FINQ AI, LLC., and its affiliates (the “Company” or “we” or “us” or “our”) respects the privacy and security of clients and users’ (“User”) personal information (“Personal Information”) and the Company is committed to protecting it. This Privacy Notice (“Notice”) describes how the Company will collect, use, store, share and protect User Personal Information. It also provides information about User Personal Information choices.
1. SCOPE AND OVERVIEW
This Notice applies to the Personal Information the Company handles or process in the Company’s business, when aUser interacts with Company’s website (“Site”), digital services offered on the Site, and other related services (“Services”) the Company may provide (collectively the “Online Services”). This Notice applies to User’s whether User is accessing the Online Services for personal or business purposes, although User is not under any obligation to provide Personal Information. This Notice does not apply to any products, services, websites, links, apps or any other content that might be offered on the Online Services by third parties.
This Notice, Terms of Use and other agreements the Company enters into, govern the use of our Online Services. By attempting to use or access Online Services, User agrees to be bound by the Notice. If User does not agree with the Notice, User must not use or access the Online Services.
2. PERSONAL INFORMATION COMPANY COLLECTS
Company may collect and retain Personal Information from Users’ interactions with us to open an account or sign up for a newsletter, contact us with questions, or enter into agreements with us.
A. Information Company Collects From Users
As of the date of this Notice, the Company collects the following information regarding the User:
Name
Email address
Requests or inquiries User’s make about the Online Services, and
Communications between Users and the Company (e.g., emails, phone conversations, chat sessions, surveys, feedbacks, or other promotional offers running on the Online Services).
In the future, the categories of Personal Information the Company may collect from Users may include, but is not limited to:
Credit Card Information;
Additional contact details (e.g., name, postal address, email address, phone number);
Account information, including routing numbers, password and other login or authentication and security credential information;
Profile information that arises from User’s use of the Online Services such as investments or transactions made by User;
Requests to transfer or receive funds via the Online Services;
Information about the Online Services requested and how it is used;
User’s background information, User responses to account registration questionnaires and other information needed for AI or Algorithm Based Technologies for Automated Decision Making; and
B. Information Company Collects Automatically or From Others
The Company may collect Personal Information automatically when User uses Online Services.
Automatic Data Collection: When User visits the Site, or otherwise uses or interacts with the Company’s Online Service, the Company may automatically collect:
Unique identifiers and information contained in cookies;
Settings preferences and backup information;
Uniform Resource Locators (URL) clickstream to, thru, and from Company's website and Online Services;
Content viewed or searched for, page response times, and page interaction information (such as scrolling, clicks, and mouse-overs);
Network and connection information, such as the Internet protocol (IP) address and information about User's Internet service provider; and
Computer and device information, such as browser type and version, operating system, or time zone setting.
Location data when User visits or accesses Online Services (e.g., information received from GPS signals, nearby wi-fi access points and cellular antennas, whether the app is active or not). User can disable location-based services through the device’s operating system. Once such service has been disabled, FINQ will no longer receive information regarding User’s location. ;
Cookies and Pixels. The Company may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information from User’s device through use of the Service. Technologies are small data text files stored on User’s computers, tablets, mobile phones, or other devices that allow us and the Company’s partners to identify Users each time the individual initiates a session on the Site. Technologies facilitate and customize the User’s experience of the Online Services and track User’s use of the Online Services. Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Site or the Service may not work properly.
Analytics. The Company uses Google Analytics to collect information about the use of the Online Services. Google Analytics collects information such as how often User visits the Online Services, which pages User visited when doing so, and which other sites User used prior to coming to the Online Services. Google’s ability to use and share information collected is governed by the Google Analytics Terms of Service and the Google Privacy Policy. Users can visit these links to find out how Google Analytics collects and processes data and how to opt out.
Social Media Platforms and Links to Other Websites. When clicking on certain social media links provided on the Online Services (e.g., Facebook, Instagram, WhatsApp) User will be transferred to the Company’s sites on such social media (“Social Media Sites”). The User’s use of Social Media Sites is governed by the terms of use and privacy policy of the respective Social Media Sites and not by the Company. By clicking links to a third-party website or service on the Online Services, a third party may also transmit cookies to Users. This Notice does not cover the use of cookies by any third parties, and the Company is not responsible for such third parties’ privacy policies and practices. The Company does not have any control over any third-party privacy practices, or the technology used by any third parties in order to collect any Personal Information. Each User is advised to thoroughly review such third parties’ privacy policies before making any use of such third party’s products and services.
3. HOW THE COMPANY USES AND SHARES USER PERSONAL INFORMATION
The Company uses the Personal Information the Company collects for a variety of business purposes, such as, to operate, provide, and improve the Online Services.
A. Providing the Online Services
The Company uses Personal Information to provide Users with Online Services, such as:
creating and managing User accounts;
verifying the identity or authority of User and User’s relevant contact persons or representatives;
contacting Users and communicating with User with respect to the Online Services (e.g., by phone, email, chat, or responding to inquiries from Users);
informing User about updates or offers;
providing marketing, analytics, and advertising to promote Company’s Online Services some of which may personalized or interest-based advertising;
providing assistance and support; and
fulfilling User requests.
B. Administrative Purposes
We use User information for various administrative purposes, such as:
meeting contractual or legal obligations and statutory requirements;
detecting security incidents (e.g. preventing and detecting fraud or illegal activity);
researching and enhancing the Online Services and for internal research and internal analysis purposes (e.g., trouble shooting, data analysis, testing and statistical purposes including examining User behavioral data and interactions with the Online Services to improvement and development of the Online Services;
analyze transactional data performed through third-party service providers and partners in order to determine how the Compay can improve products and services for Users.
The Company may ask for User’s consent to use User's Personal Information for a specific purpose, as required by applicable law.
4. SHARING USER INFORMATION TO THIRD PARTIES
The Company may disclose User Personal Information to third parties for various purposes. When the Company shares User information with third parties, the Company requires such recipients to agree to only use the Personal Information shared with them in accordance with this Notice, contractual specifications, and other specific instructions. Third parties are directed to refrain from using Personal Information for other purposes.
Compliance with the Law and Requests from Law Enforcement. The company may share User’s information to comply with applicable laws or regulations and contractual obligations including, but not limited to, the Company’s obligations with other financial institutions (e.g., disclosure to fund managers, portfolio service providers) government entities, other regulatory authorities, and financial institutions. The Company also may share User information to comply with a court order, subpoena, or other legal process, respond to a lawful request by a government authority, law enforcement agency or similar government body (whether situated in User's jurisdiction or elsewhere), or when the Company believes release is necessary and appropriate to investigate, prevent or take action (including exchanging information with other companies and organizations) related to illegal activities, fraud detection and prevention, Anti-Money Laundering, IP violations, situations involving potential threats to the personal safety of others, and for credit risk reduction.
Legitimate Business Interests. The Company will also share information to protect the Company’s legitimate business interests and to enforce terms and other agreements, or protect the rights, property, or security of the Company, its Users, or others.
Business Transfers. The Company may share Personal Information with its affiliated entities in connection with the provision of Online Services to users.
Third-Party Service Providers. There are certain circumstances in which, the Company, may share your User Personal Information with unaffiliated third-party service providers and/or sub-contractors that provide services for the Company's business operations and support the provision of services. The Company may share User Personal Information with unaffiliated third-party service providers and/or subcontractors for the provision of certain services, including but not limited to data processing and hosting, payment processing, IT, marketing, consultancy services, identification verification and fraud detection, customer support, AI tools systems, and messaging or mailing services. In certain cases, we may disclose aggregated or de-identified information about Users for marketing, advertising, research, or other purposes to unaffiliated third-party service providers and/or subcontractors.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If the Company is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, the Company may disclose User Personal Information as part of such a transaction as permitted by law and/or contract.
5. USER PRIVACY RIGHTS AND CHOICES
A. Data Subject Rights
The Company provide Users with the following privacy choices regarding Personal Information as required by applicable law and described below.
Request to Know about User Personal Information and the Ability to Port Information. User is entitled to review User’sPersonal Information held in our systems and databases and receive a copy of your data.
Request Correction. User’s Personal Information be amended if User finds that it is incorrect, incomplete, unclear, or outdated.
Request Deletion. User can request that the Company delete User’s Personal Information. This is subject to certain exemptions provided for by law.
Request Restriction or Object. User can restrict how User’s Personal Information is used or object to how it is processed.
Withdraw Consent. User can withdraw consent to the processing of the User’s Personal Information at anytime.
To exercise some or all of these rights, please send an email to: Hello@finqai.com. User will not be discriminated against for exercising User’s rights. The Company will respond to verifiable requests received as required by law, and may also ask Users for additional information to verify or process the request. The Company may also check with third-party identity verification services to verify Users identity before taking any action regarding Users Personal Information. The Company will respond substantively to verifiable requests within the periods required by law, which is most likely within 45 days unless the Company notifies you that additional time (up to 45 extra days) is needed.
6. Supplemental Notice
This supplemental notice for California, Colorado, Connecticut, Delaware, Iowa, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia residents (“Supplemental Notice States”) only applies to the Company’s processing of Personal Information that is subject to the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Delaware Personal Data Privacy Act (“DPDPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Maryland Online Data Privacy Act (“MODPA”), the Montana Consumer Data Privacy Act (“MCDPA”), the Nebraska Data Privacy Act (“NDPA”), New Hampshire Privacy Act (“NHPA”), the New Jersey Data Protection Act (“NJDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Tennessee Information Protection Act (“TIPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UTCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”) (collectively the “State Privacy Law(s)”).
The State Privacy Laws provide state residents with specific rights regarding their Personal Information. If User is a resident of one of the states with State Privacy Laws, User can opt out of automated profiling that produces legal or similarly significant effects. Only User, or someone legally authorized to act on User’s behalf, may make a verifiable consumer request related to User’s Personal Information. User may also make a verifiable consumer request for your minor child. To designate an authorized agent, please contact the Company as outlined in “Contact Us” below and provide written authorization signed by the User and User’s designated agent. To protect User’s privacy, the Company will take the following steps to verify identity before fulfilling User’s request. When User’s make a request, the Company will ask you to provide sufficient information to confirm that User is the person the Company collected Personal Information from or an authorized representative. This may include asking User to answer questions regarding User’s account and use of Online Services.
Certain states permit businesses to charge Users a fee if their requests are excessive; the Company may charge a fee for excessive requests. Subject to certain exceptions, California consumers can make the following requests twice every twelve (12) months. If the Company determine that the User’s request is excessive, the Company may charge a fee or notify the User of the reason for the denial of the request.
The Company asks that User’s with disputes about the Company’s privacy practices contact the Company as described in the “Contact Us” section below. If the Company declines to act in response to any of User’s privacy requests, User has the right to appeal that decision within a reasonable amount of time but no later than 90 days from the date of the decision. To submit an appeal request, User can exercise this right by contacting the Company as described in the “Contact Us” section below. If User believes rights have been violated and cannot resolve the issue directly with the Company, User may file a complaint with User’s state attorney general’s office.
Civil Code Section § 1798.83 permits Users of the Company’s Sites and Online Services who are California residents to request certain information regarding the disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us as outlined in “Contact Us” below.
7. Supplemental Data Subject Rights for Users in the European Economic Area (“EEA User”)
A. Legal basis to process data
The Company will only process User’s Personal Information if it has one or more of the following legal basis for doing so:
Contractual Necessity: processing of Personal Information is necessary to enter into a contract with User, to perform Company’s contractual obligations to User under the Terms of Use, to provide the Online Services, to respond to requests from User, or to provide User with customer support;
Legitimate Interest: Company has a legitimate interest to process User’s Personal Information;
Legal Obligation: processing of User’s Personal Information is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
Consent: processing of User’s Personal Information with User's consent.
B. EEA User's Data Subject Rights Regarding Personal Information
Subject to Applicable Data Protection Laws, an EEA User has certain rights with respect to the EEA User's Personal Information, including the following:
Request to Access: EEA User may ask whether Company holds Personal Information about User and request copies of such Personal Information and information about how it is processed;
Request to Correct: EEA User may request that inaccurate Personal Information is corrected;
Request to Erasure: EEA User may request the deletion of certain Personal Information;
Request to Restrict: User may request the Company to cease or restrict the processing of Personal Information where the processing is inappropriate;
Request to Object: EEA User may object to automated decision making (including profiling) in certain circumstances.
Withdraw Consent: When EEA User consents to processing User’s Personal Information for a specified purpose by Company, User may withdraw User’s consent at any time, and Company will stop any further processing of User’s data for that purpose.
In certain circumstances, Company may not be able to fully comply with EEA User’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Company will still respond to notify User of such a decision.
EEA User can exercise EEA User’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting the Company at: Hello@finqai.com. In some cases, Company may need EEA User to provide Company with additional information, which may include Personal Information, if necessary to verify EEA User's identity and the nature of EEA User's request.
8. INTERNATIONAL DATA TRANSFERS
The Company may transfer and store User Personal Information processed by us anywhere in the world (e.g., Israel) including countries that may not have data protection laws that are equivalent to those in User’s jurisdiction. User Personal Information may also be processed by Company staff situated or service providers located outside the EEA for the following purposes:
data storage and backup;
to meet legal compliance obligations;
to facilitate the business operations, where the Company has determined its legitimate interests are not overridden by User’s rights.
When the Company or its affiliates transfer Personal Information to provide the Online Services, the Company will implement reasonably necessary safeguards to protect your data including: relying on recognized legal adequacy mechanisms, which may include entering into European Commission-approved Standard Contractual Clauses, where applicable, and ensuring all transfers comply with this notice and applicable data protection laws and requirements.
9. DATA RETENTION
Company, at its sole discretion, may retain certain Personal Information of Users as long as reasonably required for the following purposes: (i) to preserve the relationship with Users; (ii) to provide Users with the Online Services; (iii) to comply with Company’s legal or contractual obligations; (iv) to protect Company from any potential disputes; (v) to conduct audits; or (vi) as otherwise required to comply with contracts and comply with all applicable laws.
10. HOW THE COMPANY SECURES USER DATA
The Company take steps to ensure that User information is treated securely. The Company takes appropriate technical and organizational measures to protect the Personal Information collected about Users from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. The Company also requires third-party service providers and partners to have appropriate safeguards in place. Unfortunately, no data security system, Internet, is ever 100% secure or error free; therefore, The Company cannot ensure or warrant the security of any information User provide to the Company. To the fullest extent permitted by applicable law, the Company does not accept liability for unintentional disclosure.
11. CHILDREN’S INFORMATION
The Company’s Online Services are not intended for children. Children under 18 years of age, or the age of majority in their state, may only use the Online Services with the consent and oversight of a parent or guardian.
12. OTHER PROVISIONS
Changes to the Notice. Company may change this Notice from time to time in the Company’s sole discretion. Company will post any changes to this Notice on its Site, and if Company makes any material changes to this Notice, the Company will notify User as required by applicable law. User will be deemed to have accepted the Notice, as amended, if the User continues to use the Online Services after the Notice takes effect.
13. CONTACT US
If User has any questions about this Privacy Policy, Company data practices, or User wishes to submit a request to exercise User’s rights as detailed in this Notice, please contact the Company using the following information:
FINQ AI, LLC.
Address: 9 Ahad ha’am St., Tel Aviv, Israel, 6520115
Email: Hello@finqai.com