FINQ AI, LLC., and its affiliates (the “Company” or “we” or “us” or “our”) respects the privacy and security of our clients and users’ (“User”) personal information (“Personal Information”) and we are committed to protecting it. This Privacy Notice (“Notice”) describes how we collect, use, store, share and protect your Personal Information. It also provides information about your Personal Information choices.
1. SCOPE AND OVERVIEW
This Notice applies to the Personal Information we handle or process in our business, when A User interacts with our Company’s website (“Site”), digital services offered on the Site, mobile applications (“Apps”) and other related services (“Services”) we may provide (collectively the “Online Services”). This Notice applies to you whether you are accessing the Online Services for personal or business purposes, although you are 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.
2. PERSONAL INFORMATION WE COLLECT
We may collect and retain personal information (“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.
Information We Collect From Users
As of the date of this Notice, we collect only the following information regarding the User:
Credit Card Information;
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 we may collect from Users may include, but are not limited to:
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;
identification information, including biometric data (e.g., a copy of User’s identification certificate which include, amongst others, facial photograph, full legal name, gender, date of birth, nationality, civil status, current address), and other government-issued identification numbers, tax information, subject to limitations imposed by applicable law;
health data (e.g., health declaration, disabilities, diseases, medicines, hospitalization) and such other information necessary to conduct due diligence and comply with applicable state and industry laws, such as anti-money laundering and other rules and regulations applicable to the Company;
financial information (e.g., credit card, bank account information source of funds, investment objectives, gross annual income, approximate net worth) and any other financial information about User’s assets, credit history and capacity, type of securities in User’s investment portfolio, investment style preference or otherwise required to ensure that the Online Services are suitable for User;
relevant third-party contact information (e.g., family members, beneficiaries, attorneys, attorneys-in-fact, shareholders, beneficial owners, persons under any trust, trustees, partners, committee members, directors, officers or authorized signatories, guarantors, other security and other individuals); and
B. Information We Collect Automatically or From Others
We may collect Personal Information automatically when you use our Online Services:
Automatic Data Collection: When you visit our Site, or otherwise use or interact with our Service, we 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 you 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 you use our Online Services (e.g., information received from GPS signals, nearby wi-fi access points and cellular antennas, whether the app is active or not);
3. HOW WE USE AND SHARE YOUR PERSONAL INFORMATION
We use the Personal Information we collect for a variety of business purposes, such as, to operate, provide, and improve the Online Services.
Providing our Online Services
We use your information to fulfill our contract with you and provide you with our Online Services, such as:
creating and managing your User account;
verifying the identity or authority of User and its 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.
We use your 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 our third-party service providers and partners in order to determine how we can jointly improve our 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 YOUR INFORMATION TO THIRD PARTIES
We disclose User Personal Information to third parties for various purposes. When we share User information with third parties, we require such recipients to agree to only use the Personal Information shared with them in accordance with this Notice, our contractual specifications, and our other specific instructions. Third parties are directed to refrain from using Personal Information for other purposes.
To Protect Ourselves or Others
Compliance with the Law and Requests from Law Enforcement. We may share your information to comply with applicable laws or regulations and contractual obligations including, but not limited to, our obligations with other financial institutions (e.g., disclosure to fund managers, portfolio service providers) government entities, other regulatory authorities, and financial institutions. We also may share your 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 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. We also will share information to protect our legitimate business interests and to enforce our 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 we may share your Personal Information with unaffiliated third-party service providers and/or sub-contractors which provide services for the Company's business operations and support the provision of services. We may share your Personal Information with unaffiliated third-party services 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 we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, we disclose your Personal Information as part of such a transaction as permitted by law and/or contract.
5. YOUR PRIVACY RIGHTS AND CHOICES
A. Data Subject Rights.
We provide you with the following privacy choices regarding your Personal Information as required by applicable law and described below.
Request to Know about your Personal Information and the Ability to Port Information. You are entitled to review your Personal Information held in our systems and databases and receive a copy of your data;
Request Correction. Your Personal Information be amended if you find that it is incorrect, incomplete, unclear, or outdated
Request deletion. You can request that we delete your Personal Information. This is subject to certain exemptions provided for by law.
Request Restriction or Object. You can restrict how your Personal Information is used or object to how it is processed.
Withdraw consent. You can withdraw consent to our processing of your Personal Information.
If you would like to exercise some or all of these rights, please send an email to: Hello@finqai.com. You will not be discriminated against for exercising your rights.
Supplemental Data Subject Rights for Users in the European Economic Area (“EEA User”).
1. Legal basis to process data
The Company will only process User’s Personal Information if it has one or more of the following legal bases for doing so:
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.
2. 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 Delete: 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.
6. INTERNATIONAL DATA TRANSFERS
You acknowledge that all Personal Information processed by us may be transferred to, and stored anywhere in the world (e.g., Israel), that may not be subject to equivalent data protection law. Personal Information may also be processed by staff situated outside the EEA who works for us or for one of our service providers:
to store it;
where we are legally required to do so;
to facilitate the operation of our businesses, where it is in our legitimate interests, and we have concluded these are not overridden by User's rights.
Where Personal Information is transferred by the Company or its affiliates in relation to providing the Online Services, the Company will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, which may include by entering into European Commission approved standard contractual clauses relevant to transfers of Personal Information and that it is treated securely and in accordance with this Notice.
7. DATA RETENTION
Company may retain certain Personal Information of Users as long as reasonably required for the following purposes, at Company’s sole discretion: (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.
8. HOW WE STORE AND SECURE YOUR DATA
Data Location. Company currently maintains, stores and processes Personal Information in the following jurisdictions: Israel, US and Europe and other locations as reasonably necessary for the proper performance and delivery of the Online Services (for example, in those locations where the Company’s contracted service providers are storing or processing the Personal Information), or as may be required by applicable law. Each User hereby gives User's consent to such transfer, processing, and storage of User's Personal Information outside its jurisdiction. Data protection and privacy laws may vary between jurisdictions, nevertheless, the Company will comply with reasonable industry standards, and apply such appropriate lawful mechanisms and contractual terms as required to ensure adequate protection of the Users’ Personal Information, as set forth in this Notice. For data transfers from the EEA or the UK to countries which are not considered to be offering an adequate level of data protection, Company (and anyone acting on its behalf) have entered into Standard Contractual Clauses, as applicable.
Security. We take steps to ensure that your information is treated securely. We take appropriate technical and organizational measures to protect the information we collect about Users from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. We also require our 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, we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
9. CHILDREN’S INFORMATION
The Company's Online Services are not intended for children. Children under 18 years of age, may use the Online Services only with the involvement of a parent or guardian.
10. SUPPLEMENTAL NOICE FOR CALIFORNIA RESIDENTS
This supplemental Notice for California residents (“California Notice” only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. (“CCPA”), including any subordinate or implementing legislation, is applicable to the following:
The Company will only process Personal Information on User’s behalf.
11. OTHER PROVISIONS
Database Registration. Certain Personal Information processed by us is stored in database no. 700071406 at the Israeli Registrar of Databases. You are advised, however, that we are under no obligation to maintain any information, and that you must not rely on our databases as a backup option.
Changes to the Notice. Company may change this Notice from time to time in our sole discretion. Company will post any changes to this Notice on its Site, and if Company makes any material changes to this Notice, we will notify you as required by applicable law. Company will obtain User’s prior consent to any material changes, as required by applicable laws (as defined in the Company’s Data Processing Agreement located: [insert hyperlink] (“DPA”). 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.
12. CONTACT US
FINQ AI, LLC.
Address: 42 Montefiore St., Tel Aviv, Israel, 6520115