Privacy Policy
This Privacy Policy explains how UAB FluxPayAI ("FluxPay", "we", "us") collects, uses, and protects personal data in connection with our payment services.
Data Controller
Company: UAB FluxPayAI (DBA AlterFlux)
Registration No.: 306367141
Address: Gedimino pr. 20, LT-01103 Vilnius, Lithuania
Email: compliance@fluxpay.ai
Personal Data We Process
- Identity data: full name, date of birth, nationality, government-issued ID documents
- Contact data: email address, phone number, business address
- Financial data: bank account details (IBAN), transaction history, settlement records
- KYC/KYB data: proof of identity, proof of address, UBO information, corporate registry extracts
- Technical data: IP address, browser type, device identifiers, access logs
- Transaction data: payment amounts, card BIN data (no full PANs stored), timestamps, merchant identifiers
Legal Basis for Processing
- Contractual necessity: processing required to perform our payment services agreement with you
- Legal obligation: AML/CFT obligations, tax reporting, regulatory requirements under Lithuanian and EU law
- Legitimate interest: fraud prevention, system security, service improvement
- Consent: marketing communications (where applicable, with opt-out at any time)
Retention Periods
| Data Type | Retention Period |
|---|---|
| KYC/KYB records | 8 years after end of business relationship |
| Transaction records | 8 years from transaction date |
| Suspicious activity reports | 8 years from filing date |
| Access and audit logs | 5 years |
| Marketing consent records | Until consent withdrawn |
Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right of access: request a copy of your personal data
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure: request deletion of your data (subject to legal retention requirements)
- Right to restriction: request restricted processing in certain circumstances
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interest
- Right to withdraw consent: where processing is based on consent
To exercise any of these rights, contact us at compliance@fluxpay.ai. You also have the right to lodge a complaint with the State Data Protection Inspectorate (VDAI) of Lithuania.
Sub-processors
We share personal data with the following categories of sub-processors, all bound by data processing agreements:
| Category | Purpose | Location |
|---|---|---|
| Cloud Infrastructure | Hosting and data storage | EU (AWS Frankfurt) |
| KYC/KYB Provider | Identity verification | EU (Lithuania) |
| Card Schemes | Payment processing | EU |
| Banking Partners | Fund settlement | EU |
| Sanctions Screening | AML/CFT compliance | EU |