Terms of Use

It is extremely important to us to protect your data and we take extreme measures to do so.

Terms of Service

1. General
Chargeflow offers chargeback mitigation solution, disputemanagement platform, chargeback alerts services, and ancillary solutions (collectively, the “Services”) operated by Chargeflow Inc., ("Company", "We", "Us" or "Our"). 

These terms of use (the "Terms") govern your ("You", "Your", “Merchant” or “User”) use of the Services as well as our website located at https://www.chargeflow.io (the “Website”). 

These Terms should be read carefully by You in their entirety prior to Your use of the Services. Please note that these Terms constitute a legally binding agreement between You and Us and that if You do not agree with any provision of these Terms, You shall immediately cease using the Services and the Website.  

These Terms incorporate Our Privacy Policy and Data Processing Activities page and by agreeing to these Terms, You confirm that You also accept and agree to Our Privacy Policy and Data Processing Activities.     

2. Eligibility
2.1.     You are only entitled to use the Services and the Website, if You comply with all of the following:

2.1.1.     You are at least 18 years old; 

2.1.2.     We have not closed or disabled Your Account (as defined below) in the past for any reason; and

2.1.3.     You have the right, authority and capacity to enter into these Terms and to abide by all the terms and conditions of these Terms.

3. Registration 
3.1.      In order to use the Services, You must install Our application and connect the add-on and open an account (the “Account”). 

3.2.      When You register to the Services,You are required to complete certain details about Yourself, as further described in Our Privacy Policy. You will further provide information with respect to your online/retail store (the “Store”) and connect ourServices to your CRM system, payment gateway and payment processor or payment facilitator. You will need to open a separate account for each Store you connect to the Services.

3.3.      The information that You provide during the registration process must be accurate, up-to-date and complete. In addition, You will be asked to choose a password, which, together with Your email address associated with Your Account (the “Access Information”),will constitute Your identification information for the purpose of logging into Your Account. 

3.4.     You are solely responsible for maintaining the confidentiality of your Account information and Access Information. You remain solely responsible for activit yon Your Account with the use of Your Access Information. If You share Your password with anyone, We will not be held liable for any loss that may occur as a result thereof. You may not allow any other third party to use or access Your Account. You must notify Us immediately of any unauthorized access to Your Account, or any other breach of security. 

3.5.     It is Your responsibility to keep the email address associated with Your Account up to date, so that the Company can communicate with You electronically. You understand and agree that You forfeit the right to plead ignorance if You do not receive an electronic communication sent to You by the Company, because Your Account's email address is incorrect, out of date, blocked by Your service provider, or You are otherwise unable to receive electronic communications.

4.     The Services
4.1.     Upon activation of the Services, Chargeflow will address all open disputes on Your Stores.

4.2.      If at the time of connecting to our services, you already have open chargebacks (“Old Chargebacks”),Chargeflow will use its best efforts to address those. However, Chargeflow will only take responsibility over disputes opened after connecting to the Services and Chargeflow does not guarantee that Old Chargebacks will be addressed by Chargeflow. You can view the status of disputes and Services in the Chargeflow dashboard. 

4.3.     Chargeflow will process customer information on behalf of the Merchant for the purpose of addressing the chargebacks as provided by the Chargeflow DPA. The Merchant undertakes and warrants that these processing activities are permitted under its Privacy Policy.

4.4.     As part of the Services, Chargeflow, at its own discretion may reach out to Your customers directly and resolve the dispute directly with the customer, until the customer withdraws the chargeback or closes the dispute at its own initiative. 

5.     Fees; Payments; Taxes
5.1.     Chargeflow shall be entitled to fees for chargebacks settled in the favor of the Merchant through the Services. For the removal of doubt, if Merchant disconnects a Store from the Services, after Chargeflow a dispute was opened, the Merchant will be obligated to pay Chargeflow fees. 

5.2.      Late Payments. Merchant shall pay interest on all late payments at the lesser of (a) 1.5% per month or (b) the highest rate permissible under applicable law,calculated daily and compounded monthly. Merchant shall reimburse Chargeflow for all costs and expenses, including, but not limited to attorneys’ fees,incurred in collecting any unpaid amounts owed by Customer hereunder.

5.3.      Taxes. All amounts due hereunder are exclusive of all sales, use,excise, service, value added, or other taxes, duties and charges of any kind(whether foreign, federal, state, local or other) associated with these Terms,the Service, or Merchant’s access to the  Chargeflow Service.Merchant shall be solely responsible for all such taxes, duties and charges(except for taxes imposed on Chargeflow’s income), which may be invoiced by Chargeflow from time-to-time.

6.     Limitation of liability
6.1.     Your use of the Website and/or the Services shall be at Your sole risk. To the fullest extent permitted by law, We disclaim all warranties, explicit or implied, in connection with the Website and the Services and Your use thereof including implied warranties of merchantability, title, fitness for a particular purpose or non-infringement, usefulness, authority, accuracy,completeness, and timeliness. Accordingly, the Services, including all content and functions made available on or accessed through or sent from the Website,are provided “as is”, “as available” and “with all faults" basis.
6.2.     CHARGEFLOW DOES NOT UNDERTAKE THAT ALL CHARGEBACKS WILL BE RESOLVED AT THE MERCHANTS’ BENEFIT. CHARGEFLOW FURTHER DOES NOT UNDERTAKE THAT ALL DISPUTES WILL BE RESOLVED AND ALL FRAUD ATTEMPTS IDENTIFIED.          

6.3.     Without derogating from the generality of the foregoing, We assume no liability or responsibility for any (a) errors, mistakes, or inaccuracies of any content included in the Website; (b) any interruption or cessation of transmission to or from the Services; or (c) any bugs, viruses, Trojan horses, or the like which may be transmitted to or through the Services or Website by any third party.

6.4.     You agree to hold Us harmless for any losses caused, directly or indirectly, to You and/or to any other third party, with respect to the Website and/or the Services and You shall bear sole responsibility for any of Your decisions made relying on the content of the Website and/or the Services.

6.5.     In no event will We be liable to You or any third party for any special, direct,indirect, incidental, special, punitive, or consequential damages whatsoever,including any lost profits or lost data arising from Your use of the Website and/or the Services or other materials on, accessed through or downloaded from the Website or as part of the Services, whether based on warranty, contract,tort, or any other legal theory, and whether or not We have been advised of the possibility of these damages and in cases where judicial authority finds Us liable, Our liability shall not exceed the fees due to Chargeflow at the 6months preceding to the event giving rise to the liability. The foregoing limitation of liability shall apply to the fullest extent permitted by law in the applicable jurisdiction.

6.6.     We are not responsible for any disruption or technical malfunction of any telephone or network lines, computer online systems, servers or providers, hardware,software, failure due to technical problems or traffic congestion on the internet (or inaccessibility of the internet) or incompatibility between theServices and Your browser and/or Store systems and/or other equipment. Without derogating from the above, We do not assume any responsibility or risk for Your use of the internet.


7.     Intellectual property rights
7.1.     The Services and the Website including the algorithm used to provide the Services,the anonymized and aggregate data collected, the look and feel of the services,the content, including the video materials, text, photos, logos, any graphical display of data, designs, sound, figures, analysis, statistics, trademarks and any other content embodied in the Services and the Website are protected by Our intellectual property rights or of third parties. 

7.2.     As between You and Us, We retain all right, title and interest in and to the Services and the Website. The use of the Services and the Website does not confer on You any of the intellectual property rights embodied therein, other than the right to use such in accordance with the terms of these Terms.

7.3.     You shall not, nor shall You allow any other party to modify, decompile,disassemble, reverse engineer, copy, transfer, create derivative works from, rent, sub-license, distribute, reproduce framed, republish, scrape, download,display, transmit, post, lease or sell in any form or by any means, in whole or in part, use for any purpose other than for using the Services and the Website pursuant to the Terms or otherwise exploit any of the contents of the Services and the Website without Our explicit, prior written permission.


8.     Third party services or content
8.1.     While using the Services, You may view content or services provided by third parties,including advertisements.

8.2.     We do not control, endorse or adopt such content or services, and it may not always be accurate or current. 

8.3.     Without derogating from the generality of the foregoing, it is emphasized that all content provided by third parties are not provided by the Company or by anyone on its behalf, and We do not control, endorse or adopt any such content.

8.4.     Accordingly,We recommend that You independently verify all information before relying onit, and any decisions or actions taken based upon such information are Yoursole responsibility.

8.5.     Alert Services
If you elect to subscribe to the Alerts Services, as defined below, the following will apply

8.5.1.       “Chargeback Alert” and/or the“Chargeflow Prevent” service (the “Alerts Service”) are provided by Pinpoint Intelligence, LLC d/b/a Pinpoint Payments (“Pinpoint”) and subject to the Pinpoint terms and conditions, including: (i) Pinpoint Alerts Services Agreement available in the following link, click here ; (ii) Pinpoint RDR Service Agreement available in the following link, click here; and(iii) Pinpoint Master Services Agreement available in the following link, click here

8.5.2.     By subscribing, You hereby confirm that You read, understood, and consent to all of Pinpoint’s terms and conditions mentioned above. It is hereby clarified that the Alerts Services, to the extent provided to You, shall be deemed part of the Services for the purposes of these Terms. 

8.5.3.      It is clarified that as a part of the Alerts Services, Chargeflow, at its sole discretion, may make a refund on behalf of the Merchant when a new alert is received or may open a dispute and settle it directly.

8.5.4.      You may terminate the Alerts Services, at any time, by giving written notice to Chargeflow at least thirty (30) days in advance (the “Notice Period”). During any such Notice Period, Chargeflow shall be entitled to receive payments of the applicable fees for the Services rendered to You. Termination of the Alert Services will not affect other Services you receive from Chargeflow. 

9.     Links 
9.1.      The Website may contain links,content, advertisements, promotions, logos and other materials to platforms,websites or software that are controlled or offered by third parties (the “Links”).We caution You to ensure that You understand the risks involved in using such websites, software, platforms or materials before retrieving, using, relying upon or purchasing anything via these websites, platforms or software or based on such materials. Such Links are provided solely for Your convenience, and You agree that under no circumstances will You hold Us liable for any loss or damage caused by use of or reliance on any content, goods or services available on other websites, platforms or software.

9.2.     The inclusion of Links in the Website is not an endorsement, authorization, sponsorship, affiliation or any other connection between Us or those websites, platforms, software or their operators.

10.  Miscellaneous
10.1.     We may,at Our sole discretion, amend, modify, terminate or discontinue, from time to time, any of the Services and/or introduce new Services. We shall not be liable for any loss suffered by You resulting from any such changes made and You shall have no claims against Us in such regard.

10.2.     We may modify these Terms from time to time. When We do, We will provide notice to You by publishing the most current version and revising the date at the top of this page and any modifications shall be effective immediately upon such publication. By continuing to use the Website or the Services after any changes come into effect, You are deemed to agree to the revised Terms.

10.3.     You agree that transmission of information to or from the Website does not create between You and Us any relationship that deviates from those specified in this Terms. 

10.4.     These Terms and the Privacy Policy, as amended from time to time, constitute the only valid agreements between You and Us, and no representation, promise, consent or undertaking, whether written or oral, that is not included in the Terms or Our Privacy Policy will be binding upon the parties. 

10.5.     These Terms and the relationship between You and Us shall be governed by, and construed and interpreted in accordance with, the laws Israel, and You irrevocably submit to the exclusive jurisdiction of the competent courts of Tel-Aviv, with respect to any dispute regarding the validity, breach,interpretation, performance or otherwise arising out of or in connection with these Terms and the relationship between You and Us.

10.6.     No failure or delay on Our part in exercising any right, power or remedy thereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any such right, power or remedy preclude any other or further exercise thereof or the exercise of any other right, power or remedy.

10.7.     If any provision of these Terms is held by a court of competent jurisdiction to be unenforceable under applicable law, then such provision shall be excluded from these Terms and the remainder of these Terms shall be interpreted as if such provision was so excluded and shall be enforceable in accordance with its terms; provided, however, that in such event these Terms shall be interpreted so as to give effect, to the greatest extent consistent with and permitted by applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

10.8.     We may transfer or assign any and all of Our rights and obligations hereunder to any third party; without derogating from the above, the Website and/or any of the Services may be operated by third parties. You may not transfer, assign or pledge in any manner whatsoever any of Your rights or obligations under these Terms. 

Privacy Policy

We at Chargeflow, Inc. (the "Company", "We", "Us" or "Our"), are committed to securing your Personal Data and your privacy. This is the privacy policy that covers the Chargeflow App, website [www.chargeflow.io] (both the “Chargeflow”), and the services offered on Chargeflow (the “Services”).This Policy does not apply to the processing activities we perform as processors on behalf of our merchants and our use of their client data. These activities are addressed on our Data Processing Activities. In this Policy, you ("You", "Your" or "User") may find information about the types of information that We collect about users of Chargeflow, when We collect it, how We use it, and share it with third parties, maintain it, etc.

We will uphold the following principles:

To be transparent in respect of the collection and processing of Personal Data about you:
It is important to Us that you have at all times all the information required for you to make educated decisions about the processing of Personal Data about you. For this purpose, We will make use of various techniques and measures aimed to provide you with relevant information about the processing of Personal Data about you, in the proper manner and timing. 

In addition, if We find you are required to be provided with specific information, We will provide it to you in the appropriate time and place.

We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: privacy@chargeflow.io. 

To process Personal Data about you solely for the purposes outlined in the Policy:
The purposes for which We may process Personal Data about you include, inter alia, to provide you with Our Services, to customize our Services to your needs and preferences, to improve Our Services, to protect Our rights and interests, to offer you content and materials that can be of interest to you, to perform business and administrative activity that supports the provision of Our Services, and/or to uphold any legal and/or regulatory requirements that apply to Us. For more information, see section 6 of Our Complete Privacy Policy.

To invest significant resources in order to respect your rights in connection with Personal Data about you:
We apply significant resources to allow you to exercise your rights as a data subject. Therefore, you may approach Us at any time you wish to review Personal Data about you, have Us amend it, erase it, cease using it for specific purposes or in general, or transfer it to you or to a third party. We will fulfill your wishes in accordance with the law.

To secure Personal Data about you:
While We cannot promise absolute protection of the Personal Data about you, We can promise that We use and will continue to use a wide array of means and measures aimed at ensuring the Personal Data about you is secured. 

1. The Scope
This Policy describes what kind of Personal Data We collect about natural persons, and how We collect it, use it, share it with third parties, secure it, process it, etc.

In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to. 

In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data. 

You must be at least 18 years old to access and/or use Our Services and/or register with Us. We do not knowingly collect Personal Data about any person under the age of 13. 

2. Data Controller

The Company:
The Company is the data controller in respect of the Personal Data about you.

The Company is a processor with respect to any customer data in holds and processes on behalf of its customers. For additional information please refer to the Data Processing Activities Page.

3. When Do We Collect Personal Data About You?

We collect Personal Data about you whenever you use Our Services, use Our service channels, use the Platform and/or contact Us. 

In some instances, you will actively provide Us with the Personal Data, and in other instances, We will collect the Personal Data about you by examining and analyzing your use of Our Services and/or Our service channels.

4. No Obligation To Provide Personal Data To The Company And Its Implications

You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with the products or services you requested Us to provide you, will prevent your use of the Platform and the Services or a part thereof, and/or will cause the malfunctioning of Our Services. 

5. What Personal Data About You Do We Collect? 

Personal Data We collect upon registration with the Platform
. Upon creation of an account with Chargeflow, you provide Us with the following information: full name, user name, email address, telephone number, and your Store details as provided by the CRM and e-commerce platform, as well payment processors, and payment gateway. While some of the details mentioned above are required fields in pages of registration, others are not required, but We recommend that you complete them so that We can provide you with the best services We can. 

Personal Data We collect when you use or access the Chargeflow. Whenever you access to or use Chargeflow, We collect from you by way of observation of Your use thereof certain usage information. This information includes online activity log, traffic information (including, without limitation, IP address or device ID, time of access, date of access, web and mobile page(s) visited, language used, software crash reports and type of browser used and information regarding the device you used, location data.

Personal Data We receive from you: any Personal Data you provide to Us of your own free will when contacting Us. We may record and/or document in writing your calls. 

6. The Purposes Of The Processing Of Personal Data And Their Legal Basis 

The Company processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

The Company will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data about you are as follows:

a. Your consent that the Company will process Personal Data about you for one or more specific purposes. By way of example, for the purpose of sending marketing materials to you. 

Where the legal basis for the processing of the Personal Data about you is consent, you may at any time withdraw your consent for the purposes for which you provided your consent by sending a notice free of charge to the following email address: privacy@chargeflow.io.

Where you withdraw your consent for the processing of Personal Data about you, We might not be able to provide you with some or all of the Services you requested or in the form intended to be provided to you, and you will have no claim in respect of that. 

b. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. This refers to all the information required for us to provide you with the Services and grant you access thereto. 

c. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claims. 

The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:

Purpose / Legal Basis
1. In order to register you with Our Services 
Upon your request to open an account and register to use the Services, We will process Personal Data about you in order to allow Us to perform such request. 

• Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

2. In order for Us to be able to provide you with Our Services
Whenever you request to use Our Services, We will process the Personal Data required for Us to perform such request.

• Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

3. In order to contact you for the purpose of operational requirements
In some circumstances, We will contact you in order to update you in respect of certain operational matters—for instance, if We are wish to update you of new Services features. In these circumstances, We will need to use Personal Data about you accordingly. 

• Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

4. In order to respond to your queries, requests, and/or complaints, and to provide you with customer support services
Processing of Personal Data about you is required in order to respond to queries you have concerning your use of the Services, and in general to provide you with customer support services. 

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

5. In order to customize the Services to your Needs and preferences
We may analyze the data that We gather about you and infer from such analysis additional information about you, in order to make accessible to you a more customized content or services. 

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

6. In order to send you marketing materials
Inasmuch as you agree to receive marketing materials from Us, We will send you, via the means of communication you consented to, marketing materials relating to Our Services, whether in existence now or in the future, whether similar to Our Services and whether different ones, and/or products and services of third parties.
It is hereby clarified that you may withdraw your consent at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: privacy@chargeflow.io. Please note that you will be requested to choose from which means of communication (one, some or all) you wish to unsubscribe. It is hereby clarified that unsubscribing will not cause the deletion of your contact details, but to cease receiving marketing materials – unless you re-request to receive them.

7. In order to provide you with tailor made marketing materials and offers 
We process Personal Data about you in order to adjust the materials presented to you according to your preferences, behavior, characteristics and interests; these materials can be Ours or of third parties. For this purpose, We use Personal Data automated analysis techniques, including profiling. This activity is made in order to enhance and improve your user experience and the use of Our Services (including the Platform), and in order to offer you with additional and new products and services (whether of Ours or of third parties).

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

8. In order to comply with any legal obligations or judicial or administrative orders
We process Personal Data about you in order to comply with Our various legal obligations.

• Processing is necessary for compliance with a legal obligation to which the Company is subject.

9. In order to improve the Services, as well as to develop new ones
We may use Personal Data about you in order to improve the Services. Such processing will include, inter alia, any comments and complaints received in respect of the Services, as well as any errors and malfunctions. 

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

10. In order to perform and maintain various activities, supporting products and services
Such activities include back-office functions, business development activities, strategic decision-making, etc.

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

11. In order to analyze the effectiveness of any marketing and advertising campaigns and activities of the Company

Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

12. In order to perform analysis, including statistical analysis
We use various analytical measures (including statistical ones) to make decisions on various issues.

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

13. In order to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims
We may process Personal Data about you in order to protect Our interests, rights, and assets, or those of third parties, according to any law, regulation, or agreement, including any of Our terms and conditions and policies. 

• Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.

7. Your Right To Object To The Processing of Personal Data About You For Direct Marketing Purposes 
The Company provides you with offers that are tailored for you specifically, in order to connect you to brands, products and services in ways that are important to you. This may include ads, offers and other sponsored content related to products and services of Ours or of third parties. This is done following the processing of Personal Data about you, in order to adjust the materials presented to you, on the basis of your preferences, behavior, characteristics and interests. For this purpose, We use Personal Data automated analysis techniques that provide Us with analysis and conclusions concerning you in various aspects, including profiling. 

Similar analysis and conclusions are used to the extent that you agreed to receive marketing materials from Us, as such materials are tailored to offer you products and services which We think may be of more interest to you. 

Where Personal Data about you is processed for direct marketing purposes, you shall have the right to object at any time to such processing for this purpose, including profiling to the extent that it is related to such direct marketing, by sending a notice to the following email address: privacy@chargeflow.io, in which case We shall cease to process Personal Data about you for such direct marketing purposes. 

In addition, you may withdraw your consent from receiving marketing materials via email at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: privacy@chargeflow.io [. You can withdraw your consent from receiving marketing materials via push notifications in your mobile device’s settings page. 

Please note that if you opt out of receiving marketing communications from Us, We may still communicate with you from time to time if We need to provide you with non-marketing information about Our Services or for other legitimate non-marketing reasons.

8. Transfer Of Personal Data To Third Parties

The Company may also share Personal Data about you with third parties that provide Us with the following services: 

a. Storage and hosting providers, including cloud computing services;
b. IP address information;
c. Analysis of user experience;
d. Support;
e. Marketing and email services;
f. CRM data management;
g. Accounting and legal services; and 
h. Research, analytical, technical, and diagnostic services.

The Company may also share Personal Data about you with its related entities and business partners, which provide it with resources that enable the Company to enrich and improve the level of services and products it provides to its users. 

The Company may share Personal Data about you with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims. 

In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the Company is a part, or in the event of any similar transaction (including the sale of assets of the Company and/or of any company within the group of companies of which the Company is a part), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies of which the Company is a part. 

In the preceding twelve (12) months, We have not sold any Personal Data. 

9. Cookies and Third Party Services 
Web Tracking Information: We, and third party service providers that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the Chargeflow, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and our Contractors may also do so. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service.

Types of cookies: The cookies We may use have been classified according to their functionality, as follows: 

Type of Cookie

Purpose

Additional Information
Strictly Necessary CookiesThese cookies are strictly necessary to enable you to navigate the Platform and use features you have requested. They are used to provide you with Our content, products, and services that you have requested.Such cookies are essential to help your device download or stream information so that you can navigate around the Platform, use its features, and return to pages you have previously visited. These cookies collect Personal Data about you, such as user name and last login date, and identify you as being logged in to the Platform. These cookies are deleted when you close your web browser (session cookies).Functionality CookiesThese cookies are used to recognize you when you return to the Platform and allow Us to remember your choices and preferences. These cookies survive the closing of your web browser, and last until their applicable expiry time. Performance CookiesThese cookies are used to provide aggregated statistics in respect of the performance of the Platform and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Platform.  These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.  Third Party Marketing/Targeting Cookies These cookies are used to deliver ads and marketing communications, and to display the Platform in a manner that is more relevant to you. They are also used to measure the effectiveness of an advertising campaign. These cookies record your visit to the Platform and the pages you have visited. 
Some of these cookies are provided and used by third parties. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.  The Cookies incorporated in our Platform are as follows:


Blocking and removal of cookies
You can change your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:
Firefox
Microsoft Edge
Google
Chrome
Safari

Please note, however, that if you do so, some or all of the Platform’s features and functionalities might not perform as intended.We use mobile analytics software to allow us to better understand the functionality of Our website on your device. This software may record non personal information such as how often you use the Platform, the events that occur within the Platform, aggregated usage, performance data, and where the Platform was downloaded from. 

ONLINE TRACKING NOTICEAT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS. 

10.
Retention Of Personal Data About You

The Company shall retain Personal Data about you for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us. 

In order to ensure that Personal Data about you is not retained for longer than is required, We periodically review Personal Data retained by Us to examine whether any Personal Data can be erased. 

11. Transfers Of Personal Data To A Third Country Or An International Organization

Personal Data about you may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about you and to provide that enforceable data subject rights and effective legal remedies for data subjects are available. If you are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:

a. The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR");

b. The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or

c. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

You may request that the Company provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: privacy@chargeflow.io. 

12. Protection Of Personal Data About You

We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.  We do not guarantee however, that it will not be subject to a security event.

We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about you by such third parties. Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to Us. 

13. Links To Websites of Third Parties

The Services may provide links to websites and/or applications of third parties. The Company does not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications.

Whenever you access such third parties' websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about you. 

14. Your Rights In Respect Of The Personal Data About You

Generally, you have the right to request that We provide you with confirmation as to whether Personal Data about you is being collected by Us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict your consent to certain processing of your Personal Data. 

If you are an EEA resident, please read this section below: You are entitled to the following rights in respect of the Personal Data about you. To exercise such rights, you may send a request to exercise your rights to the following email address: privacy@chargeflow.io. 

Right of access
 
You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer. 

The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. 

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.

Right to rectification
You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement. 

Right to erasure
You have the right to obtain from the Company the erasure of Personal Data about you if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.

This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.

Right of restriction of processing
You have the right to obtain from the Company the restriction of processing of Personal Data about you if one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about you for the purposes of processing, but the Personal Data is required by you for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data about you is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

If the processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. 

Right to data portability
You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means. 

In exercising your right to data portability, you have the right for the Personal Data about you to be transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing. 

Right to withdraw consent
You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal. 

Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union. Your rights in respect of Personal Data about you as outlined in this section 14 may be restricted by European Union or Member State law to which the Company is subject.

We shall provide you with the information requested according to your rights outlined in this section 14 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. 

The information requested according to your rights outlined in this section 14 shall be provided free of charge, unless stated otherwise in this section 14. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

The Company may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section 14, if We have reasonable doubts concerning the identity of the natural person making the request. 

If you reside in California, please read below with respect to the California Consumer Privacy Act (CCPA) rights you have:

1. Right to know 

You have the right to receive the following information:
• What types of Personal Data collected;
• What are the types of sources of the Personal Data collected;
• To what end We collect the Personal Data;
• Types of third parties with whom We share Personal Data, if any; and
• The specific pieces of Personal Data We have collected about you.

2. Right of Erasure
You may ask Us to delete your Personal Data and direct Our service providers to do so.

Please note that We may not delete your Personal Data if it is necessary to complete Our legal obligation to you to provide the Services or otherwise protect Our legal rights, comply with an existing legal obligation; or use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.

3. Right to Non-Discrimination for the exercise of your privacy rights

You have the right to not be discriminated against by Us because you exercised any of your rights under the CCPA. 

4. Right to designate an authorized agent to submit CCPA requests on your behalf
You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by you. We will also require that you verify your own identity, as explained below.In order to exercise your CCPA right, please contact us using the following email: privacy@chargeflow.io.

Please note that We may need to receive Personal Data from you in order to verify your identity prior to allowing you to exercise your rights.

Changes To This Policy
We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify you of such amendments by publishing the updated Policy on the Platform. In addition, when We make significant amendments to this Policy, We will strive to inform you about such amendments via means of communication We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Platform. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page in the Services.

Data Processing

Chargeflow provides chargeback mitigation solutions, dispute management platform, chargebacks alerts services and ancillary solutions on behalf of its Merchants (the “Services”). 

For the purpose of receiving the Services, Chargeflow acts as a processor and the Merchants using Chareflow services provide Us with access to certain transaction data, which we process on their behalf in a manner described below in accordance with the merchant’s privacy policy.

A. The Personal Data we receive from the Merchant or Merchant systems:
Chargeflow connects to the merchant’s CRM system and Payment Processor and Payment Gateway and is granted access to the following data retained by the Merchant:
1. your name;
2. your address;
3. your email address; 
4. your phone number;
5. details of the disputed transaction;
6. details of the disputed order – including content, shipping information, etc.;
7. additional information related to your disputed transaction from the merchant;
8. your transacting history with the merchant.

Chargeflow does not receive your credit card or bank information. We only receive the transaction identifier.

B. How we use your Personal Data received from the Merchant 
The following list outlines the purposes for which We may process Personal Data about you based on a legitimate interest pursued by the Company or third parties:

1. In order to respond to resolve the dispute on behalf of the Merchant;
For this purpose, we may contact you directly and resolve the dispute directly and not through the credit card company;

2. In order to improve the Services, We offer, as well as to offer new ones. 
We may use Personal Data about you in order to improve the services We offer, as well as for the purpose of offering new ones; such processing will include, inter alia, developing better models for addressing chargebacks, resolving disputes, and identifying fraud patterns. We may continue to do so, even if the agreement with the Merchant is terminated.

3. In order to perform analysis, including statistical analysis. We use various analytical measures (including statistical ones) in order to make decisions on various issues, including improving existing services and introducing and developing new ones. 

C. Disclosing your Personal Data
We may also share Personal Data about you with third parties that provide Us with the following services:

a. Storage and hosting providers, including cloud computing services;
b. IP address information;
c. Support;
d. CRM data management;
e. Accounting and legal services; and 
f. Research, analytical, technical, and diagnostic services.

The Company may also share certain aspects related to Personal Data about you with other merchants in order to optimize its Services and improve fraud detection.

We also retain anonymized and de-identified data to improve our services, detect chargeback and fraud patterns and develop new offerings.

D. Data Security We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed. We do not guarantee, however, that it will not be subject to a security event. For more information see here: https://www.chargeflow.io/security

If you have any questions regarding the information provided on this page and your rights, you may contact us at privacy@chargeflow.io and we will address it in due course.