Effective date: March 10, 2017Following 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:
- Flywire also complies with any additional restrictions imposed by Standard Contractual Clauses.
- 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.
- In all cases, Flywire also complies with any additional requirements in its contracts with its customers.
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.
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.
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.
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.
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.
- Attn: Privacy Officer
- 141 Tremont Street, 10th Floor
- Boston, MA 02111, USA
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