A. Information We CollectWe 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. Information We Collect From You When you use the Service, you may provide us with the following types of information:
- Your Account information. To create an account you will need to provide us with your name, email address, and password. We will also ask about your relationship with the person on whose behalf you are making a payment, if different from you.
- Payment Information. When submitting a payment through our Service, we ask the payer for information such as the payer’s name, address, phone number, and government identification number. You will also need to provide information about the person for whom you are submitting a payment. For example, when submitting a payment to an educational institution, we will also ask for the student’s name, student ID, invoice number, date of birth, year of graduation, educational institution, and student email address. When submitting a payment to a healthcare organization, we will ask the payer to provide information such as the patient’s name, medical record number or patient account number, bill identification number, and health care organization. As part of the payment process, or to process a refund or charge-back, we and/or our partners may need the payer’s financial account information, such as bank account numbers, names, and routing codes.
- Referrals. To invite others to use the Service, you may submit their names, emails, and, for students, their educational institution.
- Job Application Information. If you apply for a job with us, you may provide us with employment-related information such as your C.V. or resume.
- Messages and Customer Service Requests. We collect the information you submit when you communicate with us by email, chat, or other methods.
- Financial Institutions and Service Providers. In the course of processing your payment transaction we may work with a number of institutions, who we have partnered with, to help us provide our Service including banks and non-bank financial institutions such as card processors, electronic money institutions and payment service providers. To process a payment, a financial institution or service provider may share with us information about the payer’s account such as account name, number, routing code and other identifying information.
- Designated Entities. We may be provided with your name and email address, before your create an account, from the educational institutions, healthcare providers and other entities for which we serve as a payment agent, in order to contact you to encourage you to make a payment through our Service. Furthermore, these Designated Entities, may use the Service to communicate with you and manage the receipt of payments.
B. How We Use the Information We CollectWe may use the information we obtain about you, as permitted by applicable law, to:
- Provide and improve the Service;
- Process your payment transaction and keep you informed about the status of your payment;
- Comply with and enforce applicable legal requirements, industry standards and our policies;
- Respond to your inquiries, resolve disputes and provide support;
- Analyze, operate and improve our business and the Service (including enhancing the user experience, managing communications and functionality, and developing new products and services);
- Communicate with you for Service-related purposes, such as sending payment reminders;
- Send you marketing messages, service updates and promotional offers;
- Compare information for accuracy and verify it with third parties;
- Further our business relationship with you, if we have collected your personal information in the context of an actual or potential business relationship;
- Evaluate your application for employment and contact you regarding possible employment at Flywire, if you have applied for a job;
- De-identify or aggregate data collected through the Service and use and disclose it for any purpose; and
- Fulfill other purposes to which you have consented, which would be reasonably expected by you, or which are otherwise authorised or required by law.
- To process your payment, we may share some of your information with the Designated Entity, for whom we serve as the payment agent.
- We may share your information with service providers and vendors who assist us with the delivery of our Service. In some cases, to successfully process your payment or refund, we may share bank/payment receipt documents that you have sent to us with financial institutions under contract with whom we work, to assist with the processing and/or refund of that payment. Our contracts oblige these financial institutions to only use your personal information in connection with the services they provide to us and not for their own benefit.
- Additionally, your information may be shared with other financial institutions, trade bodies, anti-fraud organizations and law enforcement agencies for the purposes of identifying and preventing fraud, money laundering, terrorist financing and other financial crimes.
- Flywire is a business incorporated in the United States, which also operates several international affiliates and subsidiaries. We may share personal information with these, or future, affiliates.
- If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.
D. Your Rights and ChoicesYou may have certain rights regarding the personal information we collect and maintain about you and how we communicate with you.
- When we request information from you on the Service, you may always choose not to provide us with that information. However, if you decline to provide us with certain information, we may not be able to provide you with the Service offered.
- You may opt out of e-mail marketing communications by clicking on the unsubscribe link within marketing e-mails you receive from us or by contacting us.
- If you are located in the European Economic Area or Switzerland, you may direct us not to share your personal information with third parties, except (i) with the service providers and financial institutionsunder contract we have retained to perform services on our behalf, (ii) in the event we are acquired or we transfer all or a portion of our business or assets, (iii) if a legal process or law requires disclosure, (iv) with other financial institutions, trade bodies, anti-fraud organisations and law enforcement agencies for the purposes of identifying and preventing fraud, money laundering, terrorist financing and other financial crimes, or (v) when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
- Where required by law, Flywire obtains your prior opt-in consent at the time of collection for the processing of personal information for marketing purposes.
F. How We Protect Your Personal InformationFlywire 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 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.
G. Children’s PrivacyFlywire 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.
J. Questions, Comments and Complaints about Our Handling of Personal InformationIf 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.
Attn: Privacy Officer
141 Tremont Street, 10th Floor
Boston, MA 02111, USA