Privacy policy

This website is owned and operated by Flychain, Inc. (“Flychain”). We at Flychain respect and protect the privacy of visitors to our websites, and the privacy of our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content located on this website, or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”) or third party applications relying on API, and related services (referred to collectively hereinafter as “Services”). This Privacy Policy applies to the information we collect through the Flychain websites and otherwise. Your use of the Flychain websites and our services is subject to this Privacy Policy and the Terms of Use. Please know that the Terms of Use contain a binding arbitration clause and class action waiver that impact your rights about resolving disputes. If you live in the United States, such provisions are binding on both you and Flychain. Please read the arbitration clause and class action waiver contained in the Terms of Use carefully. If you disagree or area uncomfortable with the Terms of Use, or this Privacy Policy, please discontinue your use of our website and related services, otherwise, you will have assented to our continued adherence to this Privacy Policy and the Terms of Use.

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit an email detailing your questions or concerns to jaime@flychain.us.

This website, and all other Flychain websites (collectively, the “Websites”) are general audience sites and we do not knowingly collect personal, or other, information from children under the age of 18. If you are under the age of 18, please do not use our site. If we suspect that information provided to us is, in fact, personal information of an individual younger than 18 years of age, such information will be deleted, aggregated, or anonymized as soon as possible. Please notify us if you know of any individuals under the age of 18 using our services so we can take action to prevent access to our services. We respect and value the privacy of our clients and have developed this Privacy Policy to demonstrate our commitment to protecting your privacy. This policy describes and sets forth our policies on the following topics:

1. Acceptance of this Privacy Policy
2. Information and Data
3. How we collect your information
4. How we use your information
5. Disclosure of your information to third-parties
6. Third Party Sites and Services
7. Updating, Accessing, and storing your information
8. Privacy Rights
9. California Specific Privacy Rights
10. Security
11. Choice/Opt-out
12. Information obtained from third-parties
13. Special Notice to California Residents
14. Special Notice to Vermont Residents
15. Changes to this Privacy Policy
16. Notification of Privacy Policy changes
17. Contact information

1. Acceptance of this Privacy Policy

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

2. Information and Data

Personal information is data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

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A. Information you provide to us:

To establish an account and access our Services, we’ll ask you to provide us with some important information about you. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide at least three (3) months of bank statements), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information. Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us. Any information you provide to us that is not required is voluntary.

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B. Information we collect:

• Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, IP Address, social security number, and/or email.
• Formal Identification Information: Government issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial, consumer protection, and commercial lending laws.
• Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
• Financial Information: Bank account information, Tax return information, Federal and State Tax ID, Profit and Loss Statements, Average monthly sales revenue, Income statements, Credit Score, Business Invoices, and Wire Instructions.
• Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
• Employment Information: Office location, job title, and/or description of role.Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
• Correspondence: Survey responses, information provided to our support team or user research team.
• Business Information: Business legal entity, NAICS code, business description, list of officers, members, or managers of the business, articles of incorporation, certificates of good standing, ownership structure (including percentage of ownership of each owner), number of employees, date of incorporation, primary business address, PO box address, state of incorporation, legal business name and business website.
• Funding information: Requested funding amount, purpose of funding, funder name and balance of all current outstanding working capital loans.

The documents and information collected are securely stored and safeguarded. At your request and with your permission, these documents may be shared with certain lenders.Under no circumstances will we disclose, transmit, or share in any way, these documents without your permission.

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C. Information we collect from you automatically

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We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

• Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

• How you came to and use the Services;
• Device type and unique device identification numbers;
• Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
• How your device interacts with our Sites and Services, including pages accessed and links clicked;
• Broad geographic location (e.g. country or city-level location); and, other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third-party site.

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D. Information collected from third parties

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include:

• Public Databases & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law.
• Credit Bureaus: With your consent, we obtain information from credit bureaus, including your credit report. However, we will not disclose your credit report without your explicit permission. We obtain your credit information to better provide services to you, to match you with appropriate lenders, to ensure your identity, and to avoid fraud.
• Financial Institution: With your consent, we obtain information directly from your financial institution, including copies of your account statements. We obtain this information to assist in providing Services to you, including the underwriting process. To do this, we utilize Finicity and Ocrolus. Finicity’s privacy policy, available at https://www.finicity.com/privacy/ describes its collection and use of personal data. Ocrolus’s privacy policy, available at https://www.ocrolus.com/privacy-policy/, describes its collection and use of personal data.
• Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you
• Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation.

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E. Data Anonymization and Data Aggregation

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Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).

Flychain may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.

Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators. Moreover, should you request that your information be deleted in accordance with the policies set forth more fully below, your information will be anonymized or aggregated, which complies with applicable law regarding deletion of personal information.

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3. How we collect your information

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• Log Files: Any time you visit any of our websites, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This gives us an idea of which parts of our site users are visiting. We do not share the log files externally.
• Cookies: We use “cookies” to keep track of some types of information while you are visiting our website or using our services. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to our website and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track user trends. We rely on cookies for the proper operation of our website; therefore if your browser is set to reject all cookies, the website will not function properly. Users who refuse cookies assume all responsibility for any resulting loss of functionality. We do not link the cookies to any personally identifiable information.
• Web Beacons: ”Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers. We do not link the web beacons to any personally identifiable information.
• Sign-Up Information: To process sign-ups, we may require your name, address, phone number, email address and other personal information. Such information is used primarily to process your order or as otherwise described herein. This is information you provide to us.
• Application: To access our services, we require your name, address, phone number, email address, and other personal information. We also require the name of your business, its address, its federal and state tax ID, the type of business, business location, average monthly sales, state of incorporation, name of Landlord (if applicable), credit card transactions per month, purpose of the loan, and current outstanding loans.
• Emails and Telephone Calls: We require an email address from you when you register for our services. We use your email for both transactional (e.g., order confirmation, refund and renewal processing) and promotional (e.g., newsletters, new product offerings, special discounts, event notifications, special third-party offers) purposes. Email messages we send you may contain code that enables our database to track your usage of the emails, including whether the email was opened and what links (if any) were clicked. If you would rather not receive promotional emails from us, please see the section below labeled “Choice/Opt-Out”. We reserve the right to send you certain communications relating to the Flychain services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. We may also contact you by telephone or text message (including to any wireless number you may provide to us) solely in connection with Flychain’s services. If you would rather not receive telephone calls or text messages from us, you may change or delete your number from your account preferences page(s), or ask to be removed from our contact list if you receive a call or text message from us. We fully comply with the requirements of the U.S. CAN-SPAM Act.
• Other Sources. We may obtain information about you from third parties such as credit reports. We do not pull a credit report without your permission.

4. How we use your information

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.

We may use this information in the following ways:

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1. To maintain legal and regulatory compliance

Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Flychain must identify and verify customers using our Services in order to comply with commercial lending laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your Flychain Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we reserve the right to close your account.

2. To enforce our terms in our user agreement and other agreements

Flychain handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services.

3. To detect and prevent fraud

We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or information loss.

4. To provide Flychain’s Services

We process your personal information to provide the Services to you. For example, when you wish to seek a loan from one of our lending partners, we require certain information such as your identification, contact information, and income information. We cannot provide you with Services without such information.

5. To provide Service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

6. To provide customer service

We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

7. To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services.

8. To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

9. For research and development purposes

We process your personal information to better understand the way you use and interact with Flychain’s Services. In addition, we use such information to customize, measure, and improve Flychain’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

10. To enhance your experience

We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

11. To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.

12. To engage in marketing activities

Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.

13. For any purpose

We may disclose your personal information for any purpose you consent to. The following chart summarizes how we use the categories of personal information we collect from consumers:

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