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The Stalirov&Co team audited the Ecommerce platform and drew up the Terms of Use and the Privacy Policy

About company and product

Flimcor is a marketplace that hosts products for wholesale. Analytics, which is pulled to the product page, is a platform's feature. For example, a wholesale buyer (partner) can see the average price per unit of goods on such sites as Aliexpress, Prom.ua, Amazon and Alibaba. In addition to wholesales, Flimcor provides dropshipping services.

Partners can integrate the marketplace using API and/or through the web interface, copy photos and text descriptions of the goods for placement on their resources. The scope of opportunities depends on the tariff plan.

Client Request

🔸Draw up the rules for bulk purchases and delivery of goods.

🔸Make sure that analytics on product pages are advisory and subject to change.

🔸Get the ability to integrate with advertising and analytics services.

🔸Get the right to process personal data in Ukraine and the EU.

Resolution from IT lawyers

🔸Conduct an audit and draw up Terms of Use and a Privacy Policy to determine the list of personal data and objects of processing.

🔸Fulfill the requirements for connecting the Fondy payment system and limit the platform's liability for changing the margin level of the product.


Our IT lawyers described the platform terms of using and reselling goods by wholesale buyers

◼When using the platform, partners choose one of the offered tariff plans.

◼Partners who have a paid plan can copy photos and text descriptions of goods from the platform.

◼Partners have the right to sell the goods at their own discretion and at his own risk, including independently determining the selling price. He is obliged to check the information about the product on the platform, including tracking its relevance, balance in the company's warehouse, movement and location.

We fixed the Flimcor right to suspend platform access 

Flimcor has the right to suspend a partners’ platform access or deprive them of such an access in case of violation of the terms of the agreement, tariff plan or documentation on connecting the API and its use, as well as in case of termination of the agreement.

We described the terms of purchase, delivery and storage of goods

◼A partner pays 100%  from the total price of goods in advance payment.

◼Payment for the goods is carried out in a non-cash form according to the current account or by using the functionality of the My Account platform.

◼Flimcor delivers the goods from its warehouse or pre-imports the goods. The platform indicates the minimum possible quantity of goods for delivery.

◼Goods shall be shipped within the territory of Ukraine exclusively by carriers available for election through platform features.

IT lawyers set the conditions to cancel order

A partner can cancel the order until:

◼payment for goods by the Flimcor to the supplier – in case of import;

◼sending goods – if the goods specified in the order are available at the Flimcor's warehouse.

We described the rules for goods and funds returning

In the event of complete order cancellation Flimcor returns to a partner the funds paid for the goods. In case of partial cancellation of the order, Flimcor refunds the funds paid for the part of the goods in respect of which the order was cancelled.

Funds shall be returned to a partner only after the goods return to the Flimcor warehouse in a non-cash form by transferring funds to a partner's current bank account or crediting them to the balance on the platform.

We described the API integration procedure

A partner may use the platform with API integration or through the web interface.

When using the API, a partner is obliged to independently integrate it with the site, while observing the technical requirements described in the API connection and using documentation.

IT lawyers set disclaimers to protect Flimcor rights

◼Flimcor is not responsible for any consequences resulting from the incorrect integration of the API to a partner's site.

◼The parties agree that the projected sale price of the goods is advisory in nature. Flimcor is not responsible for any use by the partner of such a price.

◼Flimcor is not responsible for the partner's obligations to consumers.

◼Flimcor is responsible for supply of inadequate quality goods within the cost of the goods.

GDPR lawyers identified personal data Flimcor collects, processes and stores

Flimcor collects, processes and stores: name; email address; phone number; identifiers (nicknames, IDs, etc.) in messaging programs (Skype, Telegram, WhatsApp, Messenger, etc.); date of birth; floor; addresses of pages in social networks; photos; postal or other physical address; information specified in orders, inquiries, correspondence; information about consent to the use of cookies.

A partner confirms that he has received consent to the personal data processing, use and storage.

We identified the external advertising and analytics services the site uses

Flimcor collects personal data from social networks; email services, including Google; Google ADS, Facebook; collection of statistics, incl. Serpstat; marketplaces: prom.ua, rozetka.ua, amazon.com. 

We drew up the Cookie Policy

The site automatically collects users' data using internal technologies and cookies, which are necessary to ensure the correct operation of the site.

Data collected automatically includes:

◼IP address, connection information, web log, user settings, language, time zone;

◼device information, device ID and type, hardware capabilities and web browser;

◼location: GPS coordinates, common territorial affiliation, determined based on the IP address;

◼data about user actions: browsing pages, clicking on links, using buttons, browsing time, searching for queries.

We suggested to implement a popup to obtain user consent to the use of Cookies

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