CCPA NOTICE

Last Amended: October 10th, 2023

APPLICABILITY:

Pursuant with the California Consumer Privacy Act of 2018 as amended and revised by the California Privacy Rights Act of 2020 (collectively “CCPA”), and any other California privacy laws, this CCPA Notice applies to FlexCorp Inc. (“Flex”) Website Visitors and Merchants who are California residents (“consumers” or “you”). This CCPA Notice is an integral part of Flex Privacy Policy, and thus, definitions used herein but not defined herein or under the CCPA shall have the same meaning as defined in the Privacy Policy.

This CCPA Notice applies to consumers Personal Information (as defined below), including employee and business-to-business Personal Information.

PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

(A) CATEGORIES OF PERSONAL INFORMATION FLEX COLLECTS

Flex collects Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.

Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below.

Personal Information does not include: publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information and additional information which is excluded from the CCPA’s scope, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Flex has collected the following categories of personal information within the last twelve (12) months:

(B) CATEGORIES OF SOURCES OF PERSONAL INFORMATION

(D) Information we receive from third parties - for example, when we receive KYC Data from credit bureaus.

(E) Information we receive automatically – certain Usage Data or Behavioral Data which we receive through third-party tools.

(F) USE OF PERSONAL INFORMATION

Flex may use certain or all of the Personal Information collected as identified above, for the following purposes:

To fulfill or meet the reason you provided the Personal Information (create your account, provide support, respond to a query, etc.);
Provide the Services;
Monitor and improve the Services;
Respond to law enforcement; or otherwise as detailed in our Privacy Policy.

Flex will not collect additional categories of Personal Information or use the Personal Information it collects for materially different, unrelated, or incompatible purposes without providing you notice.

(G) DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

Flex may disclose your Personal Information to a contractor or service provider for a Business Purpose. When Flex discloses Personal Information for a Business Purpose, it enters into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for performing the contract. Flex further restricts the contractor and service provider from selling or sharing your Personal Information.

In the preceding twelve (12) months, Flex has disclosed the following categories of Personal Information for a Business Purpose:

(H) SALE OR SHARE OF PERSONAL INFORMATION

In the preceding twelve (12) months, Flex has not “sold” information as most people would normally understand that term and it will not disclose any Personal Information in direct exchange for money or some other form of payment.

For targeting and analytic purposes, when Flex promotes its Services, it uses third-party tools that are able to market the Services online, measure these marketing efforts, identify individuals that are interested in the Services, etc. This is done by placing cookies, pixel or other tracking technology on the Website and sharing with these vendors the online identifiers and online behavior information. Disclosing Personal Information with such third-party vendors for marketing and targeting purposes (which is often referred as "cross-contextual behavioral advertising") is defined as a "Share" under the CCPA, while under certain circumstances, disclosing Personal Information for analytic purposes might be considered as a "Sale". Therefore note, Flex may share your Personal Information with a third party to help promote the Services and understand your use it.

In the preceding twelve (12) months, Flex has “sold” or “shared” the following categories of Personal Information for a Business Purpose:

(I) CHILDREN UNDER AGE 16

Our Services are not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at: legal@flexcorp.io if you have reason to believe that a child has shared any information with us.

(J) DATA RETENTION

In general, Flex retains the Personal Information it collects for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt out, where applicable.

The retention periods are determined according to the criteria describe under Section 8 in the Privacy Policy.

PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM DESCRIPTION OF THE INFORMATION PRACTICES:

(K) YOUR RIGHTS UNDER THE CCPA

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law, all as described herein and the Data Subject Request form ("DSR") available here.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

(L) HOW CAN YOU EXERCISE THE RIGHTS?

You may exercise your rights through the DSR available here. The instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer must provide are all detailed in the DSR.

Note, certain rights can be done by you independently without using the DSR. For example, depending on your interaction with us:

You can opt-out from receiving emails from us by clicking the “unsubscribe” link within the email; and
You can delete and correct any information available in your account, through your Merchant Portal settings.
Further, opt-out rights can be executed without filling the form:
Through Device-Level Choices: If you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device settings.
Use the Global Privacy Control (“GPC”) signals.

(M) AUTHORIZED AGENTS

“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, Flex will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

a. When a consumer uses an authorized agent to submit a request to know or a request to delete, Flex may require that the consumer do the following:

Provide the authorized agent signed permission to do so or power of attorney.
Verify their identity directly with Flex.
Directly confirm with the Company that they provided the authorized agent permission to submit the request.

b. Flex may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

(N) NOTICE OF FINANCIAL INCENTIVE

Flex does not offer financial incentives to consumers for providing Personal Information.

By email: legal@flexcorp.io

By mail: FlexCorp Inc. 2600 Tilton Road #1004 Egg Harbor Township, NJ 08234 United States.

UPDATES

This CCPA Notice was last updated on October 10th, 2023. As required under the CCPA, Flex will update the CCPA Notice every 12 months. The last revision date will be reflected in the “Last Amended” heading at the top of this CCPA Notice.

PART III: OTHER CALIFORNIA OBLIGATIONS

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires Flex to notify its consumers how it deals with the “Do Not Track” settings in your browser. As of the effective date listed in this CCPA Notice heading, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, Flex does not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

California’s “Shine the Light” Act (Civil Code Section § 1798.83): which permits California consumers to request certain information regarding the Company disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us the DSR available here.