Privacy Policy – United Kingdom / International

Flovide
Last updated: 30/03/2025

1. Introduction

This Privacy Policy explains how Flovide (“Flovide”, “we”, “us”, or “our”) collects, uses, stores, discloses, and protects personal information when you access or use our website, mobile applications, and financial services (collectively, the “Services”).

Flovide provides financial technology and money transfer services and is committed to safeguarding your privacy in compliance with applicable data protection and financial regulations, including GDPR, UK Data Protection Act, AML, and KYC laws.

2. Scope of This Privacy Policy

• Users of Flovide’s Services
• Website and mobile application visitors
• Customers and transaction recipients

3. Information We Collect

3.1 Personal Information

• Full name, date of birth, nationality
• Email, phone number, residential address
• Login credentials and security details
• Government-issued identification
• Bank and payment information

3.2 KYC & Compliance Data

Identity documents, proof of address, source of funds, and transaction monitoring data in line with AML and Counter-Terrorism Financing regulations.

3.3 Automatically Collected Data

• IP address, device information
• Browser and operating system
• Usage logs and cookies

4. How We Use Your Information

• Account creation and transaction processing
• Regulatory compliance and fraud prevention
• Customer support and communications
• Service improvement and analytics

5. Legal Basis for Processing

• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• User consent where required

6. Data Sharing

We do not sell personal data. We may share data with licensed banks, payment processors, identity verification providers, regulators, and law enforcement where required by law.

7. International Transfers

Where personal data is transferred outside the UK or EEA, appropriate safeguards such as contractual clauses and regulatory protections are applied.

8. Data Retention

KYC and transaction records are retained for a minimum of five (5) years in line with financial regulatory requirements.

9. Data Security

• Encryption in transit and at rest
• Restricted access controls
• Continuous monitoring and audits

10. Your Rights

• Right to access, correct, or delete your data
• Right to object to processing
• Right to data portability
• Right to lodge a complaint with a data protection authority

11. Cookies

We use cookies to enhance functionality and analyze usage. You may control cookies via your browser settings.

12. Children’s Privacy

Our services are not intended for individuals under 18 years of age.

13. Changes to This Policy

This Privacy Policy may be updated from time to time. Updates take effect immediately upon publication.

14. Contact Us

For privacy inquiries, please contact: support@flovide.com

15. Governing Law

This Privacy Policy is governed by applicable UK and international data protection laws.

Privacy Policy – United States

Flovide
Last updated: 30/03/2025

1. Introduction

This Privacy Policy explains how Flovide (“Flovide”, “we”, “us”, or “our”) collects, uses, stores, discloses, and protects personal information when you access or use our website, mobile applications, and financial services (collectively, the “Services”). This policy is designed to comply with applicable U.S. federal and state privacy laws including GLBA, CCPA, CPRA, and AML/KYC requirements.

2. Scope

• Individuals using Flovide’s Services
• Visitors to our website or mobile applications
• Customers, prospective customers, and transaction recipients

3. Information We Collect

• Personal info: name, date of birth, nationality, contact info, government ID
• Account info: login credentials, security info, bank/debit card details
• KYC/Compliance info: identity verification, proof of address, source of funds
• Recipient info: name, contact, bank/wallet info, ID where required
• Automatic data: IP address, device info, browser/OS, usage logs, cookies
• Third-party data: identity verification, banks/payment processors, fraud prevention, marketing/analytics

4. How We Use Your Information

• Create/manage accounts and process transactions
• Verify identity, comply with AML, KYC, FinCEN, BSA, and CTF obligations
• Prevent fraud and secure Services
• Respond to customer inquiries and resolve disputes
• Marketing, promotions, and internal analytics where permitted

5. Legal Bases for Processing

• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• User consent where required

6. Data Sharing

We do not sell personal information. We may share it with partner banks, payment processors, identity verification, cloud/IT vendors, and regulators or law enforcement when legally required.

7. Cross-Border Transfers

Personal data may be transferred outside the U.S., safeguarded according to applicable laws and contracts.

8. Data Retention

• KYC and transaction records: minimum 5 years after last transaction or account closure
• Other data retained as needed for legal, business, or dispute resolution purposes

9. Data Security

• Encryption in transit and at rest
• Role-based access controls
• Secure infrastructure, monitoring, and regular audits

10. Your Privacy Rights

• Access, correct, or delete personal information
• Object to processing
• Limit use of sensitive info (where applicable)
• Opt-out of certain processing activities

11. California Privacy Rights

California residents may request information on data collected, correct inaccuracies, request deletion, and are protected under CCPA/CPRA. Flovide does not sell personal information.

12. Cookies & Tracking

Cookies and similar technologies are used for core functionality, remembering preferences, and analyzing usage. Browser/device settings control cookies; some features may not work if disabled.

13. Children’s Privacy

Services are not intended for individuals under 18. No personal information is knowingly collected from minors.

14. Changes

This Privacy Policy may be updated periodically. Changes take effect immediately upon posting.

15. Contact Us

For questions or privacy requests, contact: support@flovide.com

16. Governing Law

This Policy is governed by applicable U.S. federal and state laws where Flovide operates.

Privacy Policy – Canada

Flovide
Last updated: 30/02/2025

1. Introduction

This Privacy Policy describes how Flovide (“Flovide”, “we”, “us”, or “our”) collects, uses, discloses, stores, and protects personal information when you access or use our website, mobile applications, and financial services (collectively, the “Services”). We comply with Canadian privacy laws including PIPEDA, applicable provincial laws (e.g., Quebec Law 25), and AML/KYC obligations under FINTRAC.

2. Scope

• Customers using Flovide’s Services
• Visitors to our website or mobile applications
• Individuals whose personal information is processed in connection with transactions (including recipients)

3. Personal Information We Collect

• Provided directly: identity, contact, account credentials, government ID, financial info, communications
• KYC/Compliance: identity verification, proof of address, source of funds/wealth, transaction monitoring
• Recipient info: name, contact, bank/wallet info, ID where required
• Automatically collected: IP address, device info, browser/OS, app usage, cookies
• Third-party info: identity verification, banks/payment processors, fraud prevention, analytics providers

4. Purposes for Collecting Personal Information

• Create/manage accounts and process domestic/international transfers
• Verify identity, conduct KYC/Customer Due Diligence, comply with FINTRAC
• Detect and prevent fraud, money laundering, and other financial crimes
• Respond to customer inquiries and disputes
• Analyze usage, improve services, and develop new features (with consent where required)

5. Consent

Consent is obtained under PIPEDA and provincial laws. It may be express or implied. You may withdraw consent subject to legal/contractual limitations and reasonable notice.

6. Limiting Use, Disclosure, and Retention

Personal information is used only for appropriate purposes and retained only as long as necessary to meet legal or business requirements.

7. Data Retention

• Regulatory: KYC and transaction records retained ≥5 years post-account closure or transaction
• Business/Legal: retained longer if needed for disputes, agreements, or legal obligations; securely deleted/anonymized afterward

8. Safeguards and Security Measures

• Encryption in transit and at rest
• Role-based access and secure servers
• Monitoring and security audits

9. Disclosure of Personal Information

We do not sell personal information. We may disclose it to banks, payment processors, identity verification, fraud prevention partners, regulators, courts, or law enforcement as required.

10. Cross-Border Data Transfers

Personal information may be processed outside Canada (e.g., the U.S.) with contractual safeguards and protection according to Canadian privacy standards.

11. Your Privacy Rights (Canada)

• Access personal information held by Flovide
• Request correction of inaccurate/incomplete info
• Withdraw consent (subject to legal limits)
• Challenge compliance with privacy laws

12. Quebec Privacy Rights (Law 25)

• Right to data portability
• Right to request deletion
• Right to be informed of automated decision-making

13. Cookies and Tracking

Used for functionality, preferences, and usage analytics. Preferences managed via browser/device settings. Disabling may affect some features.

14. Children’s Privacy

Services not intended for under 18. Personal information from minors is not knowingly collected.

15. Changes

Privacy Policy may be updated periodically. Updates take effect upon posting.

16. Contact

Questions or requests: support@flovide.com

17. Governing Law

Governed by Canadian federal laws and applicable provincial laws where Flovide operates.

Privacy Policy & Terms and Conditions — Nigeria

Flovide • Last Updated: 23 January 2026

1. Introduction

This Privacy Policy and Terms and Conditions (“Policy”) explain how Flovide (“we”, “us”, “our”) collects, uses, stores, and shares personal data, and the terms governing your use of our services in Nigeria.

We operate in compliance with the Nigeria Data Protection Regulation (NDPR), Central Bank of Nigeria (CBN) regulations, Anti-Money Laundering (AML), and Counter-Terrorism Financing (CTF) laws.

2. What Data We Collect

2.1 Personal Data

• Full name
• Date of birth
• Phone number
• Email address
• Residential address

2.2 KYC & Compliance Data

• National Identification Number (NIN)
• International passport, driver’s licence, or voter’s card
• Utility bill or bank statement
• Source of funds documentation

2.3 Recipient Information

• Recipient full name
• Phone number
• Bank or wallet details

2.4 Technical Data

• IP address
• Device and browser type
• App usage and page views

3. Why We Collect Your Data

• Account creation and management
• Processing local and international transfers
• AML, CTF, and CBN compliance
• Fraud prevention and security monitoring
• Service communication and improvement

4. Legal Basis (NDPR)

• Your consent
• Contract performance
• Legal obligations
• Legitimate business interest

5. Data Security

We protect your data using encryption, secure servers, access control, and TLS-secured communication.

6. Data Retention

KYC and transaction records are retained for a minimum of five (5) years in accordance with Nigerian regulations.

7. Data Sharing

We do not sell personal data. Information may be shared with banks, regulators, compliance providers, and law enforcement where legally required.

8. Your Rights Under NDPR

• Right to access
• Right to correction
• Right to deletion (where legally permitted)
• Right to object to processing
• Right to lodge a complaint with the Nigeria Data Protection Bureau (NDPB)

9. Cookies

We use cookies for essential functionality, preference storage, and analytics. You may manage cookies in your browser settings.

10. Terms of Use

Eligibility

You must be at least 18 years old to use Flovide.

User Obligations

• Provide accurate information
• Use the service lawfully
• Avoid fraud and prohibited activities

Suspension & Termination

Accounts may be suspended or terminated for regulatory reasons, fraud, or breach of this Policy.

Governing Law

This Policy is governed by the laws of the Federal Republic of Nigeria.

11. Policy Updates

This Policy may be updated periodically. Continued use of Flovide constitutes acceptance of any changes.

Dispute Resolution & Arbitration

1. Informal Resolution

If you have any complaint or dispute arising out of or relating to your use of Flovide’s services, you agree to first contact Flovide and attempt to resolve the issue informally. Complaints should be submitted through our customer support channels or via email to our designated support address at support@flovide.com.

Flovide will acknowledge and investigate complaints promptly and will make reasonable efforts to resolve the dispute within a commercially reasonable timeframe, in line with applicable Central Bank of Nigeria (CBN) consumer protection guidelines.

2. Escalation

Where a dispute cannot be resolved through informal means, either party may escalate the matter in writing for further review. Flovide may request additional information to facilitate resolution.

If the dispute remains unresolved after escalation, it shall be referred to arbitration in accordance with the provisions below.

3. Arbitration

• All disputes shall be finally settled by arbitration and not through court proceedings, except where prohibited by law.
• The arbitration shall be conducted in accordance with the Arbitration and Mediation Act, 2023 (Nigeria).
• The seat and venue of arbitration shall be Lagos State, Nigeria.
• A single arbitrator shall be appointed by mutual agreement of the parties or in accordance with the Act.
• The arbitration proceedings shall be conducted in English.

4. Costs

Each party shall bear its own legal costs and expenses. The costs of the arbitrator and arbitration proceedings shall be shared equally unless the arbitrator determines otherwise in the final award.

5. Confidentiality

All arbitration proceedings, documents, submissions, and awards shall be treated as confidential, except where disclosure is required by law, regulation, or by a competent regulatory authority.

6. Interim Relief

Nothing in this clause shall prevent either party from seeking interim or injunctive relief from a court of competent jurisdiction where necessary to protect rights or prevent irreparable harm.

7. Regulatory & Consumer Rights

• Your right to submit a complaint to the Central Bank of Nigeria (CBN) under its Consumer Protection Framework.
• Your statutory rights under Nigerian law that cannot be lawfully excluded.

8. Governing Law

This Dispute Resolution & Arbitration clause shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.