Privacy Policy

Last updated 11.11.2021 

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Your privacy is important to us. 

This Privacy Policy sets out how and why [ Floos Services - Sole Prioprietorship L.L.C.  ](“Floos”, “we”, “our” and “us”), and its affiliates and subsidiaries (collectively “Floos”, “we”, “us” or “our”) collect, use, share, transfer, and store personal data in connection with its operation of the Floos website and application (“Platforms”) and services (“Services”), and provides information about your rights. 

Floos is an early-wage access solution offered via the employer to their employees. Employees can access their wages via the Platforms. To the employer, it is an alternative to salary advance, without the impact on their cashflow. The employee is empowered to build up financial independence and resilience and to take control of their financial wellbeing.

This Privacy Policy (“Policy”) and [insert other terms] (as applicable) (“Terms”) set out the basis upon which you can access and use the Platforms. The Terms apply regardless of how you access the Platforms, including any technologies or devices by which the Platforms are made available to you. 

We are committed to safeguarding the privacy of the personal data that is provided to us or collected by us during the course of our business, including the personal data we receive from you through our Platform. This Policy sets out how and why we collect, store and use personal data, and provides information about your rights. Please read the following information carefully to understand our views and practices regarding how we handle your personal data.

1. WHO IS RESPONSIBLE FOR DATA PROCESSING & HOW TO CONTACT THEM? 

1.1 For the purposes of this Policy, we are the “data controller” who determines what personal data is collected and processed.

1.2 If you have any questions about this Policy, or our processing of your personal data, please contact us at: E-mail: [support@floos.ae]

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2. COLLECTION OF PERSONAL DATA

2.1 By using the Platforms and receiving the Services, you consent to our collection, use and disclosure of your personal data in accordance with the terms of this Policy. You can withdraw such consent at any time. However, this will not affect the lawfulness of the processing based on your consent prior to the withdrawal, or where we have other legitimate reasons for processing your personal data under applicable law. If you withdraw your consent, we may no longer be able to provide you with our Services or access to the Platform.

2.2 We may collect and process certain personal data directly from you and/or indirectly from other sources, which is described in more detail below.

When do we collect personal data?

We collect personal data from you in a variety of ways when you interact with us, both online and offline, depending on how you use the Platforms. Some examples are when you:

  • Register as a customer (“Customer”) on the Platforms;
  • Fill in any forms on the Platforms;
  • Download or register for the use of the application;
  • Engage with us through the Platforms or correspond with us;
  • Conduct a transaction where we collect personal data, including when required by applicable laws;
  • Contact us for help on using the Platforms;
  • Have provided a third party with permission to share with us personal data they hold about you, including your employer; or,
  • Otherwise, submit personal data to us along with any related content of the communication.

What personal data do we collect? 

We collect and process the following personal data:

Information you provide us:

  • Registration ID and Email address
  • A photograph of you;
  • Correspondence details, including any information you provide in your communications with us;
  • Electronic identification details, where required, to access the Platforms such as login and password.


Information provided by your employer is encrypted and only shared with parties necessary to process payments.

Information we collect about you online:

With regard to each of your visits to our Platforms, we automatically collect the following personal data:

  • Technical information, including the device type, Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone settings, browser plug-in types and versions, operating system
  • By using cookies: we may use ‘cookies’ to collect data relating to your general internet usage information about your visit; services you viewed or searched for; page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs)
  • Error reports and performance information of the Services and any problems you experience, including error reports
  • Troubleshooting and help information when you contact us to make a purchase or for support services, phone conversations, or chat sessions with us, which may be monitored and recorded; and,
  • Your engagement and interaction on the Platforms

Information we receive from your employer or payroll processor, which includes; 

  • Confirmation of contact details, including registration ID, name, phone number, e-mail address and address:
  • Date of birth, place of birth, place of residence, gender and nationality;
  • Contractual Data including salary information, working hours and shift plans;
  • Job title / profession;
  • Financial information, such as bank account details (including IBAN and BIC).

We may use the information to better understand you to enhance our ability to provide relevant marketing, and Services to you, enhance the Platform’s user experience and to help prevent and detect fraud.

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3. PURPOSES 

How we use your personal data

We use your personal data to;

  • Operate our Platforms;
  • Deliver and maintain our Services;
  • Support or carry out transactions;
  • Establish and maintain your account;
  • Facilitate your use of our Platforms;
  • Provide assistance and respond to your online inquiries;
  • Authenticate you;
  • Help us improve and personalise our Services;
  • Detect and prevent fraud and other prohibited or illegal activities;
  • Enforce our Terms;
  • Manage and protect our Platforms;
  • Provide you with marketing and promotional communications, and deliver targeted and relevant advertising and relevant offers to you, which includes better predicting content and marketing offers that may interest you, through electronic communications, such as email; and,
  • Respond to requests by government or law enforcement authorities conducting an investigation and comply with our legal obligations.

As a Customer, you will have the option to upload your photograph on the Platforms. We will not use or share this with any third party outside the Platforms without your consent. If you have any concerns about the use of your photographs or any other personal data, please contact us at the details above. 

Legal Basis of Processing

We process personal data for the purposes set out above.  We can only process personal data where we have a legal basis for doing so. On that basis, we collect and process your personal data for one or more of the following bases:

  • Your consent. You are free to withdraw your consent at any time by contacting us. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it. Where applicable, we may ask for your consent to processing at the point where you provide your personal data;
  • For the performance of a contract between you and us;
  • For compliance with our legal obligations, where other laws require the processing of your personal data. For example, taxation and anti-money laundering laws or to establish, defend and enforce our legal rights; or


  • For our legitimate business interests, which may include;
  • the provision of our Platforms and/or relevant Services to Customers;
  • the carrying out of marketing activities
  • improving and personalising our Services;
  • to host and maintain our site;
  • to identify potential customers; and,
  • for risk management, information security and disaster recovery purposes. 

This is provided always that our legitimate interests (or the legitimate interests of a third party) are not overridden by your interests or rights.


4. SHARING YOUR PERSONAL DATA

4.1 We may share your personal transaction data with your employers, for the purposes described in this Policy, including (without limitation) to carry out transactions you or your employer requests, or to make our business (or that of our affiliates) more responsive to your needs. 

4.2 In addition, we will share your personal data with third party marketers. We will share your personal data with our professional service providers (such as legal, audit, finance and insurance advisors) and third party financial institutions for the purpose of us operating our business.

4.3 We will also disclose your personal data in connection with law enforcement, fraud prevention or other legal action; as required by applicable law or regulation; or if we reasonably believe it is necessary to protect Floos, the Platforms, other customers or the public more generally. If Floos is sold or merges with another company, we may disclose your personal data for the purposes of that sale or merger or for the continuity of business purposes.

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5. COOKIES AND SIMILAR TECHNOLOGIES

5.1 The Platforms uses "Cookies" to enable you to sign in to our Platforms and to help personalise your online experience. These technologies and the information collected about you will be used to track your activity across multiple devices. Where appropriate, we use Cookies to store your preferences and other information on your computer and/or mobile devices in order to save you time by eliminating the need to enter the same information repeatedly.

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6. SECURITY 

6.1 We use up-to-date information storage and security to hold your personal data securely in electronic and physical form, to protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Whilst we have put in place physical, electronic and managerial procedures to secure and safeguard your personal data, we cannot guarantee that the personal data provided by you or that is transmitted via the Platforms or by electronic messaging is totally secure and safe and you provide it at your own risk.

6.2 Floos has established policies and procedures for securely managing information and protecting personal data against unauthorised access. We continually assess our data privacy, information management and security practices. We do this in the following ways:

  • Limiting employee access to viewing only necessary information in order to perform his or her duties;
  • Protecting against unauthorised access to personal data by using data encryption, authentication and virus detection technology, as required;
  • Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
  • Providing training to our employees.

6.3 We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an electronic message that appears to be from Floos asking for your personal data. Floos will not request your ID or password through electronic messages.

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7. TRANSFERS OF PERSONAL DATA 

7.1 Your personal data is stored within an external data storage provider in Bahrain. 

7.2 We only transfer personal data to such countries when it is necessary for the Platforms and the Services and any such transfers are subject to appropriate safeguards that assure the protection of your personal data, such as approved contractual arrangements (as appropriate) or otherwise in accordance with applicable laws. For further information on transfers, please contact us at [insert email].

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8. YOUR COMMUNICATION PREFERENCES, OPTING OUT OF MARKETING 

8.1 We may send marketing communications to you based on the marketing preferences you provide to us. Opportunities to select your preferences include the following:

  • You can click “unsubscribe” in any marketing electronic communications we send you, or by sending us an email at [insert email]; and
  • The account settings on the Platforms allow you to choose whether you wish to receive marketing communications from us, and to subscribe or unsubscribe to newsletters about our Services.

8.2 Any marketing by us, or any third parties on our behalf, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences (including the possibility of being removed from our advertising and marketing lists as set out above).

8.3 If you opt out of receiving marketing communications, we may still communicate with you in connection with transactions you request and/or Services related matters.

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9. YOUR RIGHTS

9.1 You have the following data subject rights. Please contact us using the contact details below to exercise any of your rights:

  • Access: you have the right to request information about how we process your personal data and to obtain a copy of that personal data.
  • Rectification: you have the right to request the rectification of inaccurate personal data about you and for any incomplete personal data about you to be completed.

9.2 Under certain conditions, you have the following rights:

  • Erasure: you have the right to request the erasure of your personal data.
  • Restrict and object to processing: you have the right to request us to restrict the processing of your personal data e.g. blocking any further use of your personal data and in certain circumstances you have the right to object to processing including for direct marketing. 
  • Right to data portability: you have the right to request us to transfer personal data we have collected about you to another organisation or directly to you.

9.3 If you have any questions about the type of personal data we hold about you or if you wish to request correction of personal data we hold about you, please send a written request to [support@floos.ae]. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.

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10. HOW LONG WE KEEP YOUR PERSONAL DATA

10.1 We will retain your personal data for as long as reasonably necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Once the time period has expired, we will delete or anonymise your personal data.

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11. LINKS TO THIRD PARTY SITES

11.1 Our Platforms will link to other, unaffiliated third party websites. Please note that Floos does not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal data.

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12. CHANGES TO THIS PRIVACY POLICY

12.1 We will from time to time make changes to this Policy. Please check back regularly to keep informed of any updates to this Policy. These changes are effective immediately, after they are posted on this page. We will make all reasonable efforts to notify you of all material changes to the Policy.