FINNT PRIVACY POLICY
This Privacy Policy sets forth how personal information is collected and used, that is provided on the Internet Web site located at www.finnt.com (the “Site”) and our mobile application (collectively, “Finnt, Inc.''). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Finnt, Inc. or any of its respective affiliates (together, for purposes hereof, “Finnt”). By using Finnt, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future.
Finnt is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy Policy explains how we protect personal information provided through Finnt and how we use that information in connection with our service offered through the Finnt technology (the "Service"). "Personal information" for purposes of this Privacy Policy means information that identifies you, such as your name, address, phone number, fax number or email address.
Finnt privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.
Finnt has relationships with certain service providers in order to provide its banking services and cash management programs to you. Finnt has contracted with Synapse Financial Technologies, Inc. (“Synapse”), a backend technology service provider that owns or otherwise has relationships with, (i) Synapse Brokerage LLC, an SEC-registered broker-dealer and member of FINRA and SIPC; (ii) Synapse Credit LLC, a state-licensed lender; and (iii) certain banks and financial institutions and service providers (each of the foregoing being a “Partner Financial Institution”). Among other services, Synapse assists Finnt with “Know Your Customer” requirements and other obligations. For purposes of satisfying “Know Your Customer” requirements, Finnt asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, videos, and photographs that may contain images of your face, including your driver’s license or government-issued identification number or card. Finnt will also collect information pertaining to your account transactions. Your personal information will be shared with Synapse and will be subject to the Synapse Privacy Policy. Synapse will share your information as necessary with its Partner Financial Institutions and other service providers in connection with providing their services. The privacy policies of Synapse, its affiliates and its Partner Financial Institutions can be found here.
FACTS
WHAT DOES Synapse's Bank Partners (“Bank”) AND FINNT Inc. (“The Company”) DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Contact information: name, email address, mailing address, phone number;
- Social Security number and proof of income;
- Financial information: Bank account balances and transactions history, Credit history and credit scores, paystubs;
- Demographic information: age, gender, education level, interests;
- Unique identifiers like username and account number
When you are no longer our customer, we continue to share your information as described in this notice.
Additionally, when you visit the Site or download and use our Services, we may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include:
- Type of device you use, operating system, the device identifier (or "UDID"), your IP address, geographical location;
- Mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our website, and other available information.
- Information related to your interaction with the site or mobile application, or our Services. This includes, but is not limited to, details of your purchases, content you viewed, event information, clickstream information, and cookies that may uniquely identify your browser or your account.
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Bank chooses to share; and whether you can limit this sharing.
If you are a California resident, we will not share personal information we collect about you except to the extent permitted under California law.
If Finnt, Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
QUESTIONS?
If the personal information on file for you changes, or if you no longer desire our service, you may correct or update by emailing us at [email protected].
We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us by chat or via email.
WHO WE ARE?
Who is providing this notice? FINNT Inc. in Partnership with Synapse.
WHAT WE DO
How does Finnt protect my personal information?
The security of your personal information is important to us. When you provide any sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL). The measures to protect your personal information include computer safeguards and secured files and buildings.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us.
How does the Bank collect my personal information?
We collect your personal information, for example, when you
- Open a deposit or savings account
- Provide your Social Security Number
- Share your driver’s license or government-issued ID
- Provide us your income information or wage statements
We can also collect your personal information from credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
- sharing for affiliates’ everyday business purposes—information about your creditworthiness
- affiliates from using your information to market to you
- sharing with nonaffiliates who market to you
- joint marketing with the Bank, when The Company is marketing products other than deposit accounts (including access devices like debit cards) and loans to you.
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account.
DEFINITIONS
- Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
- Company does not share with affiliates
- Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Bank shares information with the Company, a non-affiliated company it has contracted with to provide deposit and loan products and services, so they can market other financial products and services to you
- Joint marketing: A formal agreement between non affiliated financial companies that together market financial products or services to you.
- Bank & the Company jointly market deposit accounts (including access devices) and loans to you under formal agreements.The Company only will market other financial products and services (besides deposit accounts and loans) to you if expressly authorize the Company to market them to you.
OTHER IMPORTANT INFORMATION
For myself and on behalf of all joint account holders:
- I acknowledge receipt of this Privacy Notice
- I authorize the Company to send me news, features, and offers for financial products and services.
- I acknowledge that I have read and agree to the Terms of Use and Privacy Policy
SPECIAL NOTICE FOR STATE RESIDENTS
For California Residents. We will not share personal information with affiliates or nonaffiliates except as permitted by California law, such as to process your transaction or with your consent.
For Vermont Residents. We will not share personal information with affiliates or nonaffiliates except as permitted by Vermont law, such as to process your transaction or with your consent.
CCPA Privacy Notice
Privacy Policy – California
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Finnt,Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
- You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at [email protected].
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
CONTACT INFORMATION
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Website: finnt.com
- Email: [email protected]
- Postal Address: Finnt,Inc.
- 333 SE 2nd Ave, Suite 2000,
- Miami, FL 33131
Last Updated: 6/7/23