example with business partners for promotional offers or joint services.

We do not sell your personal data, and we do not permit our service providers to use your data for their own marketing purposes without your consent.

5. Your Rights Regarding Your Data: Under applicable data protection laws, including the GDPR where relevant, you have a number of rights in relation to your personal data. Subject to certain conditions and legal requirements, these may include:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectify: Ask us to correct any inaccurate or incomplete information.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected or where you withdraw consent and no other legal basis applies.
• Right to Object: Object to certain types of processing, such as direct marketing or processing based on legitimate interests.
• Right to Restrict Processing: Ask us to limit the processing of your data in specific situations.
• Right to Data Portability: Request that we provide your personal data in a structured, commonly used, and machine-readable format, and transfer it to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you can withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal.

To exercise these rights or obtain more details, you may contact us at [email protected] or use the tools available in your account settings (where applicable). You also have the right to lodge a complaint with a competent data protection authority if you believe your rights have been infringed.

6. Changes to This Privacy Policy: This Privacy Policy may be updated periodically to reflect changes in our practices, legal requirements, or technical developments. Any updates will be posted on our website, and the revised policy will indicate the latest update date. Where required by law, we will notify you of significant changes in an appropriate manner, such as by email or a prominent notice within FlexValy.

7. Modifications and Contact us: If you continue to use FlexValy after changes to this Privacy Policy have been published, this will constitute your acceptance of the updated terms. If you do not agree with the changes, you may cancel your Membership or stop using our services.

We also welcome your feedback and suggestions. By providing them, you agree that FlexValy may use your input to improve our offerings, enhance security, prevent fraud, and comply with applicable legal standards.

If you have any questions or concerns about this Privacy Policy or how your data is being used, please contact us at:
• Email: [email protected]
• Phone: +35722272252 (Mon–Fri, 08:00–23:00 GMT+2)
• Postal address: VALYSIS TRADING LTD Patmou 13, Engomi 2416, Nicosia Cyprus