Effective Date: July 24, 2018
As used in this policy, the terms “using” and “processing” information include using cookies on a computer or mobile device, tablet computers or other device, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
What information do we collect?
Our primary goals in collecting information are to provide and improve our Site, Fintel Services, services, features and content, to administer your membership and to enable users to enjoy and easily navigate the Site and Fintel Services.
When registering on our Site or Fintel Services, as appropriate, you may be asked to enter your: name, e-mail address, telephone number, employer information, location, or other personal information.
Personally Identifiable Information
In the course of using the Site or Fintel Services, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name, email address and phone number.
We also collect other information that you provide as part of registration and the administration and personalization of your account (e.g., without limitation, the name of the financial institution where you work and/or are affiliated (the “Indicated Entity”) and individual preferences) (“Non-Identifying Information”). Some of this information is optional.
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) to provide the Site and Fintel Services and administer your inquiries.
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining two items of Non-Identifying Information) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Fintel Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Site and Fintel Services and to analyze and understand how our Site and Fintel Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We also use your Personal Information to contact you with Fintel newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.
The Site and Fintel Services may include certain communications from Fintel, such as administrative messages, that you will not be able to opt out of receiving.
When you visit the Site or Fintel Services, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site and Fintel Services, pages of our Site and Fintel Services that you visit, the time spent on those pages, information you search for on our Site and Fintel Services, access times and dates and other statistics. From users of the Fintel Services, we also collect Log Data such as agent version, platform, SDK version, API key for the Fintel Services, Fintel Services version, mobile device model, manufacturer and version, access times and dates, time zones and network status. We use this information to monitor and analyze use of the Site and the Fintel Services and for the technical administration of the Site and the Fintel Services, in order to increase our Site and Fintel Services’s functionality and user-friendliness, and to better tailor our Site and Fintel Services to our visitors’ needs. For example, some of this information is collected so that when you visit the Site again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Site meet the criteria required to process their requests.
Identity theft and the practice currently known as “phishing” are of great concern to Fintel. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account login information, or social security or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Information Sharing and Disclosure
When you register through the Site or Fintel Services and submit your Personal Information, your access may be verified, in part, via information that we receive from third parties as part of our security and on-boarding process. As well, when you register through the Site or Fintel Services, your access may be verified in part by another users who works at your Indicated Entity (an “Administrator”). An Administrator will see your first and last name, your Indicated Entity, your role and department to assess in part whether to grant you access to the Site or Fintel Services. If you are not granted access we will not share any Personal Information uniquely provided by you during the registration process. Users will be able to see your first and last name, email address, phone number, your Indicated Entity, your role, and your department. Users will also be able to see your status and availability that you may choose to modify on the Site or Fintel Services from time to time. You can choose what other Personal Information you provide as part of your profile, including for example, a profile picture, and in some cases you can choose whether to share that information publicly on the Site and Fintel Services by making selections via the “settings” section of your account. We will display your Personal Information on the Site or Fintel Services according to the preferences you set in your account. You must provide truthful and accurate information about yourself but any information you choose to provide should reflect how much you want other Fintel users to know about you.
Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
We may employ third party companies and individuals to facilitate or perform the Fintel Services and to provide the Site (e.g., including, without limitation, maintenance services, database management, web analytics and improvement of the Site’s and Fintel Services’s features) or to assist us in analyzing how our Site or Fintel Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Compliance with Laws and Law Enforcement
Fintel cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Fintel or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Fintel may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Changing or Deleting Your Information
Fintel will retain an archived copy of the contents of communications that have been sent using the Site or Fintel Services, the identities of the sender(s) and the recipient(s) of such communications and any other information which Fintel is required to retain by law or legitimate business purpose.
All Registered Users may review, update, correct or delete the Personal Information by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your account in our system, please contact us at firstname.lastname@example.org with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. As indicated above however, we will retain an archived copy of your records as required by law or for legitimate business purposes.
Fintel is very concerned with safeguarding your information. The security of your personal information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site or via the Fintel Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to Other Sites
Our Site or the Fintel Services may contain links to other websites. If you choose to visit a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can do this by contacting us at email@example.com. To the extent that Fintel’s processing of your personal data is subject to the General Data Protection Regulation, Fintel relies on its legitimate interests to process your data.
Our Policy Toward Children
The Site and Fintel Services are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.
If you have any questions about this Policy, please contact Fintel at:
Fintel Technologies, Inc.
41 East 11th St., 11th Fl.
New York, NY 10003