Privacy Policy

Flanks’ commitment to data privacy

At SPLIT PAYMENTS, S.L. (referred as to “Flanks”, “we”, “our”, or “us”) 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, this Privacy Policy informs users of our website flanks.io (the “Website”) and any other services or platforms (the “Services”) displaying this Privacy Policy about the collection and processing of their personal data, in compliance with the European General Data Protection Regulation (hereinafter, “GDPR”).

Flanks controls the personal data that we collect for our own requirements, to comply with legal requirements, performance of a contract, or where you contact us directly via email or as a recruitment candidate. When Flanks collects personal data from our Clients, Resellers or from a Financial Institution we will process that data according to the instructions of the data controller/processor and/or according to our legal processing rights and/or your consent.

If you transfer third party personal data to us, this Privacy Policy will apply to that data and you are responsible for informing those third parties that this notice will apply to their personal data and for collecting and recording their consent where necessary.

For any questions regarding the processing of your personal data, please feel free to contact us via email at suportelgpd@flanks.io. 

Table of Contents

This Privacy Policy descrives the measures we take to safeguard personal information, the parties with whom we may share the information, and the choices available regarding our use of the personal information. Specifically, it includes details about:

• Who is responsible for processing your data.
• The requirements for providing your personal data.
• The data processing activities we carry out and their main characteristics, including:
  
  • The types of data we collect and how we collect it.
  • The purposes for which we collect your data.
  • The legal basis for processing your data.
  • How long we retain your data.
  • The recipients to whom your data may be disclosed.
  • Whether international transfers of your data occur.
• Your rights and how to exercise them.
• How we protect your personal information.
• Updates 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 VAT Number ESB67332775 and whose contact details are as follows:

• Address: 157 Tarragona Street, 16th floor, Barcelona 08014, Spain
• Contact telephone number: (+34) 930 40 05 44

Our data protection officer’s can be contacted at suportelgpd@flanks.io. 

2. Requirements for Providing Your Personal Data

• Minimum Age: To provide us with your personal data, you must be at least 18 years old and/or possess sufficient legal capacity to use this Website or the Services.
• Truthfulness: By providing your data to use our Website or our Services, you guarantee that the information is accurate, truthful, up-to-date, and belongs to you, not third parties. You must also notify us of any changes to the data provided. You are solely responsible for ensuring the accuracy and authenticity of your data at all times.
• Age and Data Verification: We reserve the right to verify your age and identity at any time, if necessary. This may include requesting official proof of age or using equivalent procedures. If we detect or suspect fraud or determine that you are under the required age, we may delete, temporarily disable, or terminate your account.

3. What Data Processing Do We Carry Out and What Are Its Main Characteristics?

Below, we outline how we handle your personal data and provide detailed information about your privacy:

3.1 When You Contact Us Through Our Communication Channels (Contact Form or Email)

• How Do We Collect Your Data?
  
  • Through the contact form at https://www.flanks.io/contact. 
  • By sending emails to our designated email addresses.
• What Data Do We Collect?
  
  • Identifying and Contact Information: We collect your name, surname, email address, telephone number, and the name of the company you represent. Additionally, we may collect any other information you voluntarily provide in your communications.
  • Additional Information: In certain cases, we may request further information to address your request or fulfill specific requirements.
• What Are the Purposes of Processing Your Personal Data?

• To Respond to Your Requests: The primary purpose of processing your data is to respond to your inquiries, address your concerns, and provide you with the requested information. Additionally, we may follow up on your requests as needed.
• To Improve Customer Service: The information obtained from inquiries, questions, and feedback helps us evaluate the quality of our customer service. This enables us to enhance our support processes and improve the overall customer experience.
• For Analytical and Statistical Purposes: Once the retention period described below has expired, we anonymize all collected information. This anonymized data is used to analyze frequently asked questions, automate responses, develop FAQs, and support statistical and commercial strategy development.

• What Is the Basis of Legitimacy for Processing Your Data? Is the Provision of This Data Mandatory?
  
  • Consent: The processing of your personal data for the purposes outlined above is based on your explicit consent, which you provide when voluntarily contacting us through the channels made available to request information or submit a query.
  • Legitimate Interest: Information gathered by our customer service team is processed for statistical purposes to enhance the quality of our services. You can request further details about the assessment of our legitimate interests by contacting us at suportelgpd@flanks.io. 
  • Mandatory Information: Required fields are marked with an asterisk (*) or a similar indicator. Without providing this information, we may not be able to address your inquiries or fulfill your requests.

• How Long Do We Retain Your Information?

We will process your personal data for as long as is necessary to handle your requests and, if applicable, follow up on them. Once this period ends, Flanks will retain your information in a blocked state, solely for the duration required by law to address potential liabilities and demonstrate compliance with legal obligations.

After this retention period, your data will be processed in an anonymized format, making it impossible to link statistical information to specific users.

• Who Do We Share Your Personal Data With?

We do not transfer your personal data to third parties for purposes other than those stated in Section 4 (“Who Do We Transfer Your Personal Data To?”).

Some communication channels, such as the contact form or email services, may be managed by service providers acting as Data Processors. You can find additional details about these service providers and their operations in Section 4 above.

3.2. If you are an employee, officer, representative, contractor, sub-contractor or adviser of a Client (“Client Representative”) or you are an ultimate beneficial owner of a Client.

• How Do We Collect Your Data?

We collect your data when you establish a commercial or contractual relationship with Flanks (e.g., by signing contracts, receiving quotations, or engaging in commercial communications).

• What Data Do We Collect?
  
  • Identifying and Contact Information: We collect your name, surname, email address, professional postal address, telephone number, and any other information relevant to the commercial or contractual relationship.
  • Employment Details: During the contractual relationship, we may collect information about the contact person representing the client company, such as their name, surname, professional email address, job title, and/or department.
• What Are the Purposes of Processing Your Personal Data?

• Commercial Contact: In the absence of a contractual relationship, your data will be processed solely to maintain communication with the legal entity for which you provide services.
• Performance and Maintenance of the Contractual Relationship: If a contractual relationship exists, the primary purpose of processing your data is to execute and maintain the contractual obligations between the parties. This includes:
  
  • Administrative, fiscal, legal, accounting, and commercial management of Client’s data.
  • Comply with related legal obligations including background checks and verification of our Clients for Client on-boarding and maintenance.
  • Preparing and sending estimates.
  • Performing the Services as agreed.
  • Responding to inquiries and handling complaints through various channels, including web, telephone, email, or in person.
  • Scheduling meetings and Client visits.
• Sending Publications and Commercial Communications: We may send newsletters and other commercial communications related to our products and services electronically.

• What Is the Basis of Legitimacy for Processing Your Data? Is the Provision of This Data Mandatory?
  
  • Execution of a Contract: The processing of your data is necessary to fulfill the contract between the parties. All data requested and processed by Flanks for the purposes outlined above is essential to achieve those purposes. Failure to provide this data will make it impossible to perform the Services or related administrative tasks.
  • Legitimate Interest: We process your professional contact details based on our legitimate interest in making changes to our platform to improve and further develop our service offering, as permitted under Article 6 of the GDPR. The sending of commercial communications is also based on our legitimate interest, supported by the existence of a prior contractual relationship, in accordance with the European Directive on electronic commerce.
  • Unsubscribing from Commercial Communications: You may unsubscribe from commercial communications at any time by using the mechanism provided in each email or by contacting us directly at suportelgpd@flanks.io.
  • Requesting Information About Legitimate Interest: If you would like more details about the balancing of our legitimate interests, you can contact us at suportelgpd@flanks.io.

• How Long Do We Retain Your Information?

We will process your personal data for the duration of the contractual relationship between the parties. Once this relationship ends, Flanks will retain your data in a restricted or "blocked" state for the period required by applicable laws. This retention ensures we can address potential liabilities and demonstrate compliance with legal obligations.

• Who Do We Share Your Personal Data With?

We do not transfer your personal data to third parties for purposes other than those stated in Section 4 (“Who Do We Transfer Your Personal Data To?”).

Some communication channels, such as the contact form or email services, may be managed by service providers acting as Data Processors. You can find additional details about these service providers and their operations in Section 4.

3.3. If you are the end-user of Flanks’ Services.

• How Do We Collect Your Data?
  
  • From our Clients: : We initially collect your personal data through a contractual agreement with our Clients. In  these cases, we act as a Data Processor, obtaining the necessary information to provide Flanks' Services to you through our Clients with whom you maintain a contractual relationship. 
  • From you: Some information is collected directly from you, including details required to communicate with your bank or other service providers, as well as identity and address information needed to deliver our Services. Additionally, we may collect information necessary to fulfill our legal obligations, such as compliance with anti-money laundering regulations. 
  • From your bank (the “Financial Institution”):  To deliver our Services, we may collect information from your Financial Institution, such as bank account details, account transactions, and other financial data. This information is only collected with your explicit consent. 
• What Data Do We Collect?
  
  • Identifying and Contact Information: Name, surname, email address, telephone number, and other information relevant to providing the Services.
  • Account Data: Sort code/account number, IBAN, SWIFT, account name, nickname, type, balance, currency.
  • Transaction Data: Transaction ID, amount, currency, reference, and other transaction details.
  • Verification Data: Information required by your Financial Institution for verification purposes, which may include your online user credentials.
• What Are the Purposes of Processing Your Personal Data?+

We process your personal data to:

• Perform a contract with you or our Client.
• Comply with legal obligations, including fraud prevention, anti-money laundering requirements, and verification checks.
• Fulfill our contractual obligations to you or our Client by facilitating access to account information.
• Advance our legitimate interest in ensuring the effective performance of our agreements.
• Enhance and develop our Services by making improvements to our platform

• What Is the Basis of Legitimacy for Processing Your Data? Is the Provision of This Data Mandatory?
  
  • Execution of a Contract: Processing your data is essential to fulfill the contract with you or our Client. Failure to provide the required data will prevent us from delivering the Services or completing related administrative tasks.
  • Legitimate Interest: We process your personal contact details based on our legitimate interest in making changes to our platform to improve and further develop our service offering, as permitted under Article 6 of the GDPR.

• How Long Do We Retain Your Information?

We will process your personal data for the duration of the contractual relationship between the parties. Once this relationship ends, Flanks will retain your data in a restricted or "blocked" state for the period required by applicable laws. This retention ensures we can address potential liabilities and demonstrate compliance with legal obligations.

• Who Do We Share Your Personal Data With?

We do not transfer your personal data to third parties for purposes other than those stated in Section 4 (“Who Do We Transfer Your Personal Data To?”).

Some communication channels, such as the contact form or email services, may be managed by service providers acting as Data Processors. You can find additional details about these service providers and their operations in Section 4.

3.4. When you apply for our job vacancies or send us your CV

• How Do We Collect Your Data?
  
  • Through the "Careers" form available at https://flanks.teamtailor.com/connect.
  • By receiving your CV via third-party platforms (e.g., LinkedIn or similar) where job vacancies are posted.
• What Data Do We Collect?
  
  • Identifying and Contact Information: Your name, surname, email address, and telephone number.
  • Professional and Application Information: Details included in your CV, cover letter, or any additional information you voluntarily provide in connection with the application process.
• What Are the Purposes of Processing Your Personal Data?
  
  • Participation in Selection Processes:
    We process your personal data to conduct selection processes for potential recruitment. This includes activities such as:
    
    • Reviewing applications and conducting interviews (face-to-face or online).
    • Administering knowledge or language tests relevant to the job position.
    • Using your contact details to keep you informed about the status of the selection process and your application.
  • Future Recruitment Opportunities:
    With your consent, we may retain your CV to consider you for future recruitment processes that match your professional profile.

• What Is the Basis of Legitimacy for Processing Your Data? Is the Provision of This Data Mandatory?
  
  • Performance of a Contract or Pre-Contractual Measures (Article 6(1)(b) of the GDPR): The processing of your data is necessary to take pre-contractual measures at your request or to conclude a contract. All requested data is essential for the stated purposes, and without it, we will not be able to process your application.
  • Consent: If you send us your CV without applying for a specific vacancy or agree to allow us to use your CV for future recruitment processes, we will process your data based on your explicit consent.

• How Long Do We Retain Your Information?

We will process your personal data for as long as necessary to manage the recruitment process for which you have applied or until you request its deletion. After this period, Flanks will retain the data in a blocked state for the legally required time to address any potential liabilities or demonstrate compliance with applicable obligations.

• Who Do We Share Your Personal Data With?

We do not share your personal data beyond the disclosures outlined in Section 4 ("Who Do We Transfer Your Personal Data To?"). However, some channels through which you contact us (e.g., job platforms) are managed by third-party service providers acting as processors. You can find additional details on how these processors operate in Section 4.

3.5. Website navigation (cookies)

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

For more information on how we treat youthrough these tracking tools, please visit our Cookies Policy.

3.6. Flanks’ Social Media Profiles

Flanks maintains profiles on various social networks, such as LinkedIn and YouTube.

When you choose to follow any of our social media pages, the processing of your personal data will be governed by the terms of use, privacy policies, and access regulations of the corresponding social network, as accepted by you when registering on that platform.

In this context, Flanks processes your personal data to:

• Administer and manage its presence on the social network.
• Inform you about its activities, products, or services.
• Fulfill any other purposes permitted by the social network's regulations.

Please note that Flanks has no control over the data collected or processed by the social network itself. We strongly encourage you to review the privacy policies of the social networks you use to understand their data collection practices, purposes, and processing methods.

4. Who Do We Transfer Your Personal Data To?

As a general rule, Flanks does not disclose your personal data to third parties. However, in addition to the specific transfers mentioned in the sections outlining the various data processing activities (see Section 3), we may make the following disclosures where necessary:

1. Service Providers: We may share your data with providers that deliver essential services to facilitate the functionality of our offerings (e.g., cloud hosting companies, email distribution platforms). These entities operate as data processors or sub-processors, bound by confidentiality agreements, and process your data strictly under our instructions. They are prohibited from using your data for their own purposes or for purposes outside the scope of the services provided.
2. Public Authorities: We may share your data with competent public authorities when legally required, such as for the prevention or prosecution of fraud, abuse of services, or other unlawful activities. This includes making personal data available to administrative or judicial authorities upon request or in compliance with legal obligations.
3. Corporate Transactions: In the event of a merger, acquisition, sale of assets, or similar corporate transaction involving a third party, your data may be transferred to the successor entity as part of the transaction. This includes during the pre-transaction review phase.
4. Aggregated or Anonymized Data: We may disclose aggregated or anonymized data (which cannot be used to identify you) for research, statistical, or any other purpose.
5. With Your Consent or Other Legitimate Basis: If we wish to share your personal data with third parties outside the scope of this Privacy Policy, we will seek your explicit consent or rely on another legitimate legal basis for the transfer.

Important Note:
This Privacy Policy applies solely to the collection, processing, and use of your personal data by Flanks when you interact with our Website or when you use our Services. If you access third-party websites through links on our Website or on our Services’ platform, please note that these third parties operate independently and have their own privacy policies. We recommend reviewing these policies before sharing any personal data with them.

5. Are Your Personal Data Transferred to Third Countries Outside the European Economic Area (EEA)?

Some of our service providers are located outside the European Economic Area (EEA), which involves an international transfer of your personal data. This may potentially entail a level of data protection lower than that provided within the EEA under European regulations.

To address this, Flanks has implemented measures to ensure that these transfers maintain an equivalent level of data protection. Specifically:

• Standard Contractual Clauses (SCCs): These clauses, approved by the European Commission, are signed with non-EEA service providers, ensuring compliance with EU data protection standards.
• EU-US Data Privacy Framework (DPF): Providers certified under this framework guarantee a level of data protection equivalent to EU standards.
• Adequacy Decisions: For certain countries, such as the United Kingdom, the European Commission has determined that they provide an adequate level of protection.

The use of these mechanisms ensures that international transfers do not compromise the protection of your personal data compared to using providers within the EEA.

If you want more information about the cases in which your personal data is transferred outside the EU/EEA you can contact us at suportelgpd@flanks.io. 

6. What Are Your Rights as a Data Subject?

You have the right to exercise the following data protection rights in relation to the processing of your personal data. To do so, please contact our Data Protection Officer at suportelgpd@flanks.io.

Your request will be handled promptly and, in any case, within the maximum timeframe established by law. In some cases, we may ask for a copy of your ID or another identification document to verify your identity.

i. Right to Withdraw Consent

You may withdraw your consent at any time for processing activities based on your consent. However, withdrawal will not affect the lawfulness of any processing carried out before your consent was withdrawn.

ii. Right of Access

You have the right to access the personal data we process about you, as well as to request a copy of this data. Additionally, you can obtain information about:

• The origin and recipients of your data.
• The purposes of processing.
• Any automated decision-making, including profiling.
• The retention periods for your data.
• The rights available to you under the applicable regulations.

iii. Right to Rectification

You can request the correction of inaccurate personal data or the completion of incomplete data.

iv. Right to Erasure

You can request the deletion of your personal data when:

• It is no longer necessary for the purpose for which it was collected.
• You withdraw your consent, and no other legal basis exists for processing.
• Processing is unlawful.

v. Right to Data Portability

If your data is processed based on your consent or a contract and through automated means, you can request to:

• Receive your data in a structured, commonly used, and machine-readable format.
• Have your data transferred directly to another entity where technically feasible.

vi. Right to Restriction of Processing

1. You can request the restriction of processing in the following cases:
   While we verify the accuracy of your data after you request rectification.
2. When you believe the processing is unlawful but prefer restriction over deletion.
3. If we no longer need your data, but you require it to establish, exercise, or defend legal claims.
4. When you object to processing based on our legitimate interest while we verify whether our interest overrides yours.

vii. Right to Object

You may object to the processing of your personal data based on our legitimate interests, including profiling.

• Unsubscribing from Commercial Communications:
  You can object to receiving commercial communications at any time by:
  
  • Sending an email to suportelgpd@flanks.io.
  • Clicking the unsubscribe link included in the footer of every email, in case of receiving communication by this means.

viii. Right to Lodge a Complaint with a Supervisory Authority

If you believe your data protection rights have been infringed, you may lodge a complaint with the relevant supervisory authority. In Spain, this is the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD) (www.aepd.es).

7. How Do We Guarantee the Confidentiality of Your Information?

The security of your personal data is a top priority for Flanks. To this end, we have implemented robust security measures designed to ensure the safe and effective processing of the personal data you provide. These measures safeguard the privacy, confidentiality, and integrity of your information and leverage state-of-the-art technology to prevent unauthorized access, alteration, loss, or processing of your data.

We strictly adhere to recommended security standards to protect your information. However, given the nature of the Internet and the potential for malicious acts beyond our control, absolute security cannot be guaranteed.

In the event of a security breach that compromises your personal data, Flanks is committed to taking swift and diligent action. Where required, we will notify you promptly of any relevant incidents and the measures taken to address them.

8. Updates to this Privacy Policy

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

We encourage you to regularly check the current version which will be available at our Website.