‍Last Updated 07/28/2021
‍

Privacy Notice

Privacy and security are critical to us at Finexio.This End User Privacy Policy (“Policy”) is meant to help you (the “end-user”)understand how we at Finexio collect, use, and share end-user information inour possession to operate, improve, develop, and protect our services and asotherwise outlined in this policy. Please take some time to read this policycarefully.

Please note: this policy applies to FinexioInc. and its subsidiaries, including Finexio SCF LLC (collectively, “Finexio,”“we,” “our,” and “us”).

This policy provides a simple explanation ofwhat information Finexio collects from and about end users (“End UserInformation”) and how we use and share that information. We value transparencyand want to provide you with a clear and concise description of how we treat your End User Information.

Please note that this policy only covers the information that Finexio collects, uses, and shares. This policy also does notcover any websites, products, or services provided by others. We encourage youto review the privacy policies or notices of developers or those third parties for information about their practices.

‍

Information Collection, Use, andSharing

We are the sole owners of theinformation collected on this site. We only have access to/collect the information you voluntarily give us via email or other direct contact. We will not sell orrent this information to anyone.

We will use your information to respondto you regarding the reason you contacted us. However, we will not share your information with any third party outside our organization other than as necessary to fulfill your request.

Unless you ask us not to, we maycontact you via email in the future to tell you about specials, new products orservices, or changes to this privacy policy.
‍

Information you provide. 

When you connect your financial accounts with a developer application orotherwise connect your financial accounts through Finexio, where applicable, we collect identifiers and login information required by the provider of youraccount, such as your username and password, or a security token. In some cases, we also collect your phone number, email address, security questions and answers, and one-time password (OTP) to help verify your identity before connecting your financial accounts. When providing this information, you givethe developer and Finexio the authority to act on your behalf to access and transmit your End User Information from the relevant bank or other entity that provides your financial accounts (we’ll call them “financial product and service providers” in this policy). You may also provide us with identifiers and other information, including your name, email address, and phone number, when you contact us or enter any such information on our websites.
‍

Information we collect from your financialaccounts. 

The information we receive from the financial product and service providers that maintain your financial accounts varies depending on a number of factors, including the specific Finexio services developers use, as well as the information made available by those providers. But, in general, we collect the following types of identifiers, commercial information, and other personal information from your financial product and service providers:

• Account information, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, account number, routing number, and sort code;
• Information about an account balance, including current and available balance;
• Information about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
• Information about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
• Information about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
• Identifiers and information about the account owner(s),  including name, email address, phone number, date of birth, and address information;
• Information about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and
• Professional information, including information about your employer, in limited cases where you’ve connected your payroll accounts or provided us with your pay stub information.

The data collected from your financialaccounts includes information from all accounts (e.g., checking, savings, andcredit card) accessible through a single set of account credentials.

Information we receive from your devices. When you use your device to connect toour services through a developer’s application, we receive identifiers andelectronic network activity information about that device, including internet protocol (IP) address, timezone setting and location, device location, hardware model, operating system, which features within our services you access, browser data, and other technical information about the device. We also use cookies or similar tracking technologies to collect usage statistics and to help usprovide and improve our services. You can find more information about how weuse cookies and your related choices in our Cookie Policy described below.

Information we receive about you from other sources. Wealso receive identifiers and commercial information about you directly from therelevant developer or other third parties, including our service providers, bank partners, and identity verification services. For example, developers mayprovide information such as your full name, email address, phone number, orinformation about your financial accounts and account transactions, and ourbank partners or service providers may provide information such as the statusof a transaction you have initiated.

Inferences we derive from the data we collect. We may use the information we collect about you to derive inferences. For example, we may infer your location or yourannual income or revenue based on the information we have collected about youfrom you or other sources.

How We Use Your Information

We use your End User Information for a number of business and commercial purposes, including to operate, improve, and protectthe services we provide, and to develop new services. More specifically, we use your End User Information:

• To operate, provide, and maintain our services;
• To improve, enhance, modify, add to, and further develop our services;
• To protect you, developers, our partners, Finexio, and others from fraud, malicious activity, and other privacy and security-related concerns;
• To develop new services;
• To provide customer support to you or to developers, including to help respond to your inquiries related to our service or developers’ applications;
• To investigate any misuse of our service or developers’ applications, criminal activity, or other unauthorized access to our services;
• To comply with contractual and legal obligations under applicable law; and
• For other notified purposes with your consent.

How We Share Your Information

We share your End User Information for anumber of business purposes:

• To enforce any contract with you;
• With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or developers;
• With your connected financial institution(s) to help establish or maintain a connection you’ve chosen to make;
• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
• In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
• Between and among Finexio and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;
• As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, developers, our partners, Finexio, and others; or
• For any other notified purpose with your consent.

We may collect, use, and share End UserInformation in an aggregated, de-identified, or anonymized manner (that doesnot identify you personally) for any purpose permitted under applicable law.This includes creating or using aggregated, de-identified, or anonymized databased on the collected information to develop new services and to facilitateresearch.

We do not sell or rent personal informationthat we collect.
‍

Our Retention Practices

We retain End User Information for no longerthan necessary to fulfill the purposes for which it was collected and used, asdescribed in this policy, unless a longer retention period is required orpermitted under applicable law. As permitted under applicable law, even after you stop using an application or terminate your account with one or moredeveloper, we may still retain your information (for example, if you still havean account with another developer). However, your information will only beprocessed as required by law or in accordance with this policy.

Please refer to the “Your Data Protection Rights” section for options that may be available to you, including the rightto request deletion of End User Information. You can also contact us about ourdata retention practices using the contact information below.
‍

Your Data Protection Rights

Under applicable law, and subject to limitations and exceptions provided by law, you may have certain rights inrelation to the End User Information collected about you and how it is used,including the right to:

• Access End User Information collected about you;
• Request that we rectify or update your End User Information that is inaccurate or incomplete;
• Request, under certain circumstances, that we restrict the processing of or erase your End User Information;
• Object to our processing of your End User Information under certain conditions provided by law;
• Where processing of your End User Information is based on consent, withdraw that consent;
• Request that we provide End User Information collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible;     and

Under the California Consumer Privacy Act(“CCPA”), and subject to certain limitations and exceptions, if you are aCalifornia resident, you may have the following rights with respect to End User Information we have collected about you that constitutes personal information under the CCPA:

• To request access to more details about the categories and specific pieces of personal information we may have collected about     you in the last 12 months (including personal information disclosed for business purposes);
• To request deletion of your personal information;
• To opt-out of any “sales” of your personal information, if a business is selling your information; and
• To not be discriminated against for exercising these rights.

To exercise your access or deletion rights, youcan contact us at the email and phone number listed below. You may be requiredto provide additional information necessary to confirm your identity before wecan respond to your request.

We will consider all such requests andprovide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.
‍

Changes To This Policy

We may update or change this policy from timeto time. If we make any updates or changes, we will post the new policy on Finexio’swebsite at https://Finexio.com/privacy-policy and update the effective date at the top of this policy. We will also notifydevelopers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify their end users about suchchanges to this policy, as appropriate.
‍

Contacting Finexio

If you have any questionsor complaints about this policy, or about our privacy practices generally, youcan contact us at privacy@Finexio.com
‍

Cookies

We use “cookies” on this site. A cookieis a piece of data stored on a site visitor’s hard drive to help us improveyour access to our site and identify repeat visitors to our site. Cookies canalso enable us to track and target the interests of our users to enhance theexperience on our site.
‍

Links

This website contains links to othersites. Please be aware that we are not responsible for the content or privacypractices of such other sites. We encourage our users to be aware when theyleave our site and to read the privacy statements of any other site thatcollects personally identifiable information.

This privacy notice discloses the privacy practices for https://finexio.com. This privacy notice applies solely to information collected by this website. It will notify you of the following:
‍

1. What personally identifiable information is collected from you through the website, how it is used and with whom it may be shared.
2. What choices are available to you regarding the use of your data.
3. The security procedures in place to protect the misuse of your information.
4. How you can correct any inaccuracies in the information.

Information Collection, Use, and Sharing

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.

We will use your information to respond to you regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.

Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

Your Access to and Control Over Information

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via info@finexio.com or 818.724.8110. When you contact us, you may:

• See what data we have about you, if any.
• Change/correct any data we have about you.
• Have us delete any data we have about you.
• Express any concern you have about our use of your data.
  ‍

Cookies

We use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site.
‍

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

‍