European Privacy Policy

Effective date: March 10, 2017

Following the European Court of Justice’s October 2015 invalidation of Safe Harbor, the Flywire family of companies implemented the Standard Contractual Clauses that the European Commission approved for transfers of personal data to countries such as the United States. These Clauses, which also are known as model contracts, ensure the continued lawful transfer of Personal Information to Flywire. Today, Flywire offers the following enhanced solution for data transfer compliance:
  1. Flywire continues to provide the protections of Safe Harbor to all personal data received under its Safe Harbor certification, as described in this privacy policy.
  2. Flywire also complies with any additional restrictions imposed by Standard Contractual Clauses.
  3. Certain data transfers to Flywire also are made under additional, independently sufficient legal bases for such transfers, such as certain transfers made to carry out payment transactions.
  4. In all cases, Flywire also complies with any additional requirements in its contracts with its customers.

Definitions

For the purposes of this policy:

  • "Personal Information” shall refer to any information that i) is transferred from the European Economic Area or Switzerland to Flywire in the United States, ii) is about an identified or identifiable Individual; iii) can be linked to that Individual and iv) is recorded in any form.
  • “Individual” means any natural or legal person, other than those acting in their capacity as Workers.
  • “Worker” means any person who was previously, is currently, or might in the future be engaged by a Flywire affiliate as an employee under contract of service or in any other capacity under a contract for service or any other arrangement to work for any Flywire affiliate (e.g. intern, temporary staff, contractor, job applicant, etc.), as well as any dependents, beneficiaries and other related persons about whom such person provides information to a Flywire affiliate in connection with such relationship with Flywire or its affiliate.

Notice

During account registration (which is required to use Flywire’s services), every Flywire user is provided with our Global Privacy Policy, which provides details regarding our collection and handling of Personal Information and instructions for accessing this European privacy policy.

Choice

Flywire will offer Individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a third party (other than Flywire’s service providers or as specified in the Onward Transfer section below), or (b) to be used for a purpose other than for what it was originally collected or subsequently authorised by the Individual. In the unlikely event that Flywire intended to carry out either activity with Personal Information considered sensitive under applicable European law (e.g., personal health information), Flywire would comply with applicable requirements to first obtain opt-in consent. As with all activity described in this Privacy Policy, in all cases Flywire abides by any applicable legal or contractual restrictions.

Onward Transfer of Personal Information

Flywire offers the choices set forth in the Choices section regarding certain transfers to third parties. To the extent permitted by applicable law, applicable data transfer mechanismsand applicable contractual restrictions, Flywire may disclose Personal Information without offering Individuals an opportunity to opt out (i) if required to do so by law or a legal process, (ii) to law enforcement authorities, and (iii) when Flywire believes disclosure it necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraudulent illegal activity. For more information about transfers, visit our Global Privacy Policy.

Data Integrity

Flywire shall take reasonable steps to ensure that Individual Personal Information is: (i) relevant for the purposes for which it was collected or authorised by the Individual, (ii) reliable for its intended use, and (iii) accurate, complete and current. Please contact us or use our website to update your Personal Information as necessary.

Access

Flywire will provide Individuals with reasonable access to examine Personal Information about them that it holds. Flywire will take reasonable steps to permit Individuals to correct, delete, change or challenge the accuracy of the data to the full extent required by law.

Requests for access to Personal Information should be made as discussed in the Contact section below during normal business hours, in line with Flywire standard procedures.

Please note that there are limits to the obligation to provide access to Personal Information. For example, Flywire may restrict access to certain proprietary information, such as business plans or other such sensitive information. In some cases, where permitted by law, access may be restricted where the burden of expensive of providing access will be disproportionate to the risks of the privacy of other persons, or in cases where the rights of others would be violated.

Should an Individual be denied access to Personal Information, Flywire shall provide the Individual with the reason(s) and a contact point.

Security

Flywire takes reasonable precautions to protect Individual Personal Information against loss, misuse and unauthorized access, disclosure, alteration, destruction and theft.

Flywire has in place appropriate physical and technical safeguards in addition to employee policies and procedures to protect Individual Personal Information.

Enforcement and Dispute Resolution

Flywire regularly reviews this policy to verify that it is accurate and comprehensive for the Personal Information it is intended to cover, prominently displayed, implemented fully, accessible and conforms to the European principles.

Individuals may contact Flywire with any concerns or questions about this privacy policy at the contact address provided below. Flywire will investigate and attempt to resolve any concerns or complaints regarding Personal Information in accordance with this privacy statement and at the request of the Individual.

Contact

Please address any questions or concerns regarding this policy or Flywire’s practices concerning Personal Information, and any requests to exercise rights under this policy, by:

  • Contacting Flywire’s Privacy Officer at [email protected]
  • Contacting Flywire through the methods listed on our Contact page.
  • Writing to:
    • Attn: Privacy Officer
    • Flywire
    • 141 Tremont Street, 10th Floor
    • Boston, MA 02111, USA

Amendments

Flywire, in its sole and absolute discretion, may change or modify this policy at any time and such modifications shall be effective immediately upon the post of the amended policy to Flywire.com

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