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Effective date April 22, 2021.

This Privacy Policy describes the privacy practices of Finary, Inc. and our subsidiaries and affiliates (collectively, “Finary”, “we”, “us”, or “our”) in connection with the www.finary.io website, the Finary mobile application, and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

Table of Contents

  • Personal Information We Collect
  • How We Use Your Personal Information
  • How We Share Your Personal Information
  • Your Choices
  • Other Sites, Mobile Applications and Services
  • Security Practices
  • International Data Transfer
  • Children
  • Changes to this Privacy Policy
  • How to Contact Us


Personal Information We Collect

Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes: 

  • Business and personal contact information, such as your first and last name, email and mailing addresses, phone number.
  • User generated information, such as information that you upload, generate, transmit, or otherwise make available on the Service, such as photos, videos, images, music, comments, questions, messages, your “likes”, as well as associated metadata.  Metadata includes information on how, when, where and by whom a piece of content was created or collected, how that content has been formatted or edited, and the location associated with the creation of the content.
  • Payment information needed to complete transactions, including payment card information or bank account number. 
  • Profile information, such as the username that you may set to establish an online account with us, password, date of birth, redemption code, biographical details, profile pictures, links to your profiles on social networks, interests, preferences, occupation, employers, title, position, employment function, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.  
  • Registration information, such as information that may be related to a service, an account or an event you register for.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Demographic Information, such as your city, state, country of residence, postal code, and age.
  • Financial information, such as your stated income, economic standing, financial account numbers or payment card information.
  • Government-issued identification numbers, such as a national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license of state ID number), and an image of the relevant identification card.
  • Precise geolocation information, such as when you authorize our mobile application to access your location.
  • Transactional information, such as information about payments to and from you and other details of products or services you have purchased from us. 
  • Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
  • Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms.  We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. 

If you choose to login to the Service via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.  You can read more about your privacy choices in the “Third party platforms or social media networks” portion of the “Your Choices” section.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited,  your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications. 

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile application, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites. A SDK is third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising. 

For information regarding your choices regarding the use of cookies and similar technologies on the Service, see the “Your Choices” section below.

Referrals. Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

Retention.  We will retain your personal information for the period necessary for the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The categories of personal information listed above may be linkable to your identity by us and the third parties described below in How we share your personal information.

How We Use Your Personal Information

We use your personal information for the following purposes or as otherwise described at the time of collection:

To operate the Service.  We use your personal information to:

  • provide, operate and improve the Service
  • provide information about our products and services
  • establish and maintain your user profile on the Service
  • facilitate your to login to the Service via third-party identity and access management providers, such as Facebook
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
  • facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality
  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
  • communicate with you about events or contests in which you participate
  • understand your needs and interests, and personalize your experience with the Service and our communications
  • provide support and maintenance for the Service
  • to respond to your requests, questions and feedback

For research and development.  We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications.  We may send you [Company]-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below. 

To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy: 

Affiliates.  We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Payment processors. We may share your personal information with any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe.  Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy .  

Advertising partners.  We may share your personal information with third party advertisers and advertising companies for the advertising purposes described above. Advertisers whose ads are posted on our Service may be able to infer information about you when you click on those ads (e.g., that you have a newborn if you click on an ad about a newborn product).

Third-party platforms and social media networks. We may share your personal information with third party platforms and social media networks if you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third party, or otherwise linking your account with the Service to a third party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other users and the public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to maintain a user profile with information about yourself and your brokerage accounts that you can make available to other users or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. We may make available settings through the ‘Privacy’ tab within the ‘Accounting Settings’ page that enable you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to such users or the public. 

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.  

Business transferees.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.  

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Sites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.  

Privacy settings and location data. Users of our mobile application have the choice whether to allow us to access your precise location data. Your device settings may provide the ability for you to revoke our ability to access location data.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. 

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Do Not Track.  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.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.

Delete your content or close your account. You can choose to delete certain content through your account.  If you wish to request to close your account, please contact us.

Other Sites, Mobile Applications and Services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.  Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International Data Transfer

We are headquartered in the United States and may use service providers that operate in other countries.  Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children

The Service is not intended for use by anyone under 13 years of age.  If we learn that we have collected personal information through the Service from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents with concerns to contact us.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to support@finary.io. You may also write to us via postal mail at:

Finary, Inc.

Attn: Legal – Privacy

245 8th Ave #1053

New York, New York 10011