Last updated: April 10, 2023

Finli Privacy and Security

Introduction
Finli, Inc. (“Finli”) is dedicated to protecting your personal information and informing you about how we use your personal information. Finli is the owner and operator of the Platform and collects information from you (“you”, “your”, or “user”) a user of the Platform. This Privacy Policy should be read in conjunction with the Terms of Service and is integrated into the Terms of Service as one agreement. All capitalized proper nouns not defined in this Privacy Policy will have the same definitions and meanings as defined by the Terms of Service. Please review this Privacy Policy periodically as we may revise it from time to time. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Platform. If you use the Platform following a change to the terms of this Privacy Policy you agree to accept the revised policies.

Information Collected

At Finli, we collect personally identifiable information (“PII”) and non-personally identifiable (“Non-PII”) information from you. Personally identifiable information is information that can be used to identify you personally. Non-personally identifiable information is information that must be combined with other information to identify you personally.

PII Collected

You will not be required to provide us any information when you visit our Platform. However, when you interact with our Platform we may collect your: name, email, address, age, billing information, username and password, business information, company data, financial information and data, identify verification information, and other personal information. Banking information is stored by our third party financial partners and subject to their information collection and retention policies.

Non-PII Collected

Whenever you use our Platform, we may collect Non-PII from you, including but not limited to your IP address, zip code, browsing history, search history, and registration history, interactions with the Platform, usage information, location, referring URL, browser, operating system, data usage, data transferred, and Internet service provider.

Information Collected from Other Sources

We also collect PII and non-PII information from other sources. We may collect information from the following sources: Financial partners, payment processors, banks, or other financial institutions or providers; Identity verification providers; Publicly available information; Third party integrations like your bank, payment verification, or account services; Social media advertising partners.

We will treat the information collected from other sources in the same manner as we treat PII and non-PII collected from you.

Use of Your Information

Some of your information will be visible to other users of the Platform to facilitate communication. We will never sell your information without your permission; however you agree that we may use your information in the following ways: To provide any services offered and to operate the Finli Platform; To process your transactions; To enhance or improve our users’ experiences; To contact you via email or other electronic communications when you have an invoice, inquiry, or to update you about products and services offered by our Platform or our partners; To notify you of additional Finli services and updates; Security and fraud prevention; Marketing and advertising; Auditing and research; To share your information with third party partners or third parties hired by us to perform functions and provide services to us subject to the obligations consistent with this Privacy Policy.

Anonymized Data

Please be aware that we may collect and aggregate personally identifiable information from our Platform and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.

Accessing and Editing Your Information

If you have any additional questions or wish to review, change, or access any of your information collected by us, please contact us at support@finli.com. After you have cancelled your account your PII may become immediately inaccessible. Please be aware that we may keep inaccessible copies of your PII and non-PII subject to our data retention policies which are subject to change without notice.

Cookies and Tracking

We use cookies for marketing purposes and to remember you. Additionally, some third party cookies integrated into our Platform may track your usage information and interactions with the Platform. If you disable cookies from your web browser some portions of our Platform may not work as expected.

Third Party Access to Your Information

Although you are entering into an agreement with Finli to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, and others to allow you to access the Platform. Specifically, we share information with third parties to assist us in running the Platform and operations. Further, we share information with third parties to assist in marketing, analytics, advertising, interacting with us, and sending you notifications. We share information with the following third parties:
Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, financial services, data analytics, website hosting, and technical support.

Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.

Business Customers and Other Users. We share information with our business customers or other users to provide services on their behalf.

Identity Verification Services. We share information as necessary to verify your identity.

Payment providers. We share information with banks and other financial providers in connection with providing card and payment services to you.

At your Request. We share information at your request as required by you.

Marketing and Advertising. We share information collected through the Service with vendors or other parties for marketing and advertising related purposes or we may share information with our partners in connection with facilitating referral partnerships or engaging in joint marketing activities.
Throughout the course of our provision of our services to you, we may delegate our authority to collect, access, use, and disseminate your information. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. Please be aware that their collection policies for information may differ from this Privacy Policy.

Law Enforcement

You agree that we may disclose your information to authorities if compelled to by a court order. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated US laws, the terms of our Terms of Service or our Privacy Policy, or if we believe that a third party is at risk of bodily or economic harm. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you and release your information without receiving any request to third parties where we believe that it is proper to do so for legal reasons, where your actions violate any law of the United States or any other country having jurisdiction over us, our Platform, or our Terms of Service. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or federal authorities, as required.

Opt Out of Commercial, Non-Commercial Communications and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via text and emails. However, you may unsubscribe from certain communications by notifying Finli that you no longer wish to receive these communications, we will endeavor to promptly remove you from our list once we have received that request. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Third Parties

Finli or other users may post links to or embed third party websites on the Platform, which may include information that we have no control over. When accessing a third party Platform or embedded content through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties. Finli bears no responsibility for the information collected or used by any advertiser or third party websites. You must review their policies to understand how their information collection practices work.

Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards. However, as this is the Internet, we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, perform routine credit checks, enable firewalls, and take other precautions to protect yourself from security and privacy threats.

Cookies

We use the following types of cookies:
Cookie based Authentication is used to identify a user and maintain their sessions.

Your California Privacy Rights

Finli permits residents of the State of California to use its Platform, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all visitors. You may contact us at support@finli.com with any questions.

Age Compliance

We do not knowingly collect or process any information for any persons under the age of 18. Users must be over the age of 18 to submit any information through the Platform, if you are under 18 and using our Platform, please do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 18 please contact us immediately.

International Transfer

Your information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. PII and Non-PII submitted to Finli will be collected, processed, stored, disclosed and disposed of in accordance with applicable U.S. law and this policy. If you are a non-U.S. member, you acknowledge and agree that Finli may collect and use your Information and disclose it to other entities outside your resident jurisdiction. In addition, such information may be stored on servers located outside your resident jurisdiction. U.S. law may not provide the degree of protection for information that is available in other countries.

Merger and Acquisition

In the event that Finli is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.