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RESPONSIBLE FOR TREATMENT: KIBIBYTE, S.L. DPD: PYMELEGAL, S.L. PURPOSE: Respond to the user's request. LEGITIMATION: Consent of the interested party. ASSIGNMENTS: No assignments are foreseen, except by legal obligation or judicial requirement. RIGHTS: Access, rectification, deletion, opposition, limitation, portability, revocation of consent. If you consider that the processing of your data does not comply with the regulations, you can go to the Control Authority (AEPD). ADDITIONAL INFORMATION: Privacy Policy
RESPONSIBLE FOR TREATMENT: KIBIBYTE, S.L. DPD: PYMELEGAL, S.L. PURPOSE: Respond to the user's request to receive the demo. LEGITIMATION: Consent of the interested party. ASSIGNMENTS: No assignments are foreseen, except by legal obligation or judicial requirement. RIGHTS: Access, rectification, deletion, opposition, limitation, portability, revocation of consent. If you consider that the processing of your data does not comply with the regulations, you can go to the Control Authority (AEPD). ADDITIONAL INFORMATION: Privacy Policy
RESPONSIBLE FOR TREATMENT: KIBIBYTE, S.L. DPD: PYMELEGAL, S.L. PURPOSE: Respond to the user's request. LEGITIMATION: Consent of the interested party. ASSIGNMENTS: No assignments are foreseen, except by legal obligation or judicial requirement. RIGHTS: Access, rectification, deletion, opposition, limitation, portability, revocation of consent. If you consider that the processing of your data does not comply with the regulations, you can go to the Control Authority (AEPD). ADDITIONAL INFORMATION: Privacy Policy
INDEX
1. How we treat your personal data
To manage your relationships with us, at SEFIDE EDE (hereinafter, SEFIDE) we will process your personal data to fulfill different purposes, always in accordance with the provisions of current regulations, respecting your rights and with total transparency.
To do this, in this Privacy Policy, which you can access at any time from https://sefide.com/politica-de-privacidad/ you can consult the full details of how we will use your data in the relationships we establish with you. Likewise, if you wish, you can request this information on paper at any of our offices.
The main regulations that regulate the treatments that we will do with your personal data are:
2. Who treats your data
Responsible for the treatment: The person in charge of the treatment of your personal data in your contractual and business relations with us (“Contractual Relations”) is SEFIDE EDE, SLU, with NIF B-93205474 and address at Avenida de la Ciencia, 2-3ª Plant – Postal Code 18006 of Granada.
Co-responsible for treatment: In addition, for certain treatments that we will inform you in detail in this policy, SEFIDE will treat your data jointly, deciding the objectives (“what the data is used for”) and the means used (“how the data is used”). being, therefore, responsible for these treatments.
The treatments for which SEFIDE will jointly process your data are described in detail in section 6 “What treatments we carry out with your data”.
3. Data Protection Delegate
SEFIDE has appointed a Data Protection Officer , who will assist you to answer any question related to the processing of your personal data and the exercise of your rights.
You can contact the Data Protection Delegate to send your suggestions, questions, doubts or claims through this address: dpo@sefide.com
4. Exercise of rights and presentation of claims before the Spanish Data Protection Agency (AEPD)
You can exercise your rights of access, rectification, opposition, deletion, limitation, portability and forgetting of your personal data, to withdraw your consent and not to be the subject of an automated decision, in accordance with the law.
You can request to exercise these rights through any of the following channels:
5. Data categories
At SEFIDE we will process different personal data in order to manage the Contractual Relationships that you establish with us, to carry out the rest of the data processing that derives from your condition as a client and, if you have given us your consent, to also carry out the processing of your data for the activities detailed in section 6.1.
To facilitate your understanding, we have arranged the data we process in the categories that we detail below.
Not all the categories of data that we detail are used for all data processing. In section 6, where we detail the data processing that we carry out, you can consult specifically for each specific processing the categories of data that are used, thus having the necessary information that allows you to exercise, if you wish, your recognized rights. by the RGPD, especially those of opposition and revocation of consent.
The categories of data used by the different treatments exposed in section 6 are the following:
6. What treatments we carry out with your data
The treatments that we will carry out with your data are diverse, and respond to different purposes and legal bases:
6.1. Processing based on consent
These treatments have your consent as a legal basis, as established in art. 6.1.a) of the General Data Protection Regulation (RGPD).
We may have requested that consent through different channels, for example, in the process in which you registered as a customer, through our electronic channels. If for any reason, we have never requested your consent, these treatments will not apply to you.
You can consult the authorizations that you have consented or denied us, and modify your decision at any time and free of charge at our offices, on the SEFIDE website (www.sefide.com), or in your private area of the website or applications SEFIDE mobiles.
The treatments based on your consent are indicated below in order of (1) to (4). We will indicate for each of them: the description of the purpose (Purpose), whether or not they are treatments carried out under a co-responsibility regime (Joint Controllers/Data Controller), and the categories of data used (Categories of processed data).
In the event that you have given your consent for the processing of your data for commercial purposes.
(1). Commercial offer of products and services through the selected channels
Purpose: The purpose of this data processing is to make commercial offers available to you only through the channels that you have authorized by giving us your consent.
We will only carry out this processing of your data if you have given us your consent to do so. Your consent will remain in effect as long as you do not withdraw it.
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Categories of processed data: The category of data that we will process for this purpose, whose content is detailed in section 5, is:
(two). Transfer of data to companies that are not part of the SEFIDE group
Purpose: The purpose of this treatment is to transfer your data to companies that are not part of the SEFIDE group with which we have agreements, in order for them to make commercial offers of products that they market. Those third companies to which we could transfer your data are dedicated to banking activities and consulting services.
That you authorize us to transfer your data does not mean that we do so immediately. If we reach an agreement with a third company to transfer your data, the recipient company will inform you of this circumstance, as well as the details of the treatment it intends to carry out.
We will only carry out this processing of your data if you have given us your consent to do so. Your consent will remain in effect as long as you do not withdraw it.
If you cancel all your products or services with the SEFIDE Group companies, but forget to withdraw your consent, we will do so automatically.
Categories of processed data: The category of data that we will process for this purpose, whose content is detailed in section 5, is:
(3). Identification of clients and signature of documentation through the use of biometrics
Purpose: The purpose of this data processing is to use technical means that use biometrics to verify your identity and your signature in the relations you maintain with SEFIDE.
Your authorization to this treatment will allow us to request the registration of your facial image, voice or fingerprints with the help of biometric recognition methods, to later contrast them with the originals when we need to verify your identity or your acceptance of contracts or operations. The registration of your biometrics is completely voluntary, and we will only carry out this processing of your data if you have given us your consent to do so. Your consent will remain in effect as long as you do not withdraw it.
If you do not give us your consent for this treatment, it does not mean that you stop accessing any product or service offered by SEFIDE. In that case we will carry out the tasks of verifying your identity and signature by means that do not use biometrics.
If you cancel all of your products or services, but forget to withdraw your consent, we will automatically do so with the cancellation of the last of your products and/or services.
Categories of processed data: The category of data that we will process for this purpose, whose content is detailed in section 5, is:
Responsible for the treatment: The person in charge of this treatment is SEFIDE. There are no treatments in co-responsibility with other responsible parties.
(4). Application of personal conditions in co-ownership contracts
Purpose: The purpose of this data processing is to be able to apply discounts or preferential conditions to which you are entitled by SEFIDE's commercial offer, in contracts in which you are not the sole owner.
Within our commercial offer, customers can sometimes access discounts or advantages associated with personal characteristics, such as age, employment status, the number of contracted products, account balances, or similar.
If those discounts or preferential conditions apply in contracts in which you share ownership with other clients, they could know that you meet, or have not met, the requirements that give access to those discounts or preferential conditions.
For example, if you were entitled to access discounts for belonging to a certain professional group, such as health personnel or security forces, the rest of the holders would know that you meet this characteristic when they see that these discounts are applied to the account .
Due to the foregoing, and given that this circumstance could affect your privacy, we will apply your commercial conditions in the contracts in which you are the sole owner, and we will only carry out this treatment in contracts that you share with other parties if you have given us your consent, which will remain in force as long as you do not withdraw it.
If you cancel all of your products or services, but forget to withdraw your consent, we will automatically do so with the cancellation of the last of your products and/or services.
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
Responsible for the treatment: The person in charge of this treatment is SEFIDE. There are no treatments in co-responsibility with other responsible parties.
6.2. Treatments necessary for the execution of contractual relations
These data treatments have as a legal basis the fact that they are necessary to manage the contracts that you request or in which you are a party, or to apply, if you request it, pre-contractual measures, as established in art. 6.1.b) of the General Data Protection Regulation (RGPD).
Therefore, they are necessary treatments for you to establish and maintain Contractual Relations with us. If he opposed them, we would end those relationships, or we would not be able to establish them if we had not already started them.
The treatment necessary for the execution of contractual relations is indicated below as point (1). It is indicated: the description of the purpose (Purpose), whether or not they are treatments carried out under a co-responsibility regime (Joint Controllers/Responsible for the treatment), and the categories of data used (Categories of processed data).
(1). Formalization, maintenance and execution of Contractual Relations
Purpose: The purpose of this data processing is to formalize and maintain the Contractual Relations that you and we establish.
This includes the treatment of your requests or mandates, the procedures prior to a contract (pre-contractual relationships) and the processing of your requests for access to draws, promotions or events.
This data processing involves collecting the information necessary to establish the relationship or manage the request, evaluate the suitability of the contract and process the information necessary for the correct maintenance and execution of the contracts.
The treatment operations that are carried out in the formalization, maintenance and execution of the Contractual Relations, are:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
Responsible for the treatment: The person in charge of this treatment is SEFIDE. There are no treatments in co-responsibility with other responsible parties.
In addition, if the product or service you contract is marketed by SEFIDE, but it is issued by another company, this company will be responsible for processing your data in relation to that contract.
6.3. Treatments necessary to comply with regulatory obligations
These data treatments have as legal basis the fact that they are necessary to comply with a legal obligation that is required of us, as established in art. 6.1.c) of the General Data Protection Regulation (RGPD).
Therefore, they are necessary for you to establish and maintain Contractual Relations with us. If he opposed them, we would have to end those relations, or we would not be able to establish them if we had not already started them.
The treatments necessary to comply with regulatory obligations are indicated below, ordered from (1) to (3). We will indicate for each of them: the description of the purpose (Purpose), whether or not they are treatments carried out under a co-responsibility regime (Co-responsible/Responsible for the treatment), and the categories of data used (Categories of processed data)
(1). Treatments to comply with the regulations for the prevention of money laundering and the financing of terrorism
Purpose: The purpose of these treatments is to adopt the measures imposed on our activity by Law 10/2010, on the Prevention of Money Laundering and the Financing of Terrorism. The treatment operations that are carried out to comply with the regulations on the prevention of money laundering and the financing of terrorism are:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
(two). Treatments to comply with tax regulations
Purpose: The purpose of these treatments is the adoption of the measures imposed on our activity by Law 58/2003, of December 17, General Tax, and other current tax regulations.
The processing operations carried out to comply with tax regulations are:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
(3). Treatments for the fulfillment of the obligations derived from the policies of sanctions and international financial countermeasures
Purpose: The purpose of these treatments is to adopt the measures imposed on our activity in the international financial sanctions and countermeasures programs adopted by the European Union and the Kingdom of Spain.
The processing operation carried out to comply with international financial sanctions and countermeasures programs is:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
6.4. Treatments based on the legitimate interest of SEFIDE
These treatments have as a legal basis the satisfaction of legitimate interests pursued by SEFIDE or by a third party, provided that your interests or your fundamental rights and freedoms do not prevail over those interests, as established in art. 6.1.f) of the General Data Protection Regulation (RGPD).
Carrying out these treatments will imply that we will have made a weighing between your rights and our legitimate interest in which we will have concluded that the latter prevails.
Otherwise, we would not carry out the treatment. You can consult at any time the weighting analysis of the legitimate interest of a treatment by sending your query to the email address dpo@sefide.com
Likewise, we remind you that you have the right to object to processing based on legitimate interest. You can do so easily and free of charge through the channels indicated in section 4.
We detail these treatments below, ordered from (1) to (3). We will indicate for each of them: the Legitimate Interest of SEFIDE, the description of the purpose (Purpose), whether or not they are treatments carried out under a co-responsibility regime (Joint Controllers/Data Controller), and the categories of data used (Categories of data treated)
(1). Performance management of employees, agents and suppliers
Legitimate Interest of SEFIDE: The legitimate interest of SEFIDE to carry out this treatment is to carry out a management of relations with employees and suppliers based on the analysis of their professional performance.
Purpose: The purpose of this treatment is to analyze the operations and contracts that employees, agents and suppliers maintain with clients, in order to monitor their professional performance.
In these data treatments, the information of the clients is treated, but their information is ancillary to the purpose pursued. These treatments have no effect or consequence for the owner of the data.
The treatment operations that are carried out management of the performance of employees, agents and suppliers is:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
Responsible for the treatment: The person in charge of this treatment is SEFIDE. There are no treatments in co-responsibility with other responsible parties.
(two). fight against fraud
Legitimate Interest of SEFIDE: The legitimate interest of SEFIDE to carry out this treatment is to avoid fraud that supposes economic or reputational losses.
Purpose: The purpose of this treatment is to fight against fraud that may affect both SEFIDE and you and the rest of our clients.
The processing operations carried out in the fight against fraud are:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
Responsible for the treatment: The person in charge of this treatment is SEFIDE. There are no treatments in co-responsibility with other responsible parties.
(3). Creation of statistical reports for the monitoring and management of SEFIDE's activity
Legitimate Interest of SEFIDE: SEFIDE's legitimate interest is to monitor the evolution of the Entity's business, study the behavior and evolution of the client portfolio, products and services and design new ones.
Purpose: The purpose of this treatment is to carry out statistical reports and mathematical models that allow the monitoring of the Entity's activity.
The treatment operations that are carried out in the creation of statistical reports for the monitoring and management of SEFIDE's activity are:
Categories of processed data: The categories of data that we will process for this purpose, whose content is detailed in section 5, are:
Responsible for the treatment: The person in charge of this treatment is SEFIDE. There are no treatments in co-responsibility with other responsible parties.
7. Data recipients
Responsible and co-responsible for data processing
The data that we process as a client of SEFIDE is processed by SEFIDE.
Authorities or official bodies
Credit institutions, electronic money institutions (such as SEFIDE) and other payment service providers may be legally obliged to provide information about the transactions we carry out to the authorities or official bodies of other countries located both within and outside the European Union. . This obligation occurs within the framework of the fight against the financing of terrorism and serious forms of organized crime and the prevention of money laundering, as well as within the framework of the prudential supervision of credit institutions carried out by the Bank of Spain and the European Central Bank.
Payment systems and service providers may also be subject to this obligation.
technology with which we maintain relationships and to which we transmit data to carry out transactions.
Files of compliance or non-compliance with monetary obligations
If you fail to pay any of the monetary obligations that you have contracted with us regarding our Contractual Relations, we may communicate, under the conditions and with the requirements provided in the regulations, the data of the non-payment to the following credit information systems:
Likewise, we inform you that you can exercise your rights of access, rectification, opposition, deletion, limitation, portability and forgetting of your personal data and not be subject to an automated decision, in accordance with the law, before these files of compliance or non-compliance in the addresses that we have indicated.
Data communication in service outsourcing
Sometimes, we use service providers with potential access to personal data. These providers provide adequate and sufficient guarantees in relation to data processing, since we carry out a responsible selection of service providers that incorporates specific requirements in the event that the services involve the processing of personal data.
The type of services that we can order from service providers is:
8. Data retention periods
Conservation for the maintenance of Contractual Relations
We will treat your data while the Contractual Relations that we have established remain in force.
Conservation of authorizations for treatments based on consent
We will process data based on your consent, until you revoke it.
If you cancel all your contracts for products and services with the companies of the SEFIDE group, but you do not revoke the consents that you have given us, we will automatically cancel them as soon as you are no longer a client.
Conservation for the fulfillment of legal obligations and formulation, exercise and defense of claims
Once the authorizations for the use of your data have been revoked by withdrawing your consent, or the contractual or business relationships you have established with us have ended, we will keep your data only to comply with legal obligations and to allow the formulation, exercise or defense claims during the statute of limitations for actions arising from contractual relationships.
We will treat this data applying the necessary technical and organizational measures to guarantee that they are only used for these purposes.
data destruction
We will destroy your data when the retention periods imposed by the rules that regulate the activity of SEFIDE and the statute of limitations for administrative or judicial actions arising from the relationships established between you and us have elapsed.
9. Data transfers outside the European Economic Area
SEFIDE does not transfer data to third countries or to countries that have not been declared to have an adequate level of security.
In the event that SEFIDE needs to use service providers that carry out treatments outside the European Economic Area or in countries that have not been declared with an adequate level of protection, as established by both the General Data Protection Regulation ("RGPD") such as Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (" LOPDPyGDD "), SEFIDE will ensure to guarantee the security and correct treatment of customer data.
To do this, we require the appropriate guarantees from these service providers in accordance with the provisions of the RGPD so that they have, for example, binding corporate regulations that guarantee the protection of information in a similar way to that established by European regulations or that subscribed to the standard clauses of the European Union.
Likewise, SEFIDE would inform you of the existence of these transfers to third countries.
10. automated decisions
If during the Contractual Relations that it maintains with SEFIDE, through the enabled channels, SEFDIE adopts decisions based exclusively on automated processing, that is, without human intervention, that could produce legal effects on the Client or that could significantly affect him, such as It may be the denial to formalize the contracting of a SEFIDE product, you will be informed about it in compliance with current regulations.
Likewise, SEFIDE will adopt measures to safeguard the rights and interests of the Client, facilitating the right to challenge the decision and obtain human intervention.
SEFIDE will only carry out automated decisions when based on:
11. Revision
We will review this Privacy Policy whenever it is necessary to keep you duly informed, for example, due to the publication of new rules or criteria or the performance of new treatments.
We will notify you through the usual communication channels whenever there are material or important changes to this privacy policy.
1. What is 3DS?
3DS (also known as "Mastercard SecureCode", "Identity Check" and "Verified by Visa") is a standard that helps reduce fraud and provides additional security to your online payments. Authentication is the process by which you identify yourself by sharing secure information that is only available to you. 3DS 2.0 is the latest version and provides a much simpler and more secure process for you to authenticate your payments.
2. What is the use of authentication?
Authentication provides an extra layer of security for online transactions, making it harder for fraudsters to access your payment details.
3. Is 3DS active on my card?
Yes, your card has been enrolled in Mastercard SecureCode (3DS) so whenever you see the Mastercard SecureCode logo online, your card number will be automatically recognized during checkout. Your card provider is contacted during the payment process to confirm your identity as the genuine cardholder.
4. What is the authentication process?
You will receive a 6-digit One Time Password (OTP) for each online purchase you make at participating merchants. The OTP will be sent via SMS or email to the mobile phone or email address you have registered with your card provider. Simply enter the OTP on the displayed authentication page and press the "Submit" button. Your card provider will then verify the OTP and the transaction will either be approved or declined.
5. How will I know if the registered mobile number or email address is correct?
The partially masked mobile number and email address will be displayed on the authentication page so you can verify that those details are correct. If the mobile phone number and email address are incorrect, cancel the transaction and update your information on the portal or contact Customer Services by calling 965 168 192 or writing to info@flexoh.com.
6. What if I suspect fraud has occurred on my card?
If you ever suspect that a fraudulent purchase has been made with your card, contact Customer Services by calling 965 168 192 or writing to info@flexoh.com immediately.
GENERAL CONDITIONS
This agreement for opening an electronic money account and processing transactions with electronic money, as well as, where appropriate, the attached annexes, (collectively referred to as the “Contract”) is a contract between the Client, whose data must be duly filled out in the Particular Conditions form or in the access form for the provision of electronic money services and, on the other hand, SEFIDE, EDE, SLU (hereinafter “SEFIDE”), an electronic money institution duly authorized by the Ministry of Economy and registered in the Official Registry of Entities of the Bank of Spain with code number 6705. The Client must read and, if they agree, accept and sign this contract , whose General Conditions are defined below.
EXPOSE
Hereinafter, the Client and SEFIDE will also be referred to individually as the “Party” and jointly as the “Parties”. Consistent with the foregoing, the Parties signing this contract, carry it out, in accordance with the provisions of the following
STIPULATIONS
1.- Request to open an electronic money account
1.1 By this contract, in accordance with the provisions contained therein and, where appropriate, with the particular conditions agreed by the parties, the opening of an Electronic Money account is formalized, in favor of the Client.
2.- Object of the Contract
2.1 The provision of services by SEFIDE will allow the client to have an electronic money account to which a "mirror account" will be associated in Banco Inversis SA, with which they will have an IBAN in the National Electronic Compensation System that It will allow you to have direct debit services and the issuance and receipt of transfers.
2.2 Due to the Entity's operations, SEFIDE has signed an agreement through which Banco Inversis makes an omnibus account available and owned by SEFIDE through which the debit service will be provided.
Through this omnibus account, each client will have an account at Banco Inversis , called a "mirror account" which will be the one used to carry out payment services, since this account will have an IBAN recognized in the exchange system.
2.3 If requested by the client, the contract model between the Entity and Banco Inversis for the provision of the service may be made available to them. The Entity guarantees the absolute separation of client funds in the Banco Inversis account and will be responsible for any damages that could be caused to clients by their confusion.
2.4 The client consents, by signing this contract, to the transfer to Banco Inversis of those personal data that are strictly necessary to carry out the operations covered by this contract.
2.5 These mirror accounts will have a unique IBAN, will be owned by SEFIDE and will be linked to the settlements made in the user's accounts due to the operations carried out by the latter. In this way, SEFIDE will make information about the IBAN code available to the user so that the following operations can be carried out:
SEFIDE guarantees that, in the cases of use of the Mirror Accounts, the obligations of separation and control of funds are fulfilled as indicated in the fifth point below.
2.6 The electronic money account will be operational once the necessary documentation requirements are met to carry out the corresponding customer registration process, (" onboarding " in its Anglo-Saxon terminology), corresponding to the identification and verification of the customer's identity, of the beneficial owner and the purpose and nature of the business relationship.
2.7 Once the electronic money account is operational, the Client will be able to exchange fiat money for electronic money through top-ups through various means of payment, from an account opened in a credit institution operating in Spain, which can be extended to any country of the European Union or the European Economic Area if expressly agreed in the Particular Conditions. Once the funds are received, SEFIDE will issue the corresponding electronic money, SEFIDE always complying with the safeguard obligation imposed by Law 21/2011, of July 26, on electronic money.
3.- Entry and reimbursement of funds for the issuance of electronic money
3.1 SEFIDE offers different options for the Client to top up the funds in their electronic money account, among others, by bank transfer and by transfer from another electronic money account opened in SEFIDE or by means of a card issued by a Credit Institution. The funds delivered by the Client will be exchanged immediately for electronic money. These funds will not constitute deposits or other reimbursable funds from the public in the sense of what is established in the banking legislation. Likewise, no interest of any kind will be generated in favor of the Client.
3.2 Ownership of the electronic money account is non-transferable and may be subject to certain limitations on deposits, payments and withdrawals in accordance with the legislation in force, especially the legislation on the prevention of money laundering and the financing of terrorism.
3.3 The Client may make transfers from his electronic money account to other users who have an electronic money account also opened in SEFIDE.
3.4 The client may request the reimbursement of his electronic money balance in the terms provided in this contract, in such a way that SEFIDE will reimburse the holder of the electronic money when he so requests, at all times and for its nominal value, is that is, the monetary value of the electronic money available at the time of requesting the aforementioned reimbursement. If the Client does not indicate otherwise, the refund will be made to the same account from which the funds were deposited. If this is not the case, the funds may only be reimbursed to another account of which the Client is the owner and opened in a Credit Institution within the Spanish national territory.
3.5 The Client will be able to access the history of the movements and transactions carried out in his electronic money account. The movements in your electronic money account will be identified with their corresponding day and time, and will appear in your transaction history. It is recommended to periodically check the balance of your electronic money account and your transaction history, as well as read the messages related to your account sent by SEFIDE, immediately informing SEFIDE of any irregularity through the email address customerservice@sefide.com.
4.- Guarantees of the funds received
4.1 SEFIDE safeguards the funds received from its clients, in exchange for the electronic money issued in favor of them , by depositing them in a separate account in a Credit Institution in accordance with the applicable legislation. SEFIDE has posted on its website (www.sefide.com) the asset safeguard policies.
5.- Responsibilities
5.1 The Client is responsible for the proper use of their electronic money funds. Fraudulent use, both of the electronic money account itself and of the top-up means, will be considered a very serious act and will entail a violation of contractual good faith, without prejudice to the legal responsibilities that this entails. SEFIDE reserves the right to block and/or restrict the functionality of the electronic money account opened by the Client.
5.2 In order to avoid fraudulent actions, the Client must notify SEFIDE of any message received or website visited, other than www.sefide.com, which leads him to request passwords or personal data relating to his account opened at SEFIDE. If you suspect that someone has accessed your electronic money account, you should immediately contact SEFIDE. On the other hand, if SEFIDE suspects that someone has accessed your electronic money account without your authorization, or that its security has been affected in any other way, at any time it may suspend or restrict the functionality of the account, until the its security is restored. Transactions managed by SEFIDE may require additional security measures, which will be notified to you at the respective time.
5.3 Likewise, the Client must notify SEFIDE without undue delay, as soon as he becomes aware of the unauthorized use of his electronic money account. In the event that an unauthorized transaction is executed, SEFIDE will return to the Client, once the necessary investigations and inquiries have been carried out, the amount of the unauthorized operation. However, the Client will bear all the losses incurred as a result of unauthorized transactions that are the result of his fraudulent action or the breach, deliberate or due to gross negligence, of one or more of his contractual or legal obligations.
5.4 SEFIDE reserves the right to block the use of the electronic money account for objectively justified reasons related to security, such as suspicion of unauthorized or fraudulent use. Likewise, it may block it if it has reason to believe that, in any way, the Client is involved in any fraudulent activity, money laundering, financing of terrorism or other criminal activity, if it has reasonable reason to believe that its electronic money account has been been compromised or for any other security reason. The suspension will be notified before carrying it out, and if the notification is not possible according to the circumstances at the time, it will be notified as soon as possible after it is carried out, unless there is some legal impediment to making such notification.
6.- Privacy Policy
6.1 SEFIDE will comply at all times with the provisions of current regulations on data protection, in particular, the provisions of Regulation (EU) 2016/679, of April 27, 2016, regarding the protection of natural persons. regarding the processing of personal data (“RGPD”), as well as Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (“LOPDGDD”).
6.2 The personal data collected will be treated fairly and lawfully in accordance with the principles and rights contained in the LOPD and other development regulations.
6.3 For the opening of the electronic money account, the management of the electronic money account and the payment and reimbursement operations, SEFIDE will use, where appropriate, the personal data of the Client.
6.4 The Client accepts that their data and nominative information, collected by SEFIDE for the purposes of this document, will only be transmitted to the operational providers with whom they have contracted to execute the Payment Operations and provide the services, provided that the third parties recipients of these personal data are subject to regulations that guarantee a sufficient level of protection.
6.5 SEFIDE will not carry out any transfer of personal data outside the European Union. In the event that SEFIDE needs to transfer personal data outside the European Union, it will inform the Client in advance. In such a case, SEFIDE undertakes to respect the legal framework in force at all times and to implement any necessary measure to guarantee the security and confidentiality of the data thus transferred.
6.6 Some data collected and kept by SEFIDE for the purposes of this contractual relationship may give rise to the exercise of access and rectification under the conditions provided in Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of rights. digital. The Client may at any time obtain a copy of the personal data concerning him, simply by requesting it from the Data Protection Officer at the following address DPO@SEFIDE.COM, you can also request it in writing to the address of Avenida de la Ciencia number 2, 3rd floor, CP 18006, Granada.
6.7 SEFIDE will keep the information and personal data for the maximum applicable legal or regulatory period, depending on the purpose of each specific data process. In particular, SEFIDE must keep for a period of ten years the documentation that formalizes compliance with the due diligence obligations for the prevention of money laundering and the financing of terrorism, in accordance with the provisions of Law 10/2010. .
7.- Conditions of the electronic money account
7.1 The conditions that currently apply to the electronic money account will be those agreed upon by the Parties in the Specific Conditions, if applicable.
8.- Non-remuneration of electronic money funds
8.1 In accordance with the legal provisions, the granting of interest or any other benefit related to the time during which an electronic money holder is in possession of it is prohibited.
8.2 In relation to the balance that the Client has in the electronic money account, at no time can it be understood as capturing deposits, for which the funds in electronic money cannot be and will not be, in any case, remunerated, as expressly stated in article 8 of Law 21/2011, of July 26, on electronic money.
8.3 Likewise, debit positions will not be possible in the electronic money account opened by the Client in SEFIDE.
9.- Revocation of payment orders and refunds. I do not repudiate
9.1 The Client will not be able to revoke any payment authorization by means of electronic money that he has given to SEFIDE once said transaction has been processed. The Client may not revoke a payment order after it has been received by SEFIDE.
9.2 In accordance with the principle of authenticity and non-repudiation in the payments of the security system used, the parties agree that the use of SEFIDE electronic money in the conditions indicated in this contract authentically identifies the User, and it is not possible for the User to repudiate subsequently the transactions carried out, considering that said transactions have been carried out by persons endowed with sufficient powers for this purpose.
10.- Blocking electronic money accounts
10.1 SEFIDE may block the electronic money account and any payment instrument linked to it when it has objectively justified reasons related to the security of the electronic money account and any payment instrument linked to it, or when SEFIDE suspects a unauthorized or fraudulent use. In such a case, SEFIDE will inform the Client, in the agreed manner, of the blocking of the electronic money account and of any linked payment instrument and of the reasons that have given rise to it. This communication will take place prior to the blocking and, if this is not possible, immediately afterwards, unless the communication of such information is compromised for objectively justified security reasons or is contrary to any other regulatory provision.
10.2 SEFIDE may block electronic money accounts when it can be deduced from the transaction history that the Client is using the electronic money account for an illicit purpose.
10.3 The blocking of electronic money accounts, temporarily or indefinitely, will not generate any type of compensation or economic remuneration in favor of the Client.
11.- Necessary documentation to register the electronic money account
11.1 This stipulation regulates the necessary documentation to open the electronic money account in SEFIDE:
Registration of legal entity clients:
Registration of natural person clients:
11.2 SEFIDE will only proceed to open the electronic money account once the Client's registration process ( onboarding , in Anglo-Saxon terminology) has been completed satisfactorily.
11.3 The documentation required by SEFIDE indicated above may be updated and expanded unilaterally by SEFIDE, provided that this is necessary for a diligent action by SEFIDE, as well as to be able to comply with the regulations for the prevention of money laundering and financing of the terrorism. In particular, you may request additional or updated documentation regarding the obligation of formal identification; identification of the beneficial owner; obtaining information about the purpose and intended nature of the business relationship; application of continuous monitoring measures to the business relationship, as well as application of due diligence and enhanced diligence measures.
11.4 Likewise, SEFIDE may require more documentation and information depending on the nature of the operations, as well as the volumes of transactions, that are carried out in the open electronic money account.
12.- Duration, modifications and termination of the contract
12.1 The contract is concluded for an indefinite period. However, it may be resolved by any of the parties without the need for any reason, and with a minimum notice of two (2) months in advance if the resolution is at the request of SEFIDE. The resolution of the contract will determine the full reimbursement of the monetary value of the electronic money available to the Client.
12.2 SEFIDE may make changes to the initially agreed conditions at any time, communicating them at least two (2) months in advance of the date on which the new conditions are to come into force, by the means agreed for communications. Said modifications will be considered accepted by the Client if he does not expressly communicate his non-acceptance prior to the proposed date of entry into force. The opposition of the Client to said changes and the notification of objection to them, will constitute a cause for termination of the contract.
12.3 All those modifications that are more favorable for the Client may be applied immediately, without any waiting period or prior notice being necessary for this. Similarly, neither the prior notice nor the waiting period will be applicable in cases where the modification refers to a new service, additional functionality for an existing service or any other change that can be reasonably considered. that does not reduce your rights or increase your responsibilities. In these cases, the change will be made without prior notice and will take effect as soon as it is notified or published.
12.4 Either party may terminate this agreement. To do this, you must notify the other party at least two (2) months in advance. However, the contract may be subject to immediate termination by SEFIDE in the following cases:
12.5 Likewise, the contract may be terminated, without the notification indicated in the previous paragraph, in the following cases:
13.- Claims
13.1 In the event that the Client wishes to make a complaint or claim, they may contact SEFIDE's Customer Service, through the email address atencionalcliente@sefide .com and can also be submitted on paper at the address of SEFIDE indicated above.
13.2 The SEFIDE Client Defense Regulations are available to the client at www.sefide.com.
14.- Contract documentation
14.1 Without prejudice to the fact that the execution of this contract is recorded on a durable medium that allows the client to store and retrieve it easily, and its reproduction without changes of the stored information, at any time the Client, who so requests, will have the right to receive in paper or on another durable medium the contractual conditions of this contract.
15.- Prevention of Money Laundering and the Financing of Terrorism
15.1 SEFIDE will adopt the necessary technical and operational measures to comply with the obligations derived from the regulations on the prevention of money laundering and the financing of terrorism, in accordance with the legislation in force at any time.
15.2 SEFIDE may adopt, among other measures, establish the quantitative limits indicated in article 16 of Royal Decree 304/2014, of May 5, which approves the Regulation of Law 10/2010, of April 28, of prevention of money laundering and financing of terrorism.
16.- Non-compliance not attributable in the provision of the service
16.1 SEFIDE will not be responsible for the total or partial breach of the Contract when this is due to a fortuitous event or cause of force majeure, and without said breach being a cause for termination, and SEFIDE must, in any case, take all measures that were necessary to restore the service in the shortest possible time.
17.- Confidentiality
17.1 The terms of this agreement are strictly confidential. Both Parties undertake not to disclose or transmit to third parties (except to collaborators or advisors of the Parties who may need said information solely in the context of this contract), without the prior written consent of the other Party, the existence, terms and content of this contract, as well as the information contained therein, or that would have been provided by the disclosing party within the object of this contract.
17.2 The receiving party of the information shall refrain from using, duplicating, reproducing or keeping all or part of the information provided by the other party for purposes unrelated to the fulfillment of this contract, except for information that:
18.- Use of the SEFIDE Technology Platform
18.1 The Parties acknowledge that the provision of the services object of this contract will be carried out through the interconnection of the SEFIDE technological platform with the client's technological platform. In this sense, the Client is responsible for all the activities that take place when using the SEFIDE technological platform, including the “ sandbox ” and the “ API's ”. The Client undertakes to make good use of the platform, understanding good use to be that which is in accordance with current legislation, good faith and public order. Likewise, you agree not to use it for fraudulent purposes and not to carry out any conduct that could damage the image, interests and rights of SEFIDE.
18.2 The Client undertakes not to carry out any act that would have the purpose of damaging, rendering useless or overloading the website, or that would prevent, in any way, its normal use and operation . Specifically, the following activities are prohibited:
18.3 To the extent that the Client obtains knowledge or receives confidential information related to the SEFIDE technological platform, he must treat said information with strict confidentiality and may not disclose it to third parties, both during the period of validity of his registration on the platform and after that registration ceases.
18.4 Upon termination of this Agreement, Customer must destroy any copies of Confidential Information in its possession and/or that of its subcontractors or agents and, if required, certify such destruction.
18.5 The property of the technological platform of SEFIDE, including the “ sandbox ” environment and the “ API's ” to which access is given through it are the property of SEFIDE and are protected by the legislation on intellectual property.
18.6 SEFIDE's technological platform and all the information contained therein is provided "as is". The Client is responsible for evaluating the accuracy, completeness or usefulness of any information in the APIs or any other content available on the SEFIDE technology platform.
SEFIDE will not be liable: a) for the use made by the Client when he is not following SEFIDE's instructions; and b) of the effects or consequences that are derived for the Client for having made a negligent or malicious use.
19.- Assignment of the rights derived from the Contract
19.1 The Parties expressly agree that the rights and obligations arising from this Agreement may not be assigned, in whole or in part, without the express written consent of the other party.
20.- Communications
20.1 The parties agree that the transmission of information or notifications between them will preferably be done by email and in the Spanish language. To this end, the Customer must maintain a valid email address in their account profile at all times, being responsible for checking incoming messages periodically and frequently. You can contact SEFIDE at any time by sending a message to the email address: operaciones@sefide.com or customerservice@sefide.com.
21.- Applicable law and submission to jurisdiction
21.1 This contract will be interpreted and fulfilled in its own terms and, in matters not foreseen, will be governed by Spanish legislation on the matter, adjusting the obligations and responsibilities of the parties to it.
21.2 The parties submit to the jurisdiction of the Courts and Tribunals of Granada capital for any matter related to the interpretation, compliance or execution of this contract, expressly waiving any jurisdiction that may correspond to them.
21.3 And in proof of conformity, the parties sign this electronic money account opening contract, in duplicate, in the place and on the date indicated in the signing footnote of this contract.
ANNEX TO THE APPENDIX REFERRING TO THE DEBIT CARD PROPERTY OF THE FLEXOH COMPANY
This addendum ("Addendum"), together with the Mastercard Card Terms ("Terms"), govern the use of the Card. The Addendum and the Terms are both referred to as an Agreement. Your card is a plastic and/or virtual card.
You will be asked to confirm your acceptance of this Agreement when you apply for the Cards through the Corporate Accounts Platform. If you refuse to accept this agreement, we will not be able to fulfill your card order.
Unless specifically stated otherwise, words and expressions in this Addendum have the same meaning and interpretation as defined in the Terms.
Definitions
Card system: Mastercard International Incorporated . Mastercard is a registered trademark of Mastercard International Incorporated .
Currency denomination: Euro
Website: https://flexoh.com/
Mobile application: Flexoh
Customer Services: You can contact Customer Service through the following channels:
1. Information to be provided to activate the card
The card user must activate the physical card as soon as it is received, following the detailed instructions in the information documents that accompany the card.
The card user can set their PIN during the activation process in the mobile application.
2. Your account limits
Limits for physical and virtual card profiles are listed below . The limits are in the currency of the card.