This Privacy Policy (the “Policy”) explains how Flowbit Finance L.L.C-FZ (“Flowbit”, “we”, “us”, or “our”) may collect, use, store, disclose, and protect the personal data of users when they access or use the Flowbit Services.

This Policy should be read together with the Flowbit Terms & Conditions. Capitalized terms used in this Policy shall have the meanings assigned to them in the Terms & Conditions and Appendix 1 to this Policy unless the context requires otherwise.

Flowbit does not seek to collect more personal data than is reasonably necessary for the operation of the Services, security, customer support, compliance with partner requirements, and applicable legal obligations. Certain Services may require only minimal information for basic use, while additional information may be requested where appropriate.

Flowbit Finance L.L.C-FZ is a company incorporated in the Meydan Free Zone, Dubai, United Arab Emirates.

Registration Number: 2541754

Registered Address:

Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates

Contact Email: [email protected]

Flowbit provides users with technology, interface, operational, and service access to selected card, payment, digital, and partner services where available and applicable.

This Policy applies to personal data processed in connection with registration, access to an Account, use of the website, mobile application, Telegram Mini App, customer support system, Cards, Virtual Balance, crypto top-ups, digital asset transactions, card transactions, digital products, referral and bonus programs, and any other Flowbit Services or features.

This Policy also applies to personal data processed when users contact customer support, request refunds, submit disputes or chargebacks, report unusual activity, protect an Account, satisfy partner requirements, or comply with applicable legal or regulatory obligations.

Certain third-party providers, including card issuers, payment service providers, card networks, identity verification providers, anti-fraud and compliance providers, custodians, and crypto service providers, may process personal data under their own policies and, where applicable, as independent data controllers.

Depending on the Services used, Flowbit may process the following categories of personal data.

Registration Information

• first and last name;

• username;

• email address;

• telephone number;

• country;

• preferred language;

• registration date;

• Account ID;

• Telegram ID; and

• other identifiers, where applicable.

Account and Service Usage Information

• Account settings;

• Card types and statuses;

• Virtual Balance information;

• transaction history;

• top-ups;

• payments;

• fees;

• limits;

• merchant information;

• Merchant Category Codes (MCCs);

• transaction statuses;

• refunds;

• disputes;

• chargebacks; and

• customer support history.

Technical Information

• IP address;

• device information;

• operating system;

• browser type;

• application version;

• device identifiers;

• system logs;

• cookies;

• session data;

• security events;

• crash reports; and

• diagnostic information.

Transaction Information

• transaction amounts;

• currencies;

• exchange rates;

• fees;

• transaction statuses;

• merchant information;

• Merchant Category Codes (MCCs);

• transaction country;

• transaction date and time;

• transaction ID;

• provider reference;

• blockchain transaction data;

• wallet address;

• blockchain network;

• memo/tag;

• transaction hash;

• blockchain confirmations; and

• settlement status.

Security and Anti-Fraud Information

• risk indicators;

• unusual activity;

• device intelligence;

• velocity patterns;

• failed attempts;

• declined transactions;

• chargeback and dispute patterns;

• abuse indicators;

• sanctions screening results;

• wallet screening results; and

• internal risk assessments.

Customer Support Information

• support requests;

• complaints;

• messages;

• screenshots;

• documents;

• transaction explanations;

• communication records; and

• support history.

Additional Verification Information

Where necessary, Flowbit may process information relating to:

• identity verification;

• email verification;

• telephone verification;

• device verification;

• payment instrument verification;

• wallet ownership verification;

• source of funds verification;

• explanations regarding specific transactions;

• supporting documentation; and

• any other information reasonably required in a particular case.

Marketing and Referral Information

Where applicable, Flowbit may process:

• referral codes;

• bonus history;

• campaign information;

• marketing consent;

• communication preferences; and

• related marketing information.

Flowbit may collect personal data from the following sources:

• directly from the user when the user registers, accesses an Account, applies for a Card, tops up a balance, performs transactions, contacts customer support, or provides information through Flowbit interfaces;

• automatically through the use of the Services, including information relating to the user’s device, browser, mobile application, Telegram Mini App, cookies, system logs, session data, security events, and diagnostic information;

• from partners and service providers involved in the operation of the Services, including card issuers, BIN sponsors, payment processors, card networks, merchant acquirers, crypto/liquidity providers, custodians, identity verification providers, anti-fraud and compliance providers, analytics providers, hosting providers, communication providers, and customer support providers;

• during the processing of transactions and operation of the Services, including transaction statuses, authorization results, declined transactions, dispute and chargeback records, provider references, technical security events, risk signals, and system logs.

Flowbit processes personal data for the following purposes:

• registering users and providing access to the Services;

• issuing, activating, maintaining, and supporting Cards;

• displaying Virtual Balance, card balances, transaction history, fees, and limits;

• processing top-ups, payments, crypto top-ups, digital asset transactions, refunds, disputes, and chargebacks;

• providing customer support and responding to user inquiries;

• protecting Accounts, Cards, devices, transactions, and the Services;

• preventing fraud, abuse, chargeback abuse, card testing, unauthorized access, and other forms of misuse;

• managing risks and protecting Flowbit, its users, partners, and the payment infrastructure;

• complying with the requirements of partners, card issuers, card networks, payment service providers, and applicable laws or regulations;

• conducting compliance reviews, sanctions screening, wallet screening, AML/CTF checks, and other verification procedures where required or appropriate;

• investigating suspicious transactions and protecting the legitimate interests of Flowbit;

• performing analytics, improving products and Services, diagnosing technical issues, and developing new functionality;

• complying with legal obligations and responding to lawful requests from competent authorities;

• sending service-related notifications; and

• sending marketing communications where permitted by applicable law or where the user has provided consent, if such consent is required.

Subject to applicable law, Flowbit may process personal data on one or more of the following legal bases:

• performance of a contract with the user, including the Terms & Conditions, this Policy, and related documents;

• Flowbit’s legitimate interests, including maintaining the security of the Services, preventing fraud and abuse, managing risks, protecting the rights of Flowbit, its users and partners, improving the Services, and ensuring operational reliability;

• compliance with legal, regulatory, and partner requirements, including the requirements of card schemes, card issuers, payment service providers, sanctions regimes, and other mandatory obligations;

• the user’s consent, where consent is required for a particular processing activity, such as certain marketing communications, cookies, or optional features; and

• protecting the legal rights, legitimate interests, or claims of Flowbit, its users, partners, service providers, or third parties.

Where processing is based on the user’s consent, the user may withdraw that consent to the extent permitted under applicable law. Withdrawal of consent does not affect the lawfulness of any processing carried out before such withdrawal and does not affect processing based on any other lawful basis.

Flowbit may process personal data to protect Accounts, Cards, Virtual Balance, transactions, users, partners, and the payment infrastructure.

Such processing helps detect and prevent unusual activity, fraud, abuse, card testing, unauthorized access, chargeback abuse, misuse of another person’s information, suspicious transactions, and other security risks.

For these purposes, Flowbit may analyze technical information, device information, transaction history, declined transactions, login attempts, customer support interactions, disputes, chargebacks, wallet addresses, merchant information, Merchant Category Codes (MCCs), transaction patterns, and other relevant information where necessary for the security of the Services, compliance with partner requirements, or applicable legal obligations.

Flowbit may use internal risk models, monitoring rules, and verification criteria. Flowbit is not required to disclose such models, rules, suspicious activity indicators, or the reasons for any specific risk decision where such disclosure could reduce the security of the Services, violate partner requirements, interfere with an investigation, or facilitate abuse.

To provide card services, process top-ups, crypto top-ups, digital asset transactions, Virtual Balance functionality, and transaction history, Flowbit may process transaction-related information, including transaction amounts, currencies, exchange rates, fees, dates, statuses, merchant information, Merchant Category Codes (MCCs), provider references, card status, settlement status, blockchain transaction data, wallet addresses, blockchain networks, memos/tags, transaction hashes, and other transaction-related information.

Such information is necessary to display balances and transaction history, process transactions, verify transaction status, enable partner services, process refunds, disputes and chargebacks, perform technical adjustments, investigate errors, prevent fraud, and comply with partner requirements.

Transaction data may be shared with relevant card issuers, card networks, payment processors, merchant acquirers, crypto/liquidity providers, custodians, compliance providers, anti-fraud providers, and other service providers where necessary to provide a particular Service, process a transaction, maintain security, or comply with applicable legal or regulatory requirements.

When a user contacts Flowbit customer support, we may process support requests, messages, attachments, screenshots, documents, transaction explanations, contact information, communication history, and communication records.

This information is used to respond to inquiries, identify and resolve issues, verify transactions, process refunds, disputes or chargebacks, restore access to an Account, prevent abuse, improve customer support, and protect the rights and legitimate interests of Flowbit.

Flowbit may communicate with users through Flowbit interfaces, the mobile application, website, Telegram Mini App, email, SMS, push notifications, the customer support system, or any other communication channels provided by the user or made available as part of the Services.

Service messages, transaction notifications, requests for additional information, security alerts, and legally required notices may be delivered electronically.

Flowbit may use cookies, analytics tools, software development kits (SDKs), system logs, and similar technologies to operate its interfaces, authenticate users, maintain security, preserve user sessions, prevent abuse, diagnose technical issues, improve the Services, and evaluate the performance of specific features.

Users may manage cookies through their browser or device settings where such functionality is available. Disabling certain cookies or similar technologies may affect the availability or functionality of certain Flowbit Services.

Certain technical data and technologies are essential for authentication, security, and the proper operation of the Services. Such technologies cannot always be disabled without preventing the use of the relevant Service or functionality.

Flowbit may disclose personal data to third parties where necessary to provide the Services, process transactions, operate Cards, maintain security, provide customer support, ensure compliance, satisfy partner requirements, protect the rights of Flowbit, or comply with applicable law.

Recipients of personal data may include:

• Flowbit affiliates or group companies, where applicable;

• card issuers, BIN sponsors, payment processors, card networks, and merchant acquirers;

• crypto/liquidity providers and custodians;

• identity verification providers, sanctions screening providers, wallet screening providers, anti-fraud providers, and risk management providers;

• hosting providers, cloud service providers, analytics providers, logging providers, diagnostic service providers, communication providers, and customer support providers;

• legal, tax, audit, and other professional advisers;

• regulatory authorities, courts, law enforcement agencies, and other competent authorities where required or permitted by law; and

• parties involved in an actual or proposed merger, acquisition, restructuring, financing, sale of assets or business, transfer of the operating model, or similar corporate transaction.

Certain third-party providers may process personal data as independent data controllers under their own privacy policies, legal obligations, and internal procedures. Flowbit does not necessarily control such independent processing.

Flowbit may transfer, store, and process personal data outside the user’s country of residence, including in jurisdictions where Flowbit, its partners, service providers, payment infrastructure, card infrastructure, technology providers, cloud providers, analytics providers, and customer support providers are located.

Such international transfers may be necessary to provide the Services, process transactions, issue and maintain Cards, process top-ups, crypto top-ups, provide customer support, maintain security, prevent fraud, perform compliance checks, satisfy partner requirements, and comply with applicable legal or regulatory obligations.

When transferring personal data internationally, Flowbit takes reasonable measures to protect personal data, taking into account applicable law, the nature of the data, the purposes of processing, and available contractual, technical, and organizational safeguards.

The user acknowledges that the use of international card, payment, crypto, cloud, analytics, customer support, and other service providers may require the transfer of personal data between different jurisdictions.

Flowbit retains personal data for as long as reasonably necessary to achieve the purposes described in this Policy, including providing the Services, maintaining Accounts, providing customer support, ensuring security, preventing fraud, processing disputes and chargebacks, complying with partner requirements, and fulfilling accounting, tax, audit, compliance, legal, and operational obligations.

As a general rule, personal data may be retained for the duration of the user’s Account. After an Account has been closed, Flowbit may continue to retain certain information where necessary to comply with applicable law, satisfy partner or service provider requirements, prevent fraud, investigate suspicious activity, process disputes, chargebacks, refunds, or negative balances, protect the rights of Flowbit, or satisfy accounting, tax, audit, or legal obligations.

Certain categories of information relating to transactions, Cards, verification procedures, compliance, disputes, chargebacks, security, anti-fraud activities, legal obligations, or partner requirements may be retained for at least five (5) years following the closure of an Account, completion of a transaction, termination of the relationship with the user, or completion of the relevant dispute, investigation, or review, unless a longer retention period is required or permitted under applicable law, partner requirements, service provider obligations, card network rules, court orders, regulatory requirements, or decisions of competent authorities.

Where personal data is no longer required for the purposes for which it was collected, and continued retention is not required by applicable law, partner requirements, security, dispute resolution, chargeback handling, fraud prevention, compliance obligations, or protection of Flowbit’s rights, Flowbit may delete, anonymize, or restrict the processing of such personal data where reasonably practicable and technically feasible.

Flowbit implements reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, alteration, disclosure, misuse, or destruction.

Such measures may include access controls, restrictions on employee and service provider access, technical safeguards, logging, security monitoring, internal procedures, suspicious activity detection, and other reasonable security measures.

However, no method of transmitting or storing information is completely secure. Users are also responsible for maintaining the security of their Account, device, Telegram account, email account, telephone number, passwords, PINs, one-time passwords (OTPs), Card information, and any other credentials used to access the Services.

Subject to applicable law, users may have the right to:

• request access to their personal data;

• request correction of inaccurate or outdated personal data;

• request the deletion of personal data;

• request restriction of the processing of personal data;

• object to the processing of personal data;

• request data portability;

• withdraw consent where processing is based on consent; and

• lodge a complaint with a competent supervisory authority.

Certain requests may be restricted, delayed, or declined where personal data is required for providing the Services, maintaining security, preventing fraud, risk management, compliance, processing disputes or chargebacks, satisfying partner requirements, complying with legal obligations, or protecting the rights and legitimate interests of Flowbit.

To exercise any of these rights, users may contact Flowbit through its official customer support channels or by email at: [email protected].

Flowbit may request proof of identity or additional information where reasonably necessary to process such requests securely.

Flowbit may send users marketing communications, promotional offers, product updates, campaign information, referral and bonus notifications, and other promotional or informational materials where permitted under applicable law or where the user has provided consent, if such consent is required.

Users may opt out of receiving marketing communications through the available account settings, an unsubscribe link, Flowbit customer support, or any other method made available for this purpose.

Opting out of marketing communications does not affect the delivery of service-related notifications that are necessary for the operation of the Services, Account security, transactions, Cards, customer support, or legally required communications.

Flowbit may send users service-related notifications concerning their Account, Cards, Virtual Balance, transactions, fees, limits, security, customer support, updates to legal documents, risk reviews, disputes, chargebacks, and other important aspects of the Services.

Such notifications form an integral part of the Services and may be delivered through the mobile application, website, Telegram Mini App, email, SMS, push notifications, the customer support system, or any other available communication channels.

Users may not be able to opt out of certain service notifications where such notifications are necessary for the operation of the Services, security, compliance with partner requirements, or applicable legal obligations.

The Flowbit Services are not intended for individuals under the age of 18 or any higher minimum age required under applicable law to independently enter into a legally binding agreement or use the relevant Services.

Flowbit does not knowingly collect personal data from children or individuals who do not meet the applicable age requirements for using the Services.

If Flowbit becomes aware that personal data has been provided by an individual who is not legally eligible to use the Services due to age restrictions, Flowbit may restrict the relevant Account, delete or limit the processing of such personal data, and take any other reasonable measures permitted under applicable law.

Flowbit interfaces may contain links to, integrations with, or provide access to third-party websites, applications, platforms, providers, or services.

Such third parties may maintain their own privacy policies, terms of service, cookie policies, and security practices. Flowbit is not responsible for the independent processing of personal data carried out by such third parties where that processing takes place outside Flowbit’s control.

Users should review the applicable policies and terms of any third-party services they choose to use.

Flowbit may update this Policy from time to time to reflect changes to the Services, technologies, partner requirements, applicable laws, or internal business processes.

Updates may be published through Flowbit interfaces, the mobile application, website, Telegram Mini App, customer support system, email, push notifications, or other electronic communication channels.

Unless a later effective date is specified in the updated Policy or applicable law requires otherwise, the revised Policy shall become effective upon publication or otherwise being made available to users.

By continuing to use the Services after the updated Policy becomes effective, the user acknowledges and accepts the revised Policy.

Flowbit Finance L.L.C-FZ

Registration Number: 2541754

Registered Address:

Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates

Email for Privacy Inquiries: [email protected]

Users may contact Flowbit regarding the processing of personal data through the official Flowbit customer support channels available within the Services or by email at: [email protected].

Flowbit may request proof of identity or additional information where reasonably necessary to process such requests securely.

Account – a user account or profile created or used to access the Flowbit Services.

Applicable Law – any applicable laws, regulations, rules, court orders, sanctions programs, card network rules, issuer requirements, service provider requirements, and any other legally binding obligations.

Card – a virtual or physical payment card made available through Flowbit and issued by a third-party card issuer, card program partner, or other authorized provider.

Chargeback – the process of disputing a card transaction through a card issuer, card network, payment system, or another relevant partner. A chargeback does not guarantee that funds will be refunded.

Digital Assets – cryptocurrencies, tokens, stablecoins, or other digital assets that may be supported by Flowbit or its service providers.

Dispute – a request, claim, or dispute submitted by a user regarding a card transaction, refund, charge, fee, or another transaction relating to the Services.

Flowbit – Flowbit Finance L.L.C-FZ.

Merchant – a merchant, service provider, platform, seller, or supplier of goods or services that accepts or attempts to accept payment using a Card.

Partner / Provider – any third party involved in providing, processing, verifying, settling, supporting, securing, monitoring, or maintaining the Services.

Personal Data – any information relating to an identified or identifiable individual that constitutes personal data under Applicable Law.

Services – all products, features, interfaces, and services provided by or made available through Flowbit, including Cards, Virtual Balance, top-ups, digital asset transactions, card transactions, customer support, transaction history, digital products, partner services, and any related functionality.

Virtual Balance – an account balance or displayed value within Flowbit interfaces used for the functionality of the Services.

User / you – any individual who accesses or uses the Flowbit Services.