The following are the terms and conditions governing your (hereafter “the Client”) relationship with iFlyMedia (hereafter “iFlyMedia”) and the use of any website associated with iFlyMedia’s services (hereafter “the Website”). The Client agrees to use the Website and any other services offered by iFlyMedia only according to these Terms & Conditions. iFlyMedia has the right to make changes to the Website and these Terms & Conditions whenever this is appropriate. If iFlyMedia decides to introduce any changes to the Website or Terms & Conditions, it will notify the Client about these changes via an email sent to the email address provided during the Client’s registration with iFlyMedia. The Client’s continued use of the Website after any changes or modification have been introduced constitutes the Client’s consent to such changes or modifications.
“Personal Data” means any information relating to an identifiable natural person (i.e., an individual human being), such as a name, an ID number, location data, an online identifier. Personal Data also refers to one or more factors specific to the physical, economic, cultural, or social identity of the Client as a natural person.
- Collection of Personal Data
iFlyMedia collects, processes, and stores Personal Data gathered via the Client’s use of the Service or where the Client has given consent.
This Personal Data may include contact details, copies of identification documentation provided by the Client or derived from publicly accessible databases, and a government identification number. Information about devices and internet service, such as IP address and a MAC number, is also classified as Personal Data. iFlyMedia gathers Persona Data during the registration and onboarding processes, regardless whether they are completed, incomplete, or abandoned.
iFlyMedia gathers, uses, stores, and transfers Personal Data, which includes the following:
• Operating within the European Economic Area (“EEA”).
• iFlyMedia collects, stores, and processes Personal Data in accordance with the Best Practices of Data Collection in the European Union (EU), in addition to the General Data Protection Regulation (GDPR) – EU Regulation 679/2016.
• Types of Clients defined in Appendix A.
- Collection and Storing of Data Outside the EU
As mentioned above, iFlyMedia may collect Personal Data from the Client located in the Economic European Area (EEA). To facilitate the services that it provides to clients located in the EEA, iFlyMedia requests explicit consent to transfer Personal Data from the EEA to outside the area. If the Client is an individual located in the EEA and declines to consent to such transfer, the Client will not be able to use iFlyMedia’s services.
- Personal Data Usage
iFlyMedia uses Personal Data to communicate with the Client and to administer, deliver, improve, and personalize the Service. iFlyMedia may also generate generic data out of any Personal Data collected and use it for its purposes.
iFlyMedia may also use such data to communicate with the Client in relation to its other products and services or in relation to services and products offered by its partners. iFlyMedia does not share Personal Data with third parties (except partners connected to its services), save those cases when the Client has given consent or other cases defined below.
- Cases When Personal Data Can be Shared with Third Parties
iFlyMedia may share Personal Data with third parties, when it considers that sharing it is necessary to enforce the terms of its Service.
iFlyMedia may share Personal Data to comply with government agencies, including regulators, law enforcement, and justice departments.
Personal Data may be sent to third parties providing services to iFlyMedia, among which are administration or technical services.
iFlyMedia shares Personal Data in connection with the sale or transfer of its business or any part thereof.
iFlyMedia has implemented international standards to prevent money laundering, terrorist financing, circumventing trade, and economic sanctions. It will implement final rules and regulations when effective and will require checking its clients’ Personal Data. This may include the use of data supplied by third-parties or service providers which iFlyMedia will cross-reference with the Client’s Personal Data.
- Storage of Personal Data
The Personal Data that iFlyMedia collects from the Client may be transferred to and stored at any location outside the European Union (EU).
Personal Data may be processed by employees operating outside of the European Union who work for iFlyMedia or its suppliers. By submitting the Client’s Personal Data, the Client agrees to this transfer, storing, or processing. This does not apply to clients located in the EEA, as detailed above.
Personal Data provided to iFlyMedia is stored on its own or a third party’s cloud servers.
- Access to and Correction of Personal Data
The Client has the right to obtain a copy of Personal Data upon request and ascertain whether the information iFlyMedia holds about the Client is accurate and updated.
If any part of Personal Data is inaccurate, the Client may request to update the information.
The Client may also request to delete Personal Data. iFlyMedia, however, may refuse to delete the Client’s Personal Data in certain circumstances, such as compliance with law, or for legal purposes. The Client should contact iFlyMedia for data access, correction, or deletion requests.
In response to data access, correction, or deletion request, iFlyMedia will verify the Client’s identity to ensure that the Client is legally entitled to make such request. iFlyMedia aims to respond to such requests free of charge. However, it reserves the right to charge the Client a reasonable fee should the request be repetitive or difficult to fulfill.
iFlyMedia communicates news, promotions, and information about its products and services. Therefore, it may share Personal Data with third parties for marketing purposes. By using iFlyMedia’s services, the Client agrees to receive such marketing communication.
The Client may refuse to receive marketing communication from iFlyMedia. In this case, clients need to ask iFlyMedia via email to stop sending them promotional and marketing material.
The Client does not have the right to opt out from such marketing communications as operational notifications and policy and terms updates.
- Information Security
iFlyMedia strives to protect the Client from unauthorized access, alteration, disclosure, or destruction of Personal Data that it collects and stores. iFlyMedia takes various measures to ensure information security, including encryption of the communication with SSL, required two-factor authentication for all sessions, periodic review of iFlyMedia’s Personal Data collection, storage, and processing practices. iFlyMedia also provides restricted access to the Client’s Personal Data on a need-to-know basis for its employees and vendors, who are subject to strict contractual confidentiality obligations.
- Contacting iFlyMedia about Privacy Concerns
Definition of Clients
Clients can be of two types: Individual Clients and Corporate Clients
Individual clients are expected to submit the following data:
- Email address
- Mobile phone number
- Full legal name (including former name and names in local language)
- Passport number, or any government issued Identification Document (ID) number
- Date of Birth (DOB)
- Proof of identity, such as passport, driver’s license, or government-issued ID
- Residential address
- Proof of residency
- Additional Personal Data or documentation at the discretion of iFlyMedia’s Compliance Team
Corporate clients are required to submit the following information:
- Incorporation or registration information
- Full legal name of all beneficial owners, directors, and legal representatives
- Address of business and other physical locations
- Proof of legal existence
- Description of the business
- Percentage of ownership for Individual and Corporate owners
- Contact information of owners, principals, and executive management (as applicable)
- Proof of identity (passport, driver’s license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity
- Personal Data for each entity’s significant beneficial owner of the institution customer entity (see the “Individual Customer” section above for details on what Personal Data iFlyMedia collects for individual clients)
- Source of wealth