Privacy Policy

Use of information

We use the information we collect from you, including your nonpublic personal information, as follows:

• To operate, maintain, and improve our Sites, products, and services, including to monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site.
• To communicate directly with you, including to send you email messages, respond to comments and questions, and provide customer service.
• To send you email messages relating to our Sites, including information such as confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, enforce our Terms of Service, and perform other duties required by law or contract.
• To provide and deliver you products and services.
• To remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites.
• To provide custom, personalized content and information, including targeted content and advertising.

Sharing of personal information

We may share nonpublic personal information as follows:

• With other users of the Sites, as necessary to provide our services to you.
• We may share nonpublic personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
• We may share nonpublic personal information with other users of our Sites with whom you interact with on the Sites. You control what information you share.
• We may share nonpublic personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• We may share nonpublic personal information with other companies and brands owned or controlled by Finosu, Inc., and other companies owned by or under common ownership as Finosu, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.
• We may share nonpublic personal information for legal, protection, and safety purposes.
• We may share information to comply with laws.
• We may share information to respond to lawful requests and legal processes.
• We may share information to protect the rights and property of Finosu, Inc., our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
• We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
• We may share nonpublic information with those who need it to do work for us, including with third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfillment, web hosting, or providing analytic services.

Regardless of anything to the contrary, we will not share your SMS telephone number with a third party for marketing purposes. We may also share aggregated and/or anonymized data with others for their own uses, and we may also use such data for our own purposes, to the extent permitted by applicable law.

Gramm-Leach-Bliley Act Opt-Out Provision

Under the Gramm-Leach-Bliley Act, you have the right to limit our sharing of your nonpublic personal information as follows: (a) for our affiliates’ everyday business purposes – information about your creditworthiness; (b) for our affiliates to market to you; and (c) for non-affiliates to market to you.

If you prefer that we not share your nonpublic personal information as set forth in the immediately preceding sentence, please follow the instructions regarding the opt-out procedure below. If you choose not to opt-out, we reserve the right to share this information.

You may exercise your right to opt-out by providing written notice to regulatory@finosu.com that clearly states you choose to opt-out of Finosu sharing your nonpublic personal information with affiliated third parties or nonaffiliated third parties, in accordance with GLBA. Your opt-out preference will become effective within two (2) business days of receipt. This opt-out preference will remain active until you cancel this option.

Please note that this policy is not a binding contract and replaces any previous notices that you may have received from us. In the event that we make material changes to this policy, we will disseminate a revised privacy notice for your review, and provide an additional opportunity for you to exercise your opt-out preference.

California and Virginia Residents

This section applies to California and Virginia residents, as applicable.

Neither the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (“CCPA”) nor the Virginia Consumer Data Protection Act (“VACDPA”) apply to certain information, such as information subject to the Gramm-Leach-Bliley Act. The specific personal information that we collect, use, and disclose relating to an individual covered by the CCPA or VACDPA will vary based on our relationship or interaction with you.

Additional information choices and changes

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

You may send requests about personal information by contacting regulatory@finosu.com.

You can typically remove and reject cookies from our Sites with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Sites work for you. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at regulatory@finosu.com. We may not be able to modify or delete your information in all circumstances.

Third party tracking and online advertising

We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our Site over time so that they may play or display ads on our Sites, on other devices you may use, and on other websites, apps, or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or device, you may be able to set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or device. You may also be able to limit interest-based advertising through the settings on your device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. Some of these opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookie, you may need to perform the opt-out task again. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

How we store and protect your information

Your information collected through our Site may be stored and processed in the United States or any other country in which Finosu or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Finosu or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Policy.

We employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Site. However, no security system is impenetrable, and we cannot guarantee the security of our systems.

Children’s privacy

Finosu does not knowingly collect or solicit any information from anyone under the age of 13 on this Site. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at regulatory@finosu.com.

Links to other websites and services

The Sites may contain links to and from third-party websites of our business partners, advertisers, and social media sites, and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

Contact information

We welcome your comments or questions about this privacy policy. You may also contact us via email or at our address:

Email
regulatory@finosu.com

Address
Finosu, Inc.
169 Madison Ave, STE 11311
New York, New York 10016
United States