Privacy Policy | FlouLabs

Last modified: [01/26/2026]

Introduction

FlouLabs LLC, or any of its affiliates (the "Company" or "we" or "us") respect your privacy and are committed to protecting it by complying with this policy ("Policy"). This Policy describes our practices for collecting, using, preserving, protecting, and disclosing the information we receive from you or that you provide to us when you visit or use our website, social media, web applications, and mobile applications (the "Digital Platforms"):

FlouLabs website (floulabs.co)
FlouLabs Mobile Apps
Our FlouLabs branded social media pages or sites and
Email sent through the Digital Platforms.

This Policy DOES NOT APPLY in the following case:

The service offered through our Digital Platforms may contain links operated by third parties that are provided for your convenience. Such links are not under our control. We are not responsible for the content of any third party website or link contained on our website. We do not review, approve, monitor, endorse, guarantee, or make representations regarding third-party websites and the inclusion of any link, offer, or any other service provided in connection with the third-party website is not and does not imply affiliation, sponsorship, endorsement, approval, verification, or monitoring by FlouLabs of such third-party website. We are not responsible for the content of the third party's website or any lack of access at any given time. You understand that third-party websites contain their own terms and conditions of use, including, but not limited to, the privacy policy, which you are responsible for reading prior to using the third-party website. Information that you provide or is collected by a third party (see Information from Third Parties) will be subject to the third party's terms, conditions, and policies, including information you provide to websites linked to the Digital Platforms.

Please read this Policy carefully to understand our practices and policies regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register on, or use our Digital Platforms. By downloading, registering, or using our Digital Platforms, you agree to this Privacy Policy. This Policy may be modified or amended from time to time (see Changes to our Privacy Policy). You will be notified of such changes via email and the current version will be found in our web application. Your continued use of our Digital Platforms after we make any modifications or amendments to this Policy means that you accept those changes.

If you have a financial product or service with us for your personal, or your family's or household's use, we will also have provided you with a copy of the U.S. Customer Privacy Notice that explains how we collect, use, and disclose your nonpublic personal information, and provides you with certain choices regarding the use and disclosure of such nonpublic personal information about you.

Children under 13 years old

Use of our Digital Platforms is not intended or permitted for children under the age of 13 and we do not knowingly collect any personal information from children under the age of 13. If we learn that we have collected or received personal information from a child under the age of 13 without verifying parental consent, we will delete that information. If you believe that we may have any information received from or about a child under the age of 13, please contact us at cumplimiento@floulabs.co.

What information do we collect and how do we collect it?

We collect information from and about users of our Digital Platforms as follows:

Directly from you, when you provide it to us.
Automatically, when you use the Digital Platforms.
We collect two types of information:
Personal Information- - Information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be related, directly or indirectly, to you or your household. Personal Information may include nonpublic personal information (as that term is defined in United States law, more specifically in the Gramm-Leach Bliley Act (Federal Regulation P), Protected Health Information, as applicable (as that term is defined in the U.S. Health Insurance Portability and Accountability Act), and Nonpublic Personal Information (as that term is defined in Federal Regulation P). It does not include information or data about you that is made publicly available by the government, information that is publicly available without any action by FlouLabs.
Non-Personal Information- Other information that does not identify you, such as information that has been anonymized or aggregated with other information, and anonymous information.
More specifically:

Information we collect from each of the Digital Platforms	Information we collect from each of the Digital Platforms
FlouLabs website	Information You Provide to Us: Information that identifies you as an individual, or refers to information that identifies you, such as name, mailing or residence address, email address, and telephone number ("Basic Contact Information"); search queries you have made; and other information you enter on the website. Automatic Collection and Tracking of Information: Our web pages and our emails may contain small electronic files known as web beacons (also known as clean gifs, pixel tags, and single-pixel gifs) that allow the Company, for example, to count users who have visited those pages or opened an email, and keep any other statistics related to the application (such as, for example, recording the popularity of a particular content on the website, or verifying the integrity of the system and server). Business purpose of collecting information: to acquire potential new customers; to improve our website; to conduct business research and analysis, and to identify usage trends; to tailor marketing communications from our associates as well as certain third parties; to manage our business effectively; and to develop new products and services.
FlouLabs Web Apps	Information You Provide to Us: Basic contact information, name, date of birth, social security number, education, work, identification documents, gender, marital status (e.g., driver's license, green card, national identity card, passport) ("identification documents"), your online user ID and login credentials (PINs, passwords, security codes, access codes, security questions) ("access credentials"); the search queries you have made and any other information you enter into the online service. If you have a digital wallet or account with us: We also collect information about account numbers, debit/credit card numbers, and any other information, such as: account holder name, account access credentials, signature, transaction data/log, merchant information. We also collect information from third-party account identifiers used in fund transfers. Automatic Collection and Tracking of Information: When you visit, access, or use our online service, it may be using some technology to automatically collect: Usage details. The details of your access to the online service and use of the system, including traffic data, location data, logs, and any other communication information and the resources you access and use on or through the online service. Device information. Information about your computing device and internet connection, including unique device identifier, IP address, operating system, and browser type. These tracking technologies include internet cookies, flash cookies, web beacons, and device fingerprints used to collect information about the various characteristics of your device (including, but not limited to, IP address, installed fonts, language and browser parameters, and time zone) in order to create a device identifier that allows us to recognize your device, as well as knowing the time of your visit and the page(s) visited. Business Objectives That Fulfill Information Collection: To acquire potential new customers; to review and process applications; to review, prepare, and process instructions you provide for the products and services you are using; account maintenance and servicing; to track and prevent fraud; to comply with applicable laws and regulations; to protect our business and our customers from any illegal activity or activity within our discretion could be considered harmful to the operating system or put at risk information collected or to FlouLabs; conduct audits, improve our online service, conduct business research and analysis, and identify usage trends; tailor marketing communications from our partners, as well as certain third parties; To manage our business effectively and develop new products and services. We may also use these automatic and tracking technologies to collect information about your activities over time and across different third-party websites, apps, or other online services (behavioral tracking).
FlouLabs Mobile Apps (Apps) Cards	Information you provide to us: Basic contact information, name, date of birth, social security number, identification documents, gender, marital status, your user ID and application access credentials, account numbers, debit/credit card numbers, and any other information, such as: account holder name, account access credentials, assets, transaction data/history, merchant information, the search queries you have made, and any other information you enter into the app. We also collect information from third-party account identifiers used in fund transfers. Automatic Collection and Tracking of Information: When you download, access, or use our app, it may be using some technology to automatically collect: Usage details. The details of your access to and use of the App, including traffic data, location data, logs, downloaded information and any other communication information and the resources you access and use on or through the App. Device information. Information about your mobile device and internet connection, including the device's unique identifier, IP address, operating system, browser type, mobile network information, and device phone number. Location Information. Real-time information about your device's location. Information and stored files. The app may also have access to metadata and other information related to other files stored on your device. It may include, for example, photographs, audio and video clips, personal contacts, and address book information. These tracking technologies include mobile cookie IDs that are placed on the smartphone such as Device Identifier and Fingerprints to collect and analyze configuration parameters, metadata, and any other information that a device sends when it is connecting to the internet. We use it only for biometric registration, to create profiles aimed at recognizing returning devices. Purposes of the business that fulfills the collection of information: reviewing, preparing, and processing product and service options as instructed by you; account maintenance and servicing; fraud tracking and prevention; compliance with applicable laws and regulations; protecting our business and our customers from any illegal activity or activity that in our discretion may be deemed harmful to the operating system or put in place the risk information collected or to FlouLabs; conduct audits, improve our applications, conduct business research and analysis, and identify usage trends; tailor marketing communications from our partners, as well as certain third parties; manage our business effectively; provide you with personalized, location-based services and content. We may also use these automatic and tracking technologies to collect information about your activities over time and across different third-party websites, apps, or other online services (behavioral tracking).
FlouLabs branded social media pages or sites	The personal information you share on social media pages managed by FlouLabs, such as Facebook, Instagram, TikTok, and Twitter, is subject to the privacy policies and terms of use of those platforms. Please refer to these policies to learn about your rights and obligations before posting any content on such pages. You should NEVER provide personal information to FlouLabs through social media pages. The information you share on these sites, pages, or areas may be viewed by any user of those sites.
Collection of Information by Third Parties	When you use the Digital Platforms, certain third parties, whether or not related to FlouLabs, may use automatic information collection technologies to collect information about you or your device. These third parties include: Advertisers, ad networks, and ad servers Data analytics company Manufacturer of your mobile device. Your mobile device provider. Your app store platform or provider Others The information that third parties collect may be linked to your personal information or they may collect information, including your online activities over time and across different websites, applications, and other online service websites. They may use this information to present you with interest-based (behavioral) advertising or other content targeted to your preferences. We do not control the tracking technologies of these third parties or how they may use them. If you have any questions about advertising or other targeted content, you should contact the provider responsible for it directly. You can find information about how to opt out of receiving targeted advertising from these vendors in the options applicable in each case regarding how they collect, use, and disclose your information.
Information we collect from third parties about you	We obtain information about you from third parties, including, for example, financial institutions and government sources. This information may include, for example, account identifiers used for funds transfers, credit history, credit score, credit reports, and death certificate information. Business Objectives of Information Collection: Reviewing and processing requests for our products and services; achieving product and service offerings and customer acquisition; tracking and preventing fraud; complying with applicable laws and regulations; effectively managing our business; and servicing and maintaining accounts.

How do we use the information we collect about you?

We use the information we collect about you or that you provide to us, including your personal information, to:

Make available to you the Digital Platforms and their contents and any other information, products or services that you request from us or that FlouLabs recommends, in accordance with this Policy.
Process requests and transactions.
Verify your identity.
Fulfill any other purpose for which you have provided it within the available products and services.
Send you notifications about your account and ask for feedback.
To perform our obligations and exercise our rights under any contracts between you and us, including for billing and collection.
Notify you when any updates to the Digital Platforms become available, and any changes to the products or services we offer through them.
For the purposes of our business and any other purposes or means required or permitted by law or with your consent; such as the security of your account and digital services; perform data analysis of your use of our online services, including your responses to our emails and the pages and advertisements you view; provide you with content and marketing messages targeted to your preferences; operate, evaluate, and improve our business (including developing new products and services; improving existing products and services; performing data analysis; and performing accounting, auditing, and other internal functions); Advertise and market our products and services, and those of our business partners.

The usage information we collect helps us improve our digital platform and provide a better, more personalized experience by enabling us to:

Calculate the size of our audience and their usage patterns.
To store information about your preferences, which in turn allows us to personalise our digital platform, based on your particular interests.
Speed up your searches.
Recognize it when you use the digital platform.

We use the location information we collect to improve our digital platform and to provide a better and more personalized experience, including marketing communications from our partners, as well as applicable third parties.

We may also use the information collected to present advertising to our advertisers' target audiences. Although we do not disclose your personal information for these purposes without your consent, if you click or otherwise interact with an advertisement, the advertiser may assume that you meet their target audience criteria.

How do we share your information?

We may disclose aggregated information about our users and information that does not identify a particular person or device.

In addition, we may disclose personal information that we have collected or that you provide to us:

To verify your identity or answer your questions.
To our subsidiaries and associates.
To contractors, service providers, and other third parties we use to support our business, including, but not limited to, financial institutions.
To a successor, in the event of a corporate transaction (such as a merger, sale, consolidation, or other sale or assignment of some or all of FlouLabs' assets or business, whether as an active company or as part of bankruptcy, liquidation, or other similar proceeding) in which the personal information of our App users in the possession of FlouLabs was part of the transferred assets.
To third parties, to market their products or services to you, if you have consented/have not refused such disclosure, as applicable.
To fulfill any other purpose for which you provided it.
For any other purpose that we may have indicated to you when you provided us with the information.
With your consent.
If applicable, to insurers, for the purpose of processing the contracted benefits.
If applicable, with the credit bureau or similar agencies or entities.
To comply with an order, law, legal or regulatory process, including in response to a governmental or regulatory request, including applicable tax agencies, or state security agencies.
To exercise our rights under any contract between you and us, including our Terms and Conditions, and for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FlouLabs, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.
If required or necessary within FlouLabs' discretion, share personal information with regulators and/or auditors.

Your Choices About How We Collect, Use, and Disclose Your Information

We try to provide you with choices about the personal information you provide to us. This section describes the mechanisms we offer you to control certain uses or disclosures of your information.

Tracking Technologies You can set your browser to refuse some or all browser cookies, or to alert you when cookies are being sent. You can decide whether or not to allow the Digital Platforms/Websites/Applications/Online Services to collect information through other tracking technologies. If you disable or refuse or block the use of other tracking technologies, some parts of the Digital Platform may become inaccessible or not function properly. Remember that you'll need to do this with every browser you use and on every device you use.
Location Information. You can decide whether or not to allow the app to collect, disclose, and use real-time information about your device's location through your device's privacy settings. If you block the use of location information, some parts of the Digital Platform may be inaccessible or not function properly.
Company Promotion. If you do not want us to use your email address to promote our products or services or those of any third party, you may opt out of such action by sending an email to: cumplimiento@floulabs.co. You can also, at any time, reject these actions by entering the digital platform and adjusting your user preferences in your account profile, selecting or deselecting the corresponding boxes
Targeted advertising conducted by FlouLabs. If you do not want us to use the information we collect or that you provide to us to deliver targeted advertising to our advertisers' target audiences, you may opt out of such an option. You may also, at any time, modify your preferences regarding advertising in your account user profile by selecting or deselecting the appropriate boxes, or by sending us an email indicating your request to cumplimiento@floulabs.co.
Disclosure of your information for advertising or marketing to third parties. If you do not want us to disclose your personal information to unaffiliated third parties or non-agents for use for advertising and marketing purposes, you may opt out by sending an email to: cumplimiento@floulabs.co. You can also, at any time, reject such an alternative by logging into the Digital Platform and modifying your preferences in your user profile of the wallet or digital account, by selecting or deselecting the corresponding boxes, or by sending us an email indicating your request to cumplimiento@floulabs.co.
U.S. Customer Privacy Notice Where applicable, U.S. citizens who have a financial product or service with us for personal, family, or household use, we will limit our disclosure of their personal information to what you indicate in your response to our U.S. Customer Privacy Notice submitted under your Financial Services Agreement with us.

We do not control the collection or use of your information by third parties for interest-based advertising purposes. However, these third parties may offer you a way to define or limit whether you do not want your information collected or used for that purpose. You may refuse to receive targeted advertising from any of the members of the Network Advertising Initiative ("NAI") on the Network Advertising Initiative's website; and members of the Digital Advertising Alliance ("DAA"), on the latter's website. Even if you opt out of having information collected for advertising purposes, you may still receive ads from us; however, these will not be personalized to your browsing activities.

Access and correction of your personal information

To change or correct your personal information, you can log in to the digital platform and visit your account profile page. You may also send us an email at hola@floulabs.co requesting access to, correction or deletion of any personal information you have provided to us. We cannot delete your personal information without also deleting your user account. Please note, however, that we cannot comply with any request to change or delete information that, in our opinion, violates any law or legal requirement or renders the information incorrect.

Information Security

We have implemented measures to protect your personal information from accidental loss or unauthorized access, use, alteration, or disclosure of your personal information. All the information you provide to us is stored on secure servers protected by firewalls. Any transactions with your card or e-wallet and any other information will be encrypted using Secure Socket Layer ("SSL") technology or any reasonably acceptable encryption and/or security method.

The security and protection of your information is also up to you when we give you (or you choose) a password or any other access credential to access certain parts of our Digital Platforms, you are responsible for keeping such access credentials confidential. Please do not share your login credentials with anyone.

The security of your personal information is important to us. However, despite our efforts, there is no 100% secure method of transmission over the Internet, or method of electronic storage, so we cannot guarantee the absolute security of the personal information we collect from you. Remember that you are also an integral part of protecting your information. We are not responsible for any case of circumvention of the privacy parameters or security measures that we have established. If you become aware of any situation that puts the security of your information at risk or any breach of information security, please contact us immediately.

Communications

We may contact you through newsletters and marketing information that we think may be of interest to you. You may opt-out of receiving information, in whole or in part, from these marketing communications through the unsubscribe link provided or by following the instructions provided in each email. Please note that we may continue to send you service-related administrative communications, even if you have unsubscribed to marketing communications.

Official communications and fraud prevention (phishing)

For purposes of administrative and operational notifications related to your account, FlouLabs may communicate with you via emails sent from addresses under the @floulabs.co domain, including, but not limited to: updates@floulabs.co, cumplimiento@floulabs.co, and hola@floulabs.co.

FlouLabs will not ask you by email for your password, PIN, verification codes (OTP), security questions, or to share login credentials. We also won't ask you to send sensitive information via email to "prevent closure" or "unlock" your account.

If you receive a message that appears to be from FlouLabs and is suspicious (e.g., by the sender, links, attachments, or request for information), do not respond, click on links, or download files, and immediately report it to cumplimiento@floulabs.co for validation. When possible, also use the app/website's internal channels to check notifications.

Information retention period

We will retain your personal information for as long as you are a user of FlouLabs and for up to 5 years or as long as required by law, whichever is longer, to respond to questions, claims or complaints, conduct information surveys, comply with laws regarding information retention, or for technical reasons.

International Transfer of Information

Information collected while you use our Digital Platforms, including personal information, may be transferred to and maintained on computers outside of your state, province, country, or other governmental or political jurisdiction, where data protection laws may be different from those applicable in your jurisdiction. If you are located outside of the United States of America and choose to provide us with information, please note that your information, including your personal information, will be transferred to the United States of America, where it is processed and used. By using the digital platform and/or submitting personal information, you are consenting to the provisions of this Policy.

Changes to our Privacy Policy

We may make changes to our Privacy Policy from time to time. If we make any material changes to the way we treat our users' personal information, we will post the new Privacy Policy on our Digital Platforms along with a notice that the Privacy Policy has been updated and notify you by email to the primary email address listed in your e-wallet and/or an in-app alert the first time you use the e-wallet after we make the request. change.

The date of the Privacy Policy was last modified is indicated at the top of the page. You are responsible for ensuring that we have up-to-date information about your email address at all times, that you are active and able to receive mailings, and that you periodically review this Privacy Policy for any changes.

Contact Information

If you have any questions or comments about this privacy policy and our privacy practices, you may contact us at: cumplimiento@floulabs.co