FinClusive knows the importance of personal privacy and that you take it seriously. We in turn take privacy very seriously. We are providing this notice to explain our online information practices, the collection and use of information (including personal identifying information) you submit or is requested from you directly, via our website, and our other related mobile applications, services, tools, and other communications and engagement channels (collectively, the "Platform"), and the choices you have regarding the submission of this information to FinClusive.
Summary and Terms
Scope and Consent
o We collect the following information when you use FinClusive services.
a) Registration and Profile Information: When you create an account or profile with FinClusive, you voluntarily give us personal information.
b) Information to Respond to Your Requests: You may also give us your personal information to sign up for our newsletters and other communications.
c) Information About associates, members, constituents, clients, employees or friends (collectively, “referred parties”) you invite to use FinClusive services: If you invite referred parties to join use FinClusive services, you may give us their personal information.
d) Information From Other Sources: We may, on occasion, combine information from outside sources to customize your experience on the FinClusive platform, risk management, compliance, regulatory and for know-your-customer and customer due diligence purposes, including for authentication and identity verification purposes. FinClusive may, in the future, also collect and store for such purposes various biometric information.
e) Information You Post to FinClusive: You may provide us with information regarding yourself by completing a profile.
f) Mobile Information: We may collect additional information from you if you access FinClusive through a mobile device (e.g. your unique device identifier, your device's operating system, or the mobile carrier for your phone).
g) Technical Usage Information: We use tracking technologies such as cookies and other similar technologies to measure usage.
h) Geolocation: By using FinClusive services you expressly consent to our use of your geolocation to respond to your requests, improve your customer experience, or fulfill risk management, security and/or compliance related requirements.
Uses and Retention
o Use information collected from you to access or use FinClusive services and to contact you. Your information is retained for as long as we need it for our business.
Disclosure of Information
o We may share your personal information and other information we collect with the following entities: (a) FinClusive Capital, Inc., and the rest of our corporate family; (b) our service providers; (c) Partner Banks; (d) other entities with your consent; (e) legal and law enforcement; and (f) others if there is a change of control.
o You can control how and when you want to receive notifications from FinClusive from our website, mobile applications or by following instructions within the notices.
Cookies and Tracking Technologies
o We use tracking technologies (including cookies) to recognize you, protect your privacy, and customize your experience with FinClusive.
Access and Review Options
o You can review and edit your personal information by accessing your profile on our site.
California Privacy Rights
o If you are a California resident, you may request information about our practices related to disclosing your personal information and how we respond to Do Not Track signals.
o We are not responsible for the privacy practices of third-party websites that are linked to or from our Site.
o The Platform is not intended for children under the age of 18.
Notification Regarding Updates
Scope and Consent
Information We Collect
a. You may browse our website and mobile applications without telling us who you are or revealing any personal information about yourself.
b. You may also upload photographs for your User account/profile.
2. Information to Respond to Your Requests: You may provide us your personal information so we can send you newsletters and other communications. Details of how you can opt-out of receiving any communications from us are detailed in the section headed "Your Choices" below.
3. Information About Others: You may choose to submit personal information about other people to invite them to join the FinClusive community, to initiate a money transfer to or from another person, or to send information or other forms of stored/economic value. You should receive your friend’s consent to your sharing of their personal information before submitting it to us.
4. Information From Other Sources: The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, and/or additional contact information) that we have acquired in accordance with the law and which will be used to customize your experience with FinClusive, for authentication and identity verification purposes. We may also, on occasion, combine information that you post in social media regarding the FinClusive app and/or services to address any customer service issues that you identify or to further customize your experience with FinClusive.
5. Content You Associate With Your Profile: We collect any information you enter into your User profile. This includes your contact information, your bank account information, and information related to any transfers of funds you make between you and your contacts. Also, your profile may contain a photograph or other information that identifies you.
6. Mobile Information: We may collect additional information from you if you access FinClusive services through a mobile device (e.g. your unique device identifier, Cell ID, location or GPS/geo-location, mobile number, Wi-Fi base identifier (BSSID) mobile phone number, email address, user name, mobile device name, contacts/address book, financial or payment information, apps downloaded or used so our app can appear seamlessly in participating Partner Bank’s apps, photos (paired with the contacts you access within our website or mobile applications to make it easier to find your friends), your phone’s name (e.g., John’s phone) so we can identify you, biometric data (i.e., Touch ID/Fingerprint/retina/etc.) to verify your identity, health information (only if you voluntarily provide this information to us through the Platform in the open comment areas even though we do not ask you for this) and passwords (e.g., passwords you create to access FinClusive services, and those that may be associated with your banking credentials with your permission).
7. Technical Usage Information: When you use FinClusive services, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using our services, including tracking technologies as well as logs, annotated screenshots, and other relevant device information during quality assurance and bug testing for the Platform, collectively (“usage information”). We use tracking technologies (including cookies (including cookies stored in HTML-5), flash cookies, web beacons/GIFs, embedded scripts, e-tags/cache browsers), unique device tokens, deterministic finger-printing technologies, probabilistic finger-printing technologies, device graph, unique device identifier, and unique identifier header to collect usage information and we also collect your IP address.
We may use tracking technologies for a variety of purposes, including:
1. Operationally Necessary. We may use tracking technologies required for system administration, to prevent fraudulent activity, improve security, or provide for essential business intelligence for purposes of enhancing your experience or develop and/or source additional products and services for you. We are not required to obtain your consent to tracking technologies that are operationally necessary.
3. Functionality-Related. We may use tracking technologies to tell us, for example, whether you have visited the website before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
4. Targeting-Related. We may use tracking technologies to deliver content, including ads, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content as well as track the content you access (including video viewing).
The use of such tracking technologies and data has been further described and set forth in Section 3 below.
We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information
Advanced Analytics / Artificial Intelligence / Machine Learning: We may use advanced analytics software and tools – proprietary and third party vendor-based for analysis purposes and/or as required for system administration, to prevent fraudulent activity, improve security, or provide for essential business intelligence for purposes of enhancing your experience, develop and/or source additional products and services for you, or to provide feedback and analysis to related parties, such as government/regulatory authorities, our partner banks, or clients.
Our goal is to collect and use only that information that we think is required for our legitimate business interests, in order to authenticate and verify your identity, and to improve your experience of using FinClusive services.
9. Uses and Retention:
Operations / Usage of FinClusive Services: Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:
1. Provide the services and customer support you request;
2. Process transactions and send notices about your transactions or your network activity;
3. Resolve disputes, collect fees, and troubleshoot problems;
4. Prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
5. Create a new account or connect to an existing account connection between your FinClusive account(s) and a third-party account or platform, including with our Partner Banks;
6. Customize, personalize, measure, and improve our services and the content and layout of our website;
7. Provide customer service and obtain your feedback regarding the Platform (e.g., to resolve disputes, problems with your User account/profile or the Platform)
8. Send you updates about new products and services that we are offering to customers;
9. Provide you with a safe, efficient, and customized experience
10. Compare information for accuracy and verify it with third parties; and Perform other duties as required by law.
Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze services, website, mobile application and user behavior and for general business purposes, including but not limited to data analysis, audits, developing new products, enhancing our Platform, identifying usage trends, and improving services.
Communicate With You: We use your information to contact you to maintain FinClusive services, our website and mobile applications, your FinClusive profile, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications about FinClusive, or contact you for other purposes (e.g. customer service purposes as identified by your social media posts on third-party platforms, with our channel partners with whom you may or may not be affiliated), or otherwise authorized by law.
We retain information as long as it is necessary and relevant for our operations.
10. Disclosure: Information collected on the Platform may be shared with:
FinClusive Capital and its family of companies: We may share the information we collect about you with the FinClusive Capital corporate family, including our affiliates and subsidiaries, as well as with third-party suppliers, partner banks, channel partners, specified program partners, and other affiliates. The information may be disclosed to: (i) provide our services (e.g., registration, transactions, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) guide decisions about our products, sites, applications, services, tools and communications. Members of our corporate family will use this information to send you marketing communications about FinClusive services and you will have the opportunity to opt-out in email communications.
Service Providers and Other Third Parties: We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, verifying your identity, fraud investigations, website, usage and behavior analytics, marketing as permissible, and operations).
Other Entities with Your Consent: Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Platform, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request.
Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, our Partner Banks, or any other User to legal liability. In this regard, we may share your information with third parties in response to a subpoena, other legal process and/or as permitted by law. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation or that may otherwise be requested of us.
Companies in The Mobile App Industry: If you access the Platform through a mobile device, we may also share your information with carriers, operating systems and platforms.
11. Your Choices: You can control how and when you want to receive notifications from us by following instructions within the notices. To opt out of marketing communications, use the options in the communications we send and/or visit Ad Choices (for targeted marketing) as per above. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account. You can also update your User profile and registration information, including your bank account, personal information and email addresses/mobile numbers. Keeping this information up-to-date is very important. If this information is incomplete, inaccurate or not current, please update your information by looking into your profile.
You can review and update your personal information in your account settings at any time by logging in to your account.
Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.
A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):
We use both session and persistent tracking technologies. Cookies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of FinClusive services. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
2. You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Platform that assist us with various aspects of our Platform operations and services, such as Google Analytics.
14. Third Parties: Our Platform may contain links to other third party websites, such as Partner Banks or channel partners. We are not responsible for the privacy practices or the content of these third party sites.
15. Security: We store and process your information on our servers located in the United States. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account/profile registration information are secure and not shared with third parties.
16. Children's Privacy: The Platform is a general audience platform and it is not intended for anyone under the age of 18. We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group.
18. Other information:
a. We may transfer personal information to other countries, for example, for customer service or to process transactions.
b. California: If your FinClusive account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.
c. Vermont: If your FinClusive account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.
19. Contact Us:
If your questions are not answered online, you may email us at firstname.lastname@example.org.