Privacy Policy

1.1 This Privacy Policy describes the policies and procedures of FinZeo Pay (“we” or “us”) on the collection, use and disclosure of your information on finzeo.com (the “Site”) and the services, applications, and other features or functionality available on or through the Site (collectively, the “Services”). FinZeo receives information about you from various sources, including through your user account/profile with FinZeo, your use of the Services, and from various third-party websites and other services.

1.2 This Privacy Policy covers FinZeo’s processing of Personal Data that FinZeo gathers when you are accessing and using the Services. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

Personal Data

2.1 This Privacy Policy also covers FinZeo’s treatment of any Personal Data that FinZeo’s business partners share with FinZeo or FinZeo shares with its business partners. This Privacy Policy does not apply to the practices of third parties, and their sites, services or applications that FinZeo does not own or control, or to individuals that FinZeo does not employ or manage (“Third Parties”). While we attempt to provide access only to those Third Parties that share our respect for your privacy, we cannot take responsibility for the content, actions or privacy policies of those Third Parties. We encourage you to carefully review the privacy policies of any Third Parties you access.

2.2 We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

2.3 Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

2.4. First and last name

2.5. Email address

2.6. Mailing address

2.7. Telephone number

2.8. Age/birthday

2.9. Company name and job title

Public Website

3.1 When you visit our website, we receive and collect certain information about you. The information that we receive and collect depends in part on what you do on our website. You may be able to improve your experience on our website when you tell us who you are (e.g. by applying for products, making inquiries, or requesting further information about a product or service). When you request information, we will ask you for your name and other personal information or obtain such data from third parties. You are free to choose whether to disclose this information to us or not.

3.2 We or our third-party service providers may use this information for a number of purposes, such as, to better service your requests and/or inquiries, monitor website usage and/or performance, improve the customer experience of our website, ensure technological compatibility with your computer, protect against fraud or identity theft, or conduct aggregate analyses on usage patterns.

3.3 If you give us information about another person, in doing so you confirm that they have given you permission to provide it to us to be able to process their personal information and also that you have told them who we are and what we will use their data for, as set out in this Privacy policy.

Application Process and Non-Public Websites

4.1 You may need to provide us with certain personal information from time to time. This information could include information such as your date of birth and address and could be protected by applicable data privacy laws. By completing the application process and/or using our non-public websites, you confirm your agreement with our processing such information and our disclosure of such information to both our affiliated companies and third-party service providers for their processing. We and they shall only use your personal information for purposes necessary for our performance of our obligations under your customer agreement and our compliance with laws and regulations. Processing purposes could include due diligence, anti-money laundering verifications and ‘Know Your Customer’ confirmations and marketing purposes.

4.2 For our customers, further information about disclosures, transfers and other processing of personal data as part of our services is set out in the documentation provided to you at the onboarding stage and is outside of the scope of this policy, which relates only to information we obtain through this website.

How and With Whom Do We Share Your Data?

5.1 We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• 5.1.1 Payment processors
• 5.1.2 Fraud prevention service providers
• 5.1.3 Analytics service providers
• 5.1.4 Hosting service providers
• 5.1.5 Marketing service providers
• 5.1.6 Staff augmentation and contract personnel
• 5.1.7 Co-location service providers
• 5.1.8 Telecommunications service providers
  

5.2 We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• 5.2.1 Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
• 5.2.2 Social media services (if you interact with them through your use of the Services)
• 5.2.3 Third party business partners who you access through the Services, including vendors
• 5.2.4 Other parties authorized by you
  
  

5.3 We also share Personal Data when we believe it is necessary to:

• 5.3.1 Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• 5.3.2 Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud.
  This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• 5.3.3 Maintain the security of our products and services.
  
  

5.4 As part of the Services, you will receive from FinZeo email and other communications. You acknowledge and agree that by availing yourself of the Services, you allow FinZeo to send you email and other communication that it determines in its sole discretion relate to your use of the Services.

5.5 We also share information with third parties when you give us consent to do so. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

5.6 FinZeo may co-promote content or services to you with businesses with whom FinZeo is or may become affiliated with, and may share your Personal Data with such affiliates.

How Long Do We Retain Your Personal Data?

6.1 We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use?

7.1 We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, all Personal Data is encrypted. You need to prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your browser by signing off after you have finished accessing your account. FinZeo endeavors to ensure that user account information is kept private. However, FinZeo cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Browsing data and cookies

8.1 This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymized tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

Third Party Cookies

9.1 The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site and Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit our Site. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties.

9.2 Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties.

9.3 Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies.

Transfer of personal information to third parties

10.1 Your personal data may be disclosed to recipients, as well as, other types of third parties engaged to help us run our business, subject to your consent if required by law. These types of third parties may include distributors of our products and services, service providers retained to perform functions on our behalf or to provide services to us, including but not limited to, accounting, audit, consulting, legal, and other professional service providers, and providers of other services related to our business. Portions of our services may be provided by organizations with which we have a contractual relationship, including subcontractors, and, accordingly, your personal data may be disclosed to them. If, in the course of order data processing, data is forwarded to service providers, we will be responsible for ensuring that your personal information continues to be protected with the same level of protection as if we were dealing with it directly.

10.2 We also may disclose your personal information to third parties: (a) in the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; (b) if FinZeo or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; (c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the terms of this privacy policy or any other agreements; or (d) to protect the rights, property or safety of FinZeo, our customers or others (and this includes exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk reduction).
The personal data that you enter on our website is stored until the purpose for which it was entrusted to us has been fulfilled. If you no longer agree with your personal data being stored, or if it was stored in error, we will have your data deleted or blocked accordingly, or make the necessary corrections (provided this is possible in accordance with the prevailing law). If you wish, we can send you information free of charge about all of your personal data that we have saved.

Direct marketing

11.1 Subject to your consent if required by applicable law, we may use your personal data to provide you with direct marketing information about our products and services as well as those of our affiliates and third parties, and we may permit those affiliates or other third parties to send their own direct marketing to you. Our direct marketing may be by e-mail, telephone, post or SMS or such other method(s) as may become relevant. In addition, we may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.

11.2 We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in e-mails, we may provide you with an “unsubscribe” link, or an e-mail address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

Other websites and information security

12.1 Other websites that may be linked to or by our website(s) are subject to their own policies which may differ from ours. You should carefully read the privacy policies of these websites before submitting any personal information. We are not responsible for any losses or damages in connection with the information, security, privacy practices, availability, content or accuracy of materials of such third-party websites.

12.2 Please remember that communications over the internet such as e-mails are not secure. We seek to keep secure all confidential information and personal information submitted to us through this website in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through this website.

Suspicious e-mail

13.1 We will never e-mail you to request personal information over the Internet or by any other means. Help protect yourself against online fraud – if you suspect that an unsolicited e-mail is fraudulent, please contact us.

Notice to persons accessing this website outside the United States

14.1 If you reside outside the U.S., any information you provide to us on our website will be transferred out of your country and into the U.S. If you do not want your personal data to leave your country, do not provide the information to us. By providing personal data to us, you explicitly consent to the transfer of your information to the U.S.

Use by minors

15.1 The Services are not directed to individuals under the age of thirteen (13), and request that they not provide Personal Data through the Services.

Changes to our online privacy policy

16.1 Please note that we will periodically make changes to our privacy policy. It is your responsibility to review this privacy policy frequently and remain informed about any changes to it, so we encourage you to visit this page often. Your continued use of our website constitutes your acceptance of any amendments to and the most recent versions of this privacy policy.
If you have any questions or comments concerning our privacy policy please let us know by e-mailing info@www.finzeo.com.