Effective date: Apr 07, 2020
On our website, you may choose to use certain features which are provided by other entities. These features, which include social networking buttons (which will be prominently displayed on our webpage), are operated by third parties that are not affiliated with Flywire, and they may collect information directly from you. These third parties may use your information in accordance with their own privacy policies and practices.
We may obtain information about you in a variety of ways, such as when you voluntarily provide it to us, in our role as a processor of payment transactions, or when it is automatically sent to us by the device you use to access the Service.
When you use the Service, you may provide us with the following types of information:
We may receive information from others, including:
When you visit our Service or open our emails, we and our third-party service providers may collect certain information by automated means, such as cookies, web beacons and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service. We may link this data to your profile. You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, the Service may not work properly.
We work with third party partners such as analytics and advertising partners, who may collect information about your use of other websites and online services over time. To learn more about Google Analytics and the choices Google provides regarding your information, please visit http:///www.google.com/policies/privacy/partners/.
Our advertising partners may collect your information in order to show you ads that may interest you. Where required under applicable law, we will request your consent to such collection and use of your information. You may opt out of receiving personalized advertisements from us and our advertising partners who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out sections on the websites of each of those organizations. Links to those sites are here:
Network Advertising Initiative: http://www.networkadvertising.org/choices/.
Digital Advertising Alliance: http://www.aboutads.info/choices/.
We may use the information we obtain about you, as permitted by applicable law, to:
We do not rent, sell, or share personal information (as defined by California Civil Code § 1798.83) about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.
Flywire is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Flywire complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
We collect and process information about you only when we have a legal basis for doing so under applicable laws. This means we collect and use your information where:
You may have certain rights regarding the personal information we collect and maintain about you and how we communicate with you.
To facilitate our global operations, we transfer and store information in the U.S and allow access to that information from other countries in which Flywire operates. These countries may not have the equivalent privacy laws as those of the EU or UK. When we share information about you within and among our corporate affiliate (Flywire LTD, Flywire Romania, OnPlan Holdings, Flywire Securities, Flywire Global, Flywire Canada, Flywire Heathcare, Flywire Singapore, Flywire Pacific, Flywire G.K., Flywire Hong Kong, Pingfufei Commercial Shanghai) we make use of standard contractual data protection clauses, which have been approved by the European Commission.
When transferring any Personal Data from the EEA and Switzerland to the U.S., we adhere to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce. Flywire has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.
We commit to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Flywire maintains reasonable safeguards combining administrative, technical, and physical measures to provide protection to the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, interference, modification, disclosure or misuse.
We use data hosting service providers in the US and Ireland to host the information we collect and we use technical controls to secure that data
We use Secure Socket Layer (SSL) encryption on our website when transmitting information and use other commercially reasonable efforts to protect your information. We continue to assess new technology for protection of information and upgrade our information security systems where appropriate. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
Flywire makes sure that our employees know and adhere to our security policies. We require periodic training on our security policies for all personnel, no matter their department. Personnel who work directly with customers receive extra training on emerging risks, such as identity theft.
All Flywire resources agree when joining the Company to a form of confidentiality/non-disclosure agreement or specific confidentiality undertaking in their agreements of employment. Flywire resources must understand and comply fully with these terms upon commencing work at Flywire, and keep information confidential that comes into their possession or control in connection with employment with Flywire. This includes internal Flywire information, as well as information relating to clients and third parties, and applies at any time during and after employment.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Flywire is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We retain your account information for as long as your account is active and as necessary to comply with our legal obligations. After such time we will either delete or anonymize your information or if it is not possible then we will securely store your information and isolate it from any further use until deletion is possible.
Flywire is not directed to children, and we do not knowingly collect personal information from children under 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please let us know.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect And Receive section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. Flywire does not sell (as such term is defined in the CCPA) the personal information we collect.
If you have any questions, comments or complaints about our collection, use, storage or disclosure of personal information, please contact us as set forth below. Flywire will take any privacy complaint seriously and we will aim to resolve any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
In compliance with the Privacy Shield Principles, Flywire commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Flywire using the contact information details below
Attn: Privacy Officer
141 Tremont Street, 10th Floor
Boston, MA 02111, USA
Flywire has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit
https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
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