Privacy notice

Who we are

Flinq Limited is a company registered in Jersey with registered number 152668. For the activities described in this notice, Flinq Limited is the data controller unless we are processing personal data only on a client's documented instructions.

You can contact us at [email protected] or at 27 Le Clos de Orange, St Brelade, Jersey JE3 8GU.

What this notice covers

This notice covers Flinq's own use of personal data for our website, business relationships, service administration, security, support and product improvement. Where a client uses Flinq to process information relating to its own clients, counterparties, employees or other individuals, that client will normally determine why the data is used and Flinq will act as its processor under the relevant agreement. The client's own privacy information will apply to that processing.

Personal data we may collect

• Identity and business details: name, job title, employer, office and professional contact details.
• Enquiry and relationship information: messages, meeting notes, preferences and correspondence with us.
• Account and access information: username, organisation, permissions, authentication events and account settings.
• Technical and usage information: IP address, browser and device information, service activity, diagnostic records and security logs.
• Support information: support requests, feedback and information supplied to investigate or resolve an issue.
• Service content: personal data contained in documents, payment or banking records, counterparty information and other records submitted to Flinq, where relevant to the service and subject to the client's instructions.
• Cookie and preference information: consent choices and information collected through technologies described below.

We normally receive personal data directly from you, from the organisation that has authorised your use of Flinq, from systems or service providers used to deliver the service, or from public and professional sources where appropriate.

Why we use personal data

Where we rely on legitimate interests, we consider whether the use is necessary and whether your rights and interests require additional safeguards. Where we rely on consent, you may withdraw it at any time without affecting earlier lawful processing.

Cookies and website services

Our website uses CookieYes to record and manage cookie choices. The contact form is delivered using Formspree and may use Google reCAPTCHA to help detect abuse. Google Fonts and jsDelivr help deliver fonts and website scripts. These services may receive technical information such as your IP address, browser details and the page requested. Non-essential technologies will be used in accordance with the choices available through our consent mechanism.

You can also control cookies through your browser. Blocking necessary cookies may affect how parts of the website operate.

Who we share personal data with

We may share personal data, where necessary, with:

• hosting, infrastructure, security, communications, support and other technology providers;
• the organisation that has authorised your access to Flinq;
• banks, integration providers or other recipients where required to provide a client-configured service;
• professional advisers, auditors and insurers;
• regulators, courts, law-enforcement bodies or other authorities where required or permitted by law; and
• a prospective buyer, investor or successor in connection with a genuine corporate transaction, subject to appropriate confidentiality protections.

Service providers acting for us are required to handle personal data under appropriate contractual and security obligations.

International transfers

Some providers or recipients may process personal data outside Jersey or the European Economic Area. Where required, we use an approved transfer mechanism or another lawful safeguard and assess the protections that apply. You may contact us for further information about the safeguards relevant to your personal data.

Retention

We keep personal data only for as long as it is reasonably needed for the purpose for which it was collected, including to provide and secure the service, maintain appropriate business and audit records, meet legal or contractual requirements, and resolve disputes. The period varies according to the type of record, the client agreement, the sensitivity of the information, security needs and applicable limitation or regulatory periods. We delete or anonymise information when it is no longer required, subject to lawful preservation requirements.

AI-assisted functionality and automated decisions

Where AI-assisted functionality is enabled for a client, it is intended to help authorised users understand information, identify matters for review or prepare a next step. Availability, data use and controls are governed by the applicable client arrangements and product notices. Flinq does not use the website or its AI-assisted functionality to make solely automated decisions about individuals that produce legal or similarly significant effects.

Security

We use organisational and technical measures designed to protect personal data against unauthorised access, loss, alteration or disclosure. No online service can guarantee absolute security, and users should protect their credentials and notify us promptly if they suspect unauthorised access.

Your rights

Depending on the circumstances, the Data Protection (Jersey) Law 2018 gives you rights to be informed, request access, correct inaccurate data, request erasure or restriction, receive certain data in a portable format, object to particular processing, and withdraw consent where consent is the basis used. These rights are not absolute and exemptions may apply.

To exercise a right, contact [email protected]. We may need to confirm your identity and clarify the information concerned. If you are an authorised user whose organisation controls the relevant data, we may refer the request to that organisation.

You may also raise a concern with the Jersey Office of the Information Commissioner.

Children

Our website and services are intended for business users and are not directed at children. We do not knowingly invite children to create accounts or submit enquiries.

Changes to this notice

We may update this notice when our services, providers or legal obligations change. We will publish the current version here and update the date above. Where a change materially affects an existing service relationship, we will provide any additional notice required by the applicable agreement or law.