Privacy Policy

Effective Date: May 26, 2026

1. Introduction

Welcome to FlowPass ("we," "our," or "us"), operated by FLOWGATE CYPRUS LTD. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the FlowPass mobile application and website (collectively, the "Service").

2. Information We Collect

We collect information that you provide directly to us when you register and use our Service:

  • Account Information: Email address used for Magic Link authentication.
  • Identity Information (Individuals): First name, last name, date of birth, and country of birth.
  • Identity Information (Corporate Entities): Legal entity name and country of registration.
  • Transaction Data: Information about your purchases, including transaction amounts, fiat currency, crypto wallet addresses, and cashback points earned.
  • Device & Usage Data: IP address, device type, operating system, and app usage statistics to improve our Service.

Note on Biometrics: If you use biometric authentication (Face ID or Fingerprint) to authorize transactions, this data is processed securely on your device. We do not collect, store, or have access to your biometric data on our servers.

3. How We Use Your Information

We use the collected information for the following purposes:

  • To create and manage your FlowPass account.
  • To process your transactions and calculate cashback rewards.
  • To verify your identity and comply with legal and regulatory requirements (e.g., KYC/AML).
  • To send you transactional emails, including Magic Links for secure login and verification codes.
  • To improve our app's functionality, security, and user experience.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information only in the following circumstances:

  • Service Providers: With trusted third-party vendors who assist us in operating our Service (e.g., email delivery via MailerSend, cloud hosting, database management).
  • Legal Obligations: When required by law, subpoena, or other legal processes, or to protect the rights, property, or safety of FLOWGATE CYPRUS LTD, our users, or others.
  • Business Transfers: In connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business.

5. Data Security

We implement industry-standard security measures, including encryption and secure socket layer (SSL) technology, to protect your personal data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Account Deletion and Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

  • The right to access, update, or delete the information we have on you.
  • The right of rectification if your information is inaccurate or incomplete.
  • The right to object to our processing of your personal data.
  • The right to request that we restrict the processing of your personal data.
  • The right to data portability.

How to Request Account Deletion

If you wish to delete your FlowPass account and all associated personal data, you can do so by sending an email request. Please follow these steps:

  1. Send an email to admin@flowgate.tech from the email address associated with your FlowPass account.
  2. Use the subject line: "Account Deletion Request".
  3. In the body of the email, state that you wish to permanently delete your account and all associated data.

What happens when you delete your account:
Upon receiving your verified request, we will permanently delete your personal profile information (name, date of birth, country, etc.) and login credentials.

Note on Data Retention: We are required by law (for AML/KYC and accounting purposes) to retain records of your financial transactions (purchases and cashback history) for a period of up to 5 years. This transactional data will be anonymized where possible and kept securely isolated from active systems.

7. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, or as required to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

8. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes.

9. Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • Company: FLOWGATE CYPRUS LTD
  • Email: admin@flowgate.tech
  • Address: Spyrou Kyprianou, 78, MAGNUM BUSINESS CENTER, Floor 3, 3076, Limassol, Cyprus