Privacy Policy

Kairhos Limited respects your concerns about privacy. This Privacy Policy applies to the personal data collected through Flynt Finance (“Flynt”). References in this Privacy Policy to ‘Flynt’, 'we', 'us' or 'our' are to Kairhos Limited

GENERAL

This Privacy Policy, together with our Terms of Service, governs the collection, processing and use of user’s Personal Data by Flynt. Kairhos Limited is the data controller under this Privacy Policy, which sets out the manner in which Kairhos Limited, as a data controller, may use your Personal Data.This Privacy Policy also applies to the collection, processing and use of your Personal Data arising from your access and use of the Flynt website flynt.finance and the associated application program interface as well as mobile and web-based applications (collectively, the “Platform”), and our services, which includes registering to, subscribing to, buying and using our products (“Services”). If you have any questions or need any further clarity, please get in touch. Contact details are set out below in the Contact Us section.Capitalized terms in this Privacy Policy have the meaning set out in the Definitions section below.Flynt is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

The types of Personal Data we collect and how it may be used;

Our use of cookies and similar technology;

How and why we may disclose your Personal Data to third parties;

The transfer of your Personal Data within and outside of the European Economic Area (“EEA”);

Your statutory rights concerning your Personal Data;

The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Data; and

Flynt's retention of your Personal Data.

COLLECTION AND USE OF PERSONAL DATA

1. PERSONAL INFORMATION WE COLLECT

We collect the Personal Data you provide directly to us or which are generated when you access and use the Platform and the Services. This may include:

Contact information, such as name, home address, and email address;

Account information, such as username, password, account settings and preferences;

Financial information, such as bank account numbers, bank statement, and subscription information;

Identity verification information, such as images of your government-issued ID, passport, national ID card, or driving license;

Residence verification information, such as utility bill details or similar information;

Information regarding the way in which you use our Services, such as when you use our Services and the specific Services used; and

Information relating to communications with us, whether through the Platform or via e-mail, over the phone or via any other medium.

We also automatically collect certain computer, device and browsing information when you access and use the Platform or the Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

Computer or mobile device information, including IP address, operating system, network system, browser type and settings; and

Platform usage information.

Finally, we may collect Personal Data from third-party partners and public sources, which include:

Reputational information;

Financial information;

Business activities of corporate customers.

We need to collect certain types of information for compliance with legal requirements relating to our anti-fraud/anti-money laundering/counter financing of terrorism/know your customer obligations. If this information is not provided, we may not be able to provide a service for you. Your Personal Data may also be processed if it is necessary on reasonable requests by law enforcement or regulatory authority, body or agency or in the defense of a legal claim. We will not delete Personal Data if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved. We do not perform behavioral tracking of a customer’s activities on our Platform or across different websites, nor do we allow third-party data collection through our Services, save for those expressly set out in this Privacy Policy.It is important to note that the Personal Data we collect from you when you create an account will be retained for the mandatory retention period set forth by applicable law. It is necessary for us to maintain an exhaustive documentation of our operations, as required from us as regulated financial sector professionals, even if your account has not been successfully activated (e.g., if account verification has not been completed) or no transaction has been made using it.

2. HOW WE USE YOUR PERSONAL INFORMATION

We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract, for example, your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers’ identities. Some information is processed because you have given your consent to that, which can be withdrawn in your account preferences and settings. Other information we collect and use because we have legitimate business interests to so, having taken into account your rights, interests, and freedoms.We may use your Personal Information to:

A. Provide Services in relation to your contractual relationship with us:

Create and administer your Flynt account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract), and for compliance with legal obligations to which we are subject;

Process your Flynt transactions. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;

Help us respond to your customer service requests and support needs. Related processing operations are necessary for the performance of a contract with you, and for purposes of our legitimate interests (that is, improving our services and offering you the best experience); and

Contact you about Flynt Services. The email address you provide may be used to communicate information and updates related to your use of the Flynt Services.

B. Use data for further purposes based on our legitimate interests:

Personalize your Flynt Services experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our services);

Analyze Platform usage and improve our Platform as well as Platform offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our Services); and

Monitor your use of our Services and use your information to help us monitor, and protect our Services and the Platform.

Where we rely on our legitimate interests, we will carry out a balancing test to identify our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the Privacy Policy.On other occasions where we ask for your consent, we will use the data for the purposes we state at that time.

C. For purposes which are required by law:

Verify your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including for compliance with the Flynt Anti Money Laundering policy, to address other law enforcement needs as more fully described in our Terms of Service, and generally as required for compliance with legislation and regulations applicable to Flynt.

3. AUTOMATED DECISIONS MAKING

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our Services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision will be reached automatically as to whether we are able to provide products or Services to you based on your creditworthiness.

4. MARKETING

We may also occasionally communicate company news, updates, promotions and related information relating to similar products and Services provided by Flynt. We may also administer a contest, promotion, survey or other site features as will be more explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under Data Privacy Law in pursuit of our legitimate interests (that is, promoting our Services).We may share Personal Data with third parties to help us with our marketing and promotional projects or sending marketing communications.If you want to opt-out of receiving promotional and marketing emails, text messages, post and other forms of communications from us or our promotional partners in relation to which you might receive in accordance with this section, you can best opt-out by using one of the following ways:

Log into your account and update your profile;

Click 'unsubscribe' at the bottom of an email we sent you

If you do opt-out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and Services we have provided to you after you make a reservation with us, reservation confirmations or responses to your inquiries or complaints, and similar communications.

DISCLOSING AND TRANSFERRING PERSONAL DATA

We may disclose your Personal Data to third parties, legal and regulatory authorities, and transfer your Personal Data outside the EEA, as described below.

1. DISCLOSURES TO THIRD PARTIES

There are certain circumstances where we may transfer your Personal Data to employees, contractors and other parties.

We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this Privacy Policy;

We may also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centers. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function;

We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to use your information to provide the Services to you. These include credit reference agencies, anti-fraud databases, screening agencies, and other partners we do business with.

Your personal data may be transferred to other third-party organizations in certain scenarios:

If we are discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;

If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;

If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example, the Police;

If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide the Services or as required by law. Flynt’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms complying with Data Privacy Law.

2. DISCLOSURES TO LEGAL AUTHORITIES

We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:

Compelled by court order, or other legal procedure;

Disclosure is necessary to report suspected illegal activity;

Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Service.

3. INTERNATIONAL TRANSFERS OF PERSONAL DATA

With this policy, we store and process your Personal Data in data centers wherever Flynt facilities or service providers are located. As such, we may transfer your Personal Data outside of the European Union. Some of the countries to which your personal data may be transferred for these purposes that are located outside the EU do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal data in that country. Details of these specific countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under Data Privacy Law will be implemented, such as standard data protection clauses with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.

YOUR STATUTORY RIGHTS

Your personal information belongs to you. You have certain rights concerning your Personal Data under Data Privacy Laws as mentioned below and can exercise them by contacting us at [email protected].Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and certain other information about it to check that we are lawfully processing it. We process a large quantity of information, and can thus request, in accordance with DP Law, that before the information is delivered, you specify the information or processing activities to which your request relates.Correction: you are entitled to request that any incomplete or inaccurate Personal Data we hold about you is corrected.Erasure: you are entitled to ask us to delete or remove Personal Data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is required for compliance with law or in connection with claims.Restriction: you are entitled to ask us to suspend the processing of certain of your Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.Transfer: you may request the transfer of certain of your personal data to another party.Objection: where we are processing your Personal Data based on legitimate interests (or those of a third party) or for the purposes of our contractual relationship, you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes.Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.Please note that the above rights may be limited, for example, if fulfilling your request would reveal Personal Data about another person, where they would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in national laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

CRYPTOGRAPHIC HASHES

Users sending digital assets to this platform through the use of cryptographic hashes and keys take full responsibility for the risks involved. By using services offered by Flynt you will automatically accept liability of any loss, damages or implications incurred through the use of this Platform. Flynt and its owners will not be held liable for any loss of digital assets.Users who do not agree can request the return of their digital assets through the use of a withdrawal once logged in.

SECURITY OF PERSONAL DATA

We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

Password protected directories and databases;

Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Intercom securely;

PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized Flynt personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by Flynt. If you do receive a suspicious request, do not provide your information and report it by contacting one of our customer service representatives as set out in this Privacy Policy.You are responsible for keeping your account passcode, UID and password safe and secure. Do not share those with anyone. If there is unauthorized use or any other breach of security involving your information, you must notify us below as soon as possible.

RETENTION OF PERSONAL DATA

We retain Personal Data for as long as necessary to fulfill purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. The criteria we may use to determine the retention period for certain categories of data include:

How long you have been an Flynt User;

Whether there are contractual or legal obligations existing that require us to retain the data for a certain period of time;

Whether there is any ongoing legal or financial claim that relates to your relationship with us;

Whether any applicable law, statute, or regulation allows for a specific retention period; and

What the expectation for retention was at the time the data was provided to us. In accordance with our record-keeping obligations, we will retain Account and other Personal Data for at least five years (and some up to ten years, as required by applicable law) after an Account is closed.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy was last revised effective on April 6th, 2020. We may change this Privacy Policy from time to time, so it is advisable that you review it frequently. Changes to this Privacy Policy will be announced on our website or through similar means for a reasonable length of time prior to and following any changes taking effect.

To exercise your rights, please contact us at [email protected]. You can also contact the competent data protection authority as the responsible supervisory authority.

DEFINITIONS

Account. The contractual arrangement wherein a Flynt user has accepted our Terms of Service and Privacy Policy, and received approval to use the Flynt Services, including the purchase and sale of Perpetual Contract and to perform associated transactions.Flynt Platform. Hardware and software technologies used by Flynt to provide the Flynt Service as set out in our Terms of Service.Data Privacy Laws. Means data protection laws applicable to Flynt, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts as well as equivalent legislation, which apply to the processing of Personal Data by Flynt.Personal Data. Has the meaning set forth under Data Privacy Laws, and is information that identifies an individual, such as name, address, e-mail address, subscription information, and banking details. Personal Data does not include anonymized and/or aggregated data that does not identify a specific user.Service(s). The technological platform, functional rules, and market managed by Flynt to permit Sellers and Buyers to perform purchase and sale of Perpetual Contract.

Please contact us with questions, comments, or concerns regarding our Privacy Policy and/or practices at [email protected].

Cookie Policy

Effective date: 1st August, 2022

This Cookie Policy applies to the Flynt Finance (“Flynt”) website flynt.finance and the associated application program interface as well as mobile and web-based applications (collectively, the “Platform”) as well as to services, which include registering to, subscribing to, buying and using Flynt products (“Services”) and the Flynt API offered by Kairhos Limited and gives you information on how we use cookies and similar technologies. References in this Cookie Policy to 'Flynt', 'we', 'us' or 'our' are to Kairhos Limited. Please read this Cookie Policy carefully and feel free to contact us if you have any questions.

What are Cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit a website. It enables the website to remember your actions and preferences (such as language preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the Platform or browse from one page to another. When we talk about cookies in this Cookie Policy, this term includes technologies which serve a similar purpose.

How do we use Cookies?

Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Platform, analyze trends, and administer the hardware and software technologies used by Flynt to provide the Services (“Platform”). The information collected from cookies allows us to determine such things as which parts of our Platform are most visited and difficulties our visitors may experience in accessing our Platform. With this knowledge, we can improve the quality of your experience in using the Services by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Platform.We use a third-party service provider(s), to assist us in better understanding the use of our Platform. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our Platform, what products are browsed, and general transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Platform and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Platform other than to assist us.

How long do we retain data from cookies?

We retain the information we collect through cookies for up to 14 days after collection.

Cookies used on the Platform

A full list of the cookies that we use on the Platform can be found below.

Google Analytics GA version 3

Purpose of cookie

These cookies are used to collect information about how visitors use our Platform. We use the information to compile reports and to help us improve the Platform. The cookies collect information in an anonymous form, including the number of visitors to the Platform and blog, where visitors have come to the website from and the pages they visited.

More information and how to contact us

You can control and/or delete cookies as you wish - for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. To opt out of being tracked by Google Analytics across all websites, visithttp://tools.google.com/dlpage/gaoptout.However, please note that disabling cookies might make it impossible for you to use certain features of the Services, such as logging into your Flynt account or making transactions. Your use of our Platform or Services with a browser that is configured to accept cookies constitutes an acceptance of our and third-party cookies.

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Privacy Policy