Privacy Policy

1. Information We Collect.

The personal information we collect and obtain depends on how you interact with us, the Services you use, and the choices you make. When we use the term “personal information,” we are referring to information that identifies, relates to, describes, or can be associated with you. The following are the categories and specific types of personal information that we collect:

• Identity and Profile Information. This includes your phone number, email address, full name, address, and social security number.
• Financial Information. This includes your bank account numbers, debit, and/or credit card numbers that you link to your Flex account or give us when you use the Services. This may also include transaction data from financial accounts you authorize Flex to access.
• Geolocation Information. Including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
• Device Information. Including device identifiers, internet protocol (IP) addresses, cookies, beacons, pixel tags, mobile ad identifiers, or similar unique identifiers. Please see our Cookie Policy for more information.
• Biometric Data. We may collect information about your physical or biological characteristics such as photographs for verifying your identity or detecting fraud. 
• Customer Service Interaction Information. We collect information you provide when you engage with Flex’s customer service personnel and mechanisms, including through recorded phone calls, chat conversations, surveys, and email correspondence.
• Rental Information. Account information (including property management company or landlord name), rent balance information (including current and historical balance), due dates, balances owed, and transaction history. 
• Inference Data. Inferences drawn from or created based on any of the information identified above.
• Professional or Employment Information. Including business information, contact emails, phone numbers, and taxpayer ID numbers.
  
• Third Party Account Data. To help you manage your expenses in one place, you may be able to connect accounts from various service providers. If you do, we’ll collect information from those service providers, including bill amounts, due dates, login credentials, and other information you provide. This information is used to deliver our services to you. We may incorporate products and services that use artificial intelligence, including large language models and machine learning, to derive this information.

2.1. Directly from You.

We collect personal information you provide, such as when you register for an account, create a profile, or communicate with us.

We may use session replay technology to help us understand how you interact with our Website and App to troubleshoot and improve the user experience. This technology captures user interactions—such as clicks, scrolling, and typing behavior—so we can identify usability issues and optimize our content.

2.2. Third Parties.

We may also collect personal information from other third parties, including service providers, internet service providers, rent payment portals, property management companies, rental management service providers, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks, card networks, and financial institutions.

3. How We Use Your Personal Information.

3.1. To Provide Our Services.

Flex uses your information to provide our products and Services. For example, we may use information to provide customer service and support, process transactions, resolve disputes, collect payments, prevent fraud and illegal activities, customize the Services, authenticate and verify identities, and verify the accuracy of information.

3.2. To Improve Our Services.

Flex uses information to improve our services, conduct research and analysis, develop new or improved products and Services, contact you, and provide anonymous reporting to others.

3.3. To Serve You and Better Protect Your Data.

We may use information to protect you, our partners, Flex, and others from fraud, malicious activity, and other privacy and security-related concerns and to provide customer support to you, including to help respond to your inquiries related to our service or developers’ applications.

3.4. To Communicate with You and Market to You.

We may use your personal information to communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback, and to provide customer service. We may also use your information to send information to you about promotions, products or services of ours or our marketing partners that we believe may be of interest to you.

3.5. To Comply with Legal and Regulatory Obligations.

We may use your information to enable us to comply with applicable laws or regulatory processes.

3.6. Other.

We may also use your information for any other reasonable purpose to which you consent.

4. How We Protect Your Information.

4.1. Safety Policies.

Flex stores and processes your information while maintaining physical, electronic, and procedural safeguards. We maintain physical security measures to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorize access to personal information only for those employees or agents who require it to fulfill the responsibilities of their jobs.

5. How We Disclose Your Information.

5.1. For Our Business Purposes.

We disclose your information for a number of business purposes, including:

• To enforce any contract with you;
• To our data processors and other service providers, partners, or contractors in connection with the services they perform for us, including those who work to enhance our Website, the App, and/or our Services, those who protect the security of our systems, those who provide communications and marketing support to us, and those who provide research for technological development and demonstration;
• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
• In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
• Between and among Flex and our current and future parents, affiliates, subsidiaries, and other companies under common control or ownership;
• As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, our partners, Flex, and others; or
• For any other notified purpose with your consent.

We may also collect, use, and share information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

5.2 With Our Online Advertising Partners.

6. Retention of Your Personal Information.

We retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, to provide our Services, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with all applicable laws.

7. What Are Your Options?

7.1. Update Notifications.

If you no longer wish to receive notifications about our Services, you may change your notification preferences by emailing [email protected]. Alternatively, you may be able to indicate your preference by logging into your account and adjusting your preferences or by following the directions provided with the communication. Flex reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Services. You are still responsible for any amounts due to Flex even if we close or limit access to your account.

7.2. Update SMS Messaging.

You can opt out of receiving SMS messages by responding STOP to an individual message or by emailing [email protected]. Alternatively, you can update your communication preferences within the App. Again, Flex reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Services. You are still responsible for any amounts due to Flex even if we close or limit access to your account.

7.3. Access Your Information.

You can review and edit your personal information at any time by logging in to your account on the App or by contacting us at help@getflex.com. You can also request to close your account by contacting us at help@getflex.com. If you close your Flex account, we will mark your account in our database as “Closed,” but will keep your account information in our database to comply with our legal obligations. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

7.4. Contact Flex.

If you have questions or concerns regarding this Policy, please contact us at help@getflex.com.

8. Children’s Privacy.

In compliance with the Children’s Online Privacy Protection Act, our Services are not designed for or available to persons under the age of 18. We do not knowingly collect personal information or data from persons under the age of 18. If you are under the age of 18, do not use Flex or provide any information or data to Flex. If we learn that we have collected or received personal information or data from a person under the age of 18 without verification of parental consent, we will delete that information. If you believe that we may have any information from or about a person under the age of 18, please contact us at help@getflex.com.

9. Changes to This Policy. 

We may change this Policy from time to time by publishing a revised version on our Website or in the App. Your continued use of the Flex Website or the App after we make changes is deemed to be acceptance of those changes. Flex will notify you within thirty (30) days of any material change in Flex’s information collection, use, or disclosure.

10. State Consumer Privacy Rights.

Under the Gramm-Leach-Bliley Act (“GLBA”), Flex operates as a financial institution. This federal law governs how we collect and use your nonpublic personal information when you use our Services. As a result, certain state-specific privacy laws and their associated consumer rights do not apply to the nonpublic personal information that we collect to provide our Services. The consumer rights detailed below are applicable only to the data that we collect that falls outside of the scope of the GLBA, such as your browsing activity on our Website.

10.1. California Residents – Notice at Collection.

Under California law, you have the right to receive certain disclosures regarding the collection, use, and sharing of personal information. These disclosures apply only to information not subject to the GLBA or another applicable exemption. This section serves as our “Notice at Collection” under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act.

The following chart shows the categories of personal information that we may have collected during the past twelve (12) months, the sources of such information, the business purposes for which we may use such information, and the categories of third parties to whom we may disclose for such purposes.

For the table below, the list of examples for each category is intended to be illustrative and not exhaustive. We also may not collect or disclose every example listed (or use every example for each business purpose).