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Privacy Policy

Update date 25.09.2022

Privacy policy

Your privacy is important to us. This privacy statement explains:

  1. What personal data is collected by the owner of this Website or provided by you, through our interactions with you and your use of our Website (www.finanso.com), applications and software.
  2. How your personal data will be used, where it is held, how long it will be kept and your rights.

Please read this Privacy Policy carefully.

Capitalized terms that are not defined in the Privacy Policy have the meaning given to them in the Terms of Use.

Definitions and interpretation

In this Privacy, the following definitions are used:

Data controller means a person who (either alone or jointly or in common with others) determines the purposes for which and the manner in which any personal data are, or are to be processed.

Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

“You”, “your”, “User” or “data subject” means:

- Visitors to our Website

- Subscribers to any service we offer via our Website

- Users of our applications

- Prospective or existing clients corresponding with us via phone, e-mail or via other means

Data controller, “we”, “us” and “our” means:

404 PROJECTS LP, its affiliates, subsidiaries and its data processors;

Personal data (personal information) means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

This definition provides a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organizations collect information about people.

Changes to this privacy policy

We reserve the right to amend our Privacy Policy at any time. We ask you to regularly review all updates to our Privacy Policy.

Shall there be significant changes in our Privacy Policy, we will send you a notification to the e-mail provided during registration on Website or mobile application.

Who we are (Identity of the data controller)

404 PROJECTS LP, with registration number SL16159 and its registered address at 12 South Bridge, Suite 1, Edinburgh, Scotland, EH1 1DD, United Kingdom, doing business as Finanso.com, its affiliates, subsidiaries, data processors collectively referred to as “Finanso”, the “Service”.

Contact details: support@finanso.com

Your rights

You have the following rights:

The right to be informed. In this privacy statement we supply you detailed information related to your personal data storage, maintenance and processing.

The right to access information held about you. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and other information.

The right to rectify your personal data. You shall have the right to rectify your personal data without undue delay, if it is inaccurate, incomplete or out-of-date.

The right to erasure (delete or remove) your personal data. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase delete personal data without undue delay.

The right to restrict (block) processing. When processing is restricted, we will store your personal data, but not further process it. You can remove the restrictions (block) of processing at any time via request.

The right to data portability which allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. You may exercise this right, if your data is processed on the basis of your consent or a contract signed with you and the data are processed electronically.

The right to object. You have the right at any time, on the basis of your specific position, to object to the processing of your personal data.

The right related to automated decision making including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects on you.

The right to withdraw your consent. If your personal data are processed by consent, you have the right to withdraw it.

The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with your supervisory authority of your habitual residence, place of work if you have a concern about our information rights practices.

You can exercise your rights by contacting us at support@finanso.com.

You can exercise your right to erasure (delete or remove) your personal data by contacting us at support@finanso.com.

Personal data we may collect from you

We may collect and process the following data and personal information about you:

  1. Personal Data you provide us voluntarY

We collect the personal data provided by you directly.

The table below contains complete information regarding the scope of collected personal data and the purposes.

Business process

Controller

Processed personal data/

Purposes of processing

Storage period

Legal basis

Personal data recipients

User registration on the Website and access to the Service

404 PROJECTS LP

Your name, email, phone number and other relevant information when you create an account. We also may collect information relating to the actions that you perform while logged into your account.

Provision you with account related functionalities

During contract performance (Until deleting your Account)

Contract

404 PROJECTS LP

Provision you with and manage the Service

404 PROJECTS LP

Full name, date of birth, contact phone, preferred way to get a phone verification code, ID data, email address, and the password. In addition, this may include information specific to your request, such as desired loan/mortgage amount, desired region to obtain a loan/mortgage, loan/ mortgage term, card limit, daily spending limit, payment information (e.g., credit card number) for a paid Service, car make and model for auto loan or other information requested by one of our business client (the personal data provided by you is required for contract conclusion)

Performance activities associated with a contract to provide you with products or services

During contract performance (until deleting your Account) + 1 month

Contract

404 PROJECTS LP

Provision you with and manage the certain Service

404 PROJECTS LP

National identifier, credit history, credit rating data, income, expenses, data on the amount of debt (including under financial services contracts), data on your property, loan amounts, and account balances related to requesting financial products and services. Examples include credit card inquiries, and loan inquiries for products such as mortgages, personal loans, etc.

Facilitating your request and connecting you to our business clients that deliver the products and services you request

During contract performance (until deleting your Account) + 1 month

Contract

404 PROJECTS LP

Communication via web-form

404 PROJECTS LP

Name, e-mail, phone number, preferred method of obtaining a phone confirmation code, identifiers in Social Networks; contact details of your representatives

Consulting, operation effectively and doing our best to respond to your enquiry. We also use your information to send you Service-related e-mail messages/SMS or other messages via various communication channels (e.g., account verification, changes/updates to features of the Service, technical and security notices).

During contract performance (Until deleting your Account)

Contract

404 PROJECTS LP

Improvement the Service and advertisement.

404 PROJECTS LP

Name, e-mail, text and time of contacting support

We may use the information we collect to analyze and improve the Service and to provide advertising to you.

2 months

Legitimate interest

404 PROJECTS LP

We process the personal data directly provided by you from the above list, as well as the data you have opened, published on the Internet and freely available there. The provision of personal data to us may be made both at the time of your consent (contract conclusion), and at any time later, during the validity of the consent (contract performance).

The personal data provided by you during the validity of the consent (contract performance) is processed on the terms of consent (contract), unless you give other consent to the processing of personal data.

We may send you e-mail messages, phone messages containing newsletters, promotions and special offers about the Service or other services or products which we think may be the subject of interest to you. If you wish not to receive such promotional messages, you may withdraw your consent at any time by contacting us as described in paragraph “Your rights” or follow the “unsubscribe” or instructions contained in the promotional communications you receive. However, in this case we might not be able to fulfill our agreement and inform you about products and services available for you.

  1. TECHNICAL INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION:
  • Device and connectivity information such as IP (Internet Protocol) address, unique device identifiers (such as the IMEI for phones), the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting "Device Information".
  • Configuration data such as browser type, version and language setting, time zone setting, browser plug-in types and versions. Details of how you used our Website, such as your search queries. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • Log information, such as error reports, download errors, any problems you experience using our Website and any phone number used to call our customer service number.
  • Information about how you reached our Website (for example via which partners network).

We might use your automatically collected data such as IP address and browser data for our Website improvement, such as:

-to administer our Website and for internal operations, including data security, troubleshooting, testing, statistical and survey purposes;

-to ensure that content from our Website is presented in the most effective manner for you and for your device. The lawful basis for such processing is Legitimate interests.

  • Cookies and other technologies.

COOKIE POLICY

WHY DOES FINANSO USE COOKIES?

Based on the consent, we might get some information from our visitors by recording how they interact with our Website with the use of cookies, analytics tools or obtain data from the third parties.

A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a device of a user.

The cookie details are provided below.

We might use cookies to recognize you when you visit our Website or use our Services, remember your preferences, and give you a personalized experience. We collect cookies for the following purposes:

-to manage our relationship with you, analyze your application details and profile, fulfill our agreement and forward your personal details to personal loan providers;

-to develop and carry out marketing activities, study how our customers use products and services from us and other organizations and communicate with you about our products and services.

Authentication cookies. If you are signed to our Services, these cookies will help us show you the right information and personalize your experience.

Session cookies. These cookies store the ID of a session of a user. The cookie is set when a user signs in and is used to restore the session without entering the personal data.

Security cookies. We use cookies for our security features, and to help us detect malicious activity.

Preferences, features and services. These cookies help us to customize your preferences, such as which language you prefer and what your communications preferences are or to fill out forms as quickly as possible

Performance, Analytics and Research. These cookies help us analyze our Website performance. We use cookies to improve our products, features, and services, including creation of logs and recording when you access our Website.

Third-party cookies. Certain third parties may deliver cookies to your computer. The purpose of this data processing is to track conversions and to allocate them to proper affiliates. It is necessary for the performance of a contract with the third parties (our affiliates) that make use of our services. The lawful basis for such processing is our legitimate interests. Please note that we are not sharing Personally identifiable information with the third parties.

We use the following session, permanent and third-party marketing cookies, including cookies from our partners and service providers:

Domain

Cookie name

Cookie lifetime

Description of the Cookie purpose

Finanso.com

@@History/@@scroll|#

Persistent

Statistics

Finanso.com

_ga

2 years

Registers a unique ID that is used to generate statistical data on how the visitor uses the Website.

Finanso.com

_gat

Session

Used by Google Analytics to throttle request rate

doubleclick.net

IDE

1 year

Used by Google DoubleClick to register and report actions of a user of the Website after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an advertisement and to present targeted advertisements to the user.

doubleclick.net

test_cookie

Session

Used to check if the browser of the user supports cookies.

facebook.com

fr

3 months

Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.

facebook.com

tr

Session

Marketing cookie

google.com

ads/ga-audiences

Session

Used by Google AdWords to re-engage visitors that are likely to convert to customers based on online behaviour of the visitor across websites.

google.com

NID

6 months

Registers a unique ID that identifies a returning device of a user. The ID is used for targeted ads.

https://finanso.com/

i

10 years

Marketing cookie

https://finanso.com/

yandexuid

10 years

Marketing cookie

https://finanso.com/

yp

10 years

Marketing cookie

https://finanso.com/

yabs-sid

Session

Marketing cookie

https://finanso.com/

FINGERPRINT

Session

Marketing cookie

https://finanso.com/

_ym_isad

Session

Marketing cookie

https://finanso.com/

_ym_metrika_enabled

Session

Marketing cookie

https://finanso.com/

_ym_uid

2 years

Marketing cookie

https://finanso.com/

metrika_enabled

Session

Marketing cookie

https://finanso.com/

_ym_metrika_enabled_4898377

Session

Marketing cookie

https://finanso.com/

estring

Session

Marketing cookie

https://finanso.com/

clString

Session

Marketing cookie

https://finanso.com/

PP_clickid

29 days

Marketing cookie

https://finanso.com/

NEWUSER

29 days

Marketing cookie

https://finanso.com/

PATH_INFO

29 days

Marketing cookie

https://finanso.com/

idreg

29 days

Marketing cookie

What can you do if you do not want cookies to be set or want them to be removed?

Most browsers accept cookies automatically, however some people prefer not to allow cookies. You may change the security settings of your web browser in order to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites you trust, or to be notified before receiving cookies. You may also delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. However, these settings may have negative effects on the websites usability.

Browser manufacturers usually provide help pages relating to cookie management in their products. Please see below for more information:

For other browsers, please review the documentation that your browser manufacturer provides. You may opt-out of third party cookies from Google Analytics on its website.

You can op-out of interest-based targeting provided by participating advertisement servers through the Digital Advertising Alliance. In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based advertisements.

Disclosure of information to the third parties

We do not rent, sell, or share personal information about you with other people or non-affiliated companies without your consent except providing products or services you have requested when we have your permission, or under the following circumstances:

  • Lenders and other our business clients. We may share the information we collect or receive from you with Lenders or other our business clients to provide the Service to you such that they may provide you with information about your request for prequalified rates, offers, and information related to other products and services they offer. You agree that when you submit information to a Lender or the third party through the Service, submission of your information may also be governed by the Lender or the third party privacy and security policies which differ from our Privacy Policy. For details of these policies, please review the policies of the Lender or the third parties directly.

You understand that the Lenders or other our business clients may keep your information that relates to any submission of information that you may make through your use of the Service and any other information provided by Finanso in the processing of any submission of information, whether or not you are eligible for the products or services of Lenders or other our business clients. You agree to notify any particular Lender or another our business client directly if you no longer want to them to keep your information.

We may also share certain automatically collected information, including information obtained through tools such as cookies, log files (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with Lenders or other our business clients as described in the section titled “Technical information, including personally identifiable information.”

  • Service providers. We may share information with the third parties that help us operate our business and provide our services, such as parties that provide us with technology, services, data or content.

We have partnered with a number of authorized service providers (data processors), whose services and solutions complement, facilitate and enhance our own under written confidentiality agreements that guarantees that the requirements of the law will be met and the rights of data subjects are protected. Data processors only act on behalf of our documented instructions. They have direct responsibilities under the law and may be subject to fines or other sanctions if they do not comply.

These might include:

Hosting providers, Information technology service providers, data and cyber security services, web analytics, e-mail distribution and monitoring services, marketing services.

Such data processors may receive or otherwise have access to your identifiable or non-identifiable personal data, in its entirety or partially depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Under no circumstances data processors will use the data for their own purposes.

Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or legal responsibilities.

We’ll share personal data, including with such service providers as Google Inc. and Facebook. Please read the information about those companies and their data protection practices:

  • Google Inc (USA). Address: Google, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. Google Privacy policy and page about information privacy of Google Analytics.
  • Facebook, Inc (USA). Address: 1601 Willow Road, Menlo Park, CA 94025, USA (ATTN: Privacy Operations). Facebook Privacy policy.
  • Marketing partners. We may also share your information with our marketing partners. For example, we may share your information with a marketing partner who makes behaviour scoring for financial health rating.
  • Advertising. We may share certain data with Advertising platforms, including Google and Social Networks such as Twitter, Facebook, LinkedIn and Snapchat to allow us to target existing users and customers with highly relevant advertising campaigns. For the purposes of such campaigns. We may share a unique code (such as a hashed email address) with the applicable Advertising platform in order for that identifier to be matched against existing users of the relevant Advertising Platform and to identify potentially relevant audiences for targeted advertising.
  • Other parties when required by law or as necessary to protect our Users and Services. We may disclose your information to the third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
  • Administrative or judicial authority. Legal basis for such sharing is necessary compliance with our legal obligation. We may disclose or otherwise allow others access to your personal data pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable law, if we believe that the law requires us to do so with or without noticing you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention and national security.
  • In the event we are acquired by or merged with the third party entity or undergo another change of control, we reserve the right to transfer information, including any personally identifying information and non-personally identifying information, to a successor entity. In this event, we will notify you by electronic means before the information about you is transferred and becomes subject to a different privacy policy.
  • Otherwise with your consent or at your direction. In addition to the sharing described in this Privacy Policy, we may share information about you with the third parties whenever you consent to or direct such sharing.

Where Do We Store Your Information?

We take your confidentiality and security very seriously. We are committed to protecting the Personal Data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure.

PERSONAL DATA TRANSFERRING

Since Finanso is a multi-national business, we may transfer personal data between and among our affiliates, as well as transfer it to the third countries. As a result, your information may be stored and processed in any country where we have facilities, employees or in which we engage service providers. We take steps to treat personal data using the laws of the country in which we first received your data.

For certain jurisdictions your personal data may be subject to the laws of the country to which it is transferred, and if permitted by law, may be accessible without notice to you by the courts, law enforcement and national security authorities of that country. By using and participating in any of our Services or providing us with your data, you acknowledge the collection, international transfer, storage, and processing of your data.

The personal data is protected from loss, alteration or unsanctioned access. To ensure this we use relevant technical and administrative means. We are engaged in an ongoing effort to improve our data protection system.

Children

We do not sell any products or services for purchase by children. If you are under 18 or minors otherwise defined in local law or regulation, you may use our Website only with the involvement of your holder of parental responsibility. We do not knowingly collect personal information from children below 18 or minors otherwise defined in local law or regulation, without the consent of the holder of parental responsibility of the child.

Information you provide about others

In providing personal data about other individuals (such as someone in the name of whom you are registering an account or subscribing to our marketing promotions) you represent that you have notified them of (i) the purposes for which the information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information. You further represent that you have obtained all necessary consents from them.

Information for California Residents

California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we collect on our own behalf and how we share that information below. Note that while a category may be marked that does not necessarily mean that we have information in that category about you. The following table only applies to information that we collect on our own behalf, and for our own purposes; it does not include information that we collect as a service provider (business client) to another company.

In addition, please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us at: support@finanso.com.

Category of personal information that we collect

To whom we disclose personal information for business purpose

To whom we sell personal information

Registration information: name, email, phone number and other relevant information when you create an account

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Personal identifiers: such as name, phone number, date of birthday, unique personal identifier, signature, social security number, passport number, or other similar identifiers

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Contact information: name, e-mail, phone number, preferred method of obtaining a phone confirmation code, identifiers in Social Networks; contact details of your representatives

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Information about equipment (devices): data on equipment identifiers, SIM card identifiers, equipment location, cookies, software used in the equipment, technological data provided by the equipment during data transmission (protocols used, IP addresses, etc.), online identifier, email address, account name, or other similar identifiers

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Network activity data, such as internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Financial information: such as credit or debit card number, name of the financial institution in which you have an account opened, or other financial information

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Commercial information: such as information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Additional information for certain services: credit history, credit rating data, income, expenses, data on the amount of debt (including under financial services contracts), data on your property, loan amounts, and account balances related to requesting financial products and services. Examples include credit card inquiries, and loan inquiries for products such as mortgages, personal loans, etc.

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Geolocation data: such as physical location

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Inferences drawn from the above information about your predicted characteristics and preferences

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Other information about you that is linked to the personal information above

Service providers

Business clients

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

None

Besides, please review our California Privacy Policy for our California privacy disclosures and information on how to exercise your rights under the California Consumer Privacy Act (“CCPA”).

Information for Nevada Residents

Although we do not currently conduct sales of personal information, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future. To exercise this right, email us at support@finanso.com with the subject line: “Nevada: Request to Opt-Out.”