California Privacy Policy

This California Consumer Privacy Act Policy (“Policy”) is provided by Finicity Corporation(“Finicity”) including, but not limited to Finicity’s online services (i.e. Mvelopes). Finicity and its services are referred to as “we”, “us”, or “our” in the policy.

YOUR DATA

Pursuant to the California Consumer Privacy Act of 2018 (also known as the CCPA), below we list the categories of information and specific pieces of information we collect about you, as well the business purpose for collecting information about you, the sources from which we gather that information, and the third parties with whom we may have disclosed that information to.

Categories of Personal Data We Collect

We may collect certain personal information to facilitate the ability to best utilize our services.
These categories may be:

• Personal Identifiers, which may include: names; address; phone numbers; date of birth; email; account numbers; passwords; IP addresses; geotechnical information; purchase history;
• Commercial Information, which may include: records of personal property; products or services purchased, obtained, or considered; purchase history; consumer habits or tendencies; banking account number; credit/debit card numbers; bank routing numbers; and credit score;
• Professional employment information, which may include: current work status; payroll provider username and passwords; and multi-factor authentication;
• Audio data,which may include: audio recordings; or
• Anything else codified in subdivision (e) of Section 1798.80 of the CCPA.

How We Obtain Personal Data

We may obtain your personal information through a variety of sources. The potential sources are:

• Directly from the consumer;
• Public records;
• lenders;
• payroll providers;
• payment processors;
• web and data analytics;
• cloud storage providers;
• SaaS providers; or
• Partners.

Business or Commercial Purpose for Collecting Data

We may require personal information from California customers in order to best facilitate the product or products. This information may or may not be shared with third parties to best facilitate the use of the product. The business or commercial purpose for using personal information with third parties are as follows:

• Customer service;
• Quality control;
• Support and maintenance of the products;
• Internal use;
• Fraud detection;
• Comply with other local, state, and national laws;
• Debugging; and
• Other services to facilitate the use of we and the consumer.

Third Party Companies That Receive Personal Data

We utilize third parties to facilitate the product. The third parties that may receive your information fall into one of the categories below:

• Web analytics;
• Cloud Storage;
• Reporting Agencies;
• SaaS Providers; and
• Subsidiaries.

Data We Sell

We do not sell personal information to any third party.

CONSUMER VERIFICATION

In order to comply with the CCPA, we are required to verify the identity of any consumer requesting information. To request information that may have been collected in the previous 12 months, please visit our Data Privacy Consumer Rights Web Portal to initiate the verification process to move forward with the exercise of your rights.

YOUR RIGHTS

Right to Know

You have the right to request a disclosure of the personal information we have collected about you over the past 12 months, including:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting your personal information;
• The categories of third parties with whom we have shared your personal information; and
• The specific pieces of personal information we have collected about you

Right to Access

You have a right to request access to a copy of your personal information that we have in our custody and control in a readily usable format

Right to Delete

The CCPA provides consumers the ability to delete personal information, with noted exceptions, so long as the consumer is verified. To potentially delete your personal information, please visit our Data Privacy Consumer Rights Web Portal to initiate the authentication process to move forward with the exercise of your rights. If we are unable to delete your data through the exceptions found in the law, you will receive a detailed response on why deletion is not an option.

Please be aware that exercising your right to delete may affect any of your subscribed services.

Non-Discrimination

California residents have a right to access their personal information, and if requested, deleted. The consumer shall not be discriminated against from the business for exercising their rights codified in the CCPA.

EXERCISING YOUR CALIFORNIA PRIVACY RIGHTS

To exercise any of your rights listed above, please login to the portal. Or, for more information regarding your rights, contact privacy@finicity.com.

You may also contact the company by mail, please provide your full name, address, and phone number, along with a detailed request so that we can process your request in an efficient manner. Please note, that if we are unable to validate your identity through this method, the company is not obligated to comply with a request.

RESPONDING TO REQUESTS

Pursuant to California Code 999.313 (a) We will confirm receipt of request within 10 days and potential process that may follow. We aim to respond to a consumer request for disclosure, access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

AUTHORIZED AGENT

The CCPA allows consumers to designate an authorized agent to exercise the rights of a consumer. To exercise this right, a consumer must provide Us, by mail, the following information. The consumer’s name, signature, agents name, signature, expiration date of authorization, as well as other verifiable data that may be requested in order to best protect the customer.

CHANGES AND STATUS

We may revise this California Resident Privacy Notice or our practices with respect to how we use personally identifiable information at any time at our sole discretion. If we make any material changes to how we treat our customers’ personal information, we will notify you by email to the primary email address specified in your account, and through a notice on our website’s home page. You are responsible for ensuring we have an up-to-date active email address to contact you. You are advised to review this California Resident Privacy Notice periodically for any changes. Your continued use of our websites after such modifications will constitute your acknowledgment of the modified California Resident Privacy Notice and your agreement to abide and be bound by the modified Notice. Changes to this California Resident Privacy Notice are effective when they are posted on this page.

We keep this California Resident Privacy Notice under regular review and will place any updates on our website.

FAIR CREDIT REPORTING ACT

Your rights under the CCPA do not apply to any personal information that has been provided to Us in our capacity as a “consumer reporting agency” for a permissible purpose related to consumer lending or credit decisioning under the Fair Credit Reporting Act (“FCRA”) and will not be included under a CCPA request. Instead, you have the right to access any consumer report information collected pursuant to the FCRA at the Finicity Reports portal.