Privacy Policy
Preface
VG Platform Inc. (using the tradename Fleap Finance and known as Fleap, and otherwise herein referred to as “we,” “us,” or “our” depending on context) strongly believes in providing total privacy and protection to our customer’s personal data. The information our customers give us is gotten with full consent, is processed on a legal basis, and is not sold, rented, loaned, or otherwise disclosed to third parties.
Our policies are created to protect the confidentiality and security of our customer’s personal information. We only require the minimum amount of personal information needed to fulfill our service to our customers. Our privacy standards comply with the General Data Protection Regulation (GDPR), the Federal Trades Commission Act (15 U.S Code § 41 et seq.), and other applicable Laws.
Policy Overview
This Privacy Policy describes the process involved in the acquisition, processing, porting, storage, and disposing of your personal data in connection with our Services (which refers to all services, content, features, technologies, or functionalities supplied by us, as well as all related websites, apps, portals, mobiles applications, and tools. This Privacy Policy also governs your rights regarding the foregoing.
Scope and Consent
This policy is enforced after you consent to it when you sign-up, access our products, services, content, features, technologies, or functions offered from our websites, related sites, portals, applications, and services. However, we are not responsible for the handling of information gotten by third-party customers/sites through the use of our tools, portal, and
services and will not be held liable for any breach or misuse of collected information. You are therefore required to review the Privacy policy of such third-party customers/sites before using them.
Rights
You have the right of access to your personal data being processed by us which includes requesting for an update, rectification, erasure, asking for a copy of your personal data, a withdrawal of consent at any time, complaining to a data protection authority, without affecting the lawfulness of processing based on consent given before the withdrawal. You can request a restriction or deletion of your personal data based on the following:
• Non-legitimate grounds for the processing
• Unlawful processing
• Erasure is required for compliance with a legal obligation
• Inaccuracy of personal data
• Change in initial purpose
All requests shall be made in writing to us via email at privacy@fleap.finance.
Use of Personal Information
The collection and use of personal data by us are guided by certain principles.
These principles state that personal data should:
• Be processed fairly, lawfully, and in a transparent manner.
• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.
• Be adequate, relevant, and limited to what is necessary to fulfill the purpose of processing.
• Be accurate and, where necessary, up to date.
• Not be kept for longer than necessary for processing. • be processed in accordance with the data subject’s rights.
• Be kept safe from unauthorized processing, and accidental loss, damage, or destruction using adequate technical and organizational measures.
Personal Data Collected and Used by Us
We collect the following personal information in order to provide a personalized and improved experience. Personal Data may be given to us directly by you or by people or companies authorized by you to act on your behalf. We may also collect Personal Data about you from third parties in connection with our Services. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide the services envisaged or requested.
Automatic Information
In general, website users and logged-in users in the app who are not using our service do not need to provide personalized information to us. We may collect “aggregate data,” i.e., group data with no personal identifiers such as IP address, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information. We use this aggregate data to help us understand how our product, website, App, services, and other resources are being used and to improve usability. We also use it to enhance the quality and availability of products and services we offer.
Provided Information
Personal data that are provided and retained allow us to provide services to our users. We solely hold the information and engage in no contact-sharing program with other organizations.
The information collected is
Contact Information: first and last name, email address. phone number not limited to payment information, beneficiaries, transaction history any other information required to process your information as a user of our platforms.
Website Cookies: (small text files) when a user visits a website, and these cookies are used to analyze aggregate user behavior on our website. Our websites ask permission of the visitor prior to setting cookies.
Should the visitor agree, our server shall only collect the following information:
• The visitor’s IP address (including the domain name associated with the IP address, i.e., using reverse lookup).
• The date and time of the visit to the website.
• The pages visited on the website.
• The browser is being used.
• In addition, where this is available, we shall also collect:
• The country from which the visitor is accessing the website
• The language of the browser being used.
• The website from which the visitor is accessing our website.
• The search word used (if the site is accessed via a search engine).
• The type of connection and operating system. We only use these data to improve the visitor’s website experience. Please review our Cookie Policy to learn more about how we use cookies.
Third-Party Source: We may collect information from third-party websites such as social media sites that authorize us to access, store and use users’ information which will be handled in accordance with this policy.
Mobile Devices: Some of our applications can be accessed through a mobile application or mobile-optimized website from which we collect user data. This policy applies to access and use of data through mobile devices.
Surveys: In order to ensure that the services we offer meet your requirements, we may ask for your feedback in form of surveys and polls. Any feedback received from you shall only be used to improve our services and shall not be disclosed and are used for research and publication purposes.
Inquiries: When an inquiry is sent to us through our contact form, we use the personal data that you have stated in the contact form to send a response to you. Any personal data received from you shall not be used for any other purpose without your prior consent and knowledge and shall not be disclosed.
Duration Of Storage
We shall store your personal data until they are no longer necessary for the purpose for which we had collected it. Your information is only retained in accordance with legal and regulatory requirements for the collected data.
Data Storage and Security
We and our partners use a security-cleared data processor to store files and data on secure cloud-based servers hosted in the Central America on Microsoft Azure. The data processors are certified under the applicable frameworks and thereby guarantee and operate an appropriate standard of data protection and data security. Regardless of where your information is processed, we apply the same protections described in this policy and you have the right (upon your request) to be informed of the appropriate safeguards for data protection in the foreign country. We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. All data is accessed via secure connections and stored on encrypted servers and encrypted storage services. We also use firewalls and physical access controls for our data centers and information access authorization controls.
Despite our efforts to establish a secure environment for the website, you should be aware that no information is completely secure on the internet. Therefore, you should always take the necessary safeguards and precautions on your equipment. In the event of an actual or suspected breach of your Personal Data, we will use our best effort to remedy the breach within one (1) month from the date we report the breach to you.
Children's Privacy
We do not use our platforms to knowingly solicit data from children or individuals under the age of Eighteen (18). Where a parent or guardian discovers that a child or individual under the age of Eighteen (18) has provided us with his/her Personal Data without their consent, he or she should contact us at privacy@fleap.finance. and we shall immediately delete the user’s account from our servers.
Accuracy Of Information
• We shall take reasonable steps to ensure personal data is accurate.
• Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
• We shall ensure that updated personal data reflect across all boards to which it is being used.
Archiving/removal
• To ensure that personal data is kept for no longer than necessary, we put in place a data retention policy for each area in which personal data is processed and review this process annually.
• This retention policy considers what data should/must be retained, for how long, and why.
Transfer of Personal Data
We do not rent or sell your personally identifiable information to other individuals or organizations. However, we may transfer your personal data to third parties when it is necessary to provide you with our service.
Third parties could include:
• Undertakings within Fleap Finance
• Business partners
• Professional advisors
• Legal or regulatory authority
• Application program interface (API) Users
• Security-cleared data processors/subcontractors are assisting us or the group with IT or other services. When we transfer your personal data to business partners, you should be aware that they might have stored personal data concerning you collected through other means, e.g., if you have been in contact with them in another context.
We also transfer your personal data to the above or other third parties if we are obliged to do so according to legislation or in order to protect our or the group’s interests in legal disputes.
Transfer of Personal Data to Third Countries
We partner with various technology vendors from time to time. This shall result in a transfer of personal data to a third country or international organization. In order to ensure an equal level of security for such transfer in accordance with the applicable laws, we have chosen to work only with vendors that have entered Standard Contractual Clauses on Data Protection with us.
Third-Party Links
Please note that the Services may contain links to other websites not operated or controlled by us. We are not responsible for the content, accuracy, or opinions expressed in such websites, and such websites are not investigated, monitored, or checked for accuracy or completeness by us. Please remember that when you use a link to go from any of our Services to another website, our Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our site, is subject to the website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.
Changes to This Policy
We may update this Policy from time to time without any prior notice to you or consent. Thus, you are advised to consult any of the platforms through which you use the Services periodically for any changes. We will notify you of any changes by posting the revised Policy on the Services. Please note that changes shall be effective immediately after they are updated.
Contact
If you want to lodge a complaint about our processing of your personal data or have further requests, please contact us directly at privacy@fleap.finance. We maintain an incidence response plan used in dealing with incidents relating to unlawful disclosure, loss, alteration, destruction, and access to our customer’s personal data collected, transmitted, stored, or processed. We will work with the appropriate authorities to resolve any issues that we cannot resolve with you directly.
Cookie Policy
Please read this cookie policy (“cookie policy”, “policy”) carefully before using the Services operated by VG Platform Inc. (using the tradename Fleap Finance and known as Fleap, and otherwise herein referred to as “we,” “us,” or “our” depending on context).
What are Cookies?
Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, the website’s domain name, and some digits and numbers as well as some personal identifiers such as: user’s name, Phone number, user’s picture and integration into Biometric and Face ID login features of your device.
Necessary Cookies
Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features. For
example, these cookies let us recognize that you have created an account and have logged into that account. Functionality Cookies Functionality cookies let us operate the site in accordance with the choices you make. For example, we will recognize your username and remember how you customized the site during future visits.
Performance Cookies
These are used to gather data on how users use our website and the pages visited most often. They monitor only the performance of our website as the user interacts with it. All data collected by these cookies are anonymous and are solely used to improve the functionality of our website.
How to delete Cookies?
If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. However, deleting strictly necessary and performance cookies from your browser may remove or limit your access to some functionality on this website.
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