Effective Date: May 25, 2018
Who We Are
Finicity enables a financial data-sharing ecosystem that is secure, inclusive and innovative. The Service is operated by Finicity Corporation for users of the Service. This Privacy Statement sets forth our policy with respect to the information that is collected from visitors to our website(s) and users of the Services.
Information We Collect
Information you provide
You may choose to provide us with information including, but not limited to: your contact information (name, address, phone number and email address), usernames, passwords, personal identification numbers (“PINs”) (“Login Information”), date of birth, social security number, and any other information you choose. To maximize the value of the Services, we may request you provide additional information. Whenever we ask for additional or optional information, we identify those fields appropriately so you may know what information is required to provide the requested Service. If you choose to withhold any Personal Data requested by us, it may not be possible for you to gain access to certain parts of the Services you wish to use, or for us to respond to you appropriately.
Information we receive when you test our Services
You may provide us with Login Information to access your bank or other financial accounts when you test our Services. If you test our Services, we may collect information from your financial institution, including but not limited to:
- Bank Statements
- Bank transactions
- W-2s and other tax related documentation
Information we collect automatically
- Log Information. We collect information about your computer or web browser in order to analyze trends and administer our websites. This information is collected in a generic aggregate format and is not linked to personally identifiable information.
- Cookies. In order to better serve you and protect your account information, we use “Cookies,” nuggets of data that are stored on your hard drive as a file. Cookies data are usually stored on your computer’s hard drive as a file in a web browser folder called “Cookies,” and you can delete this file anytime you choose. The cookies used on our Services are valid only for the current session and become invalid shortly thereafter. Cookies created by our Services will only work with our Services.
- Notwithstanding any provisions of this Privacy Statement to the contrary, we collect and may share or publicly disclose compiled, aggregated data concerning financial transaction of its users. This information is collected in a generic, aggregate format and, to the extent it is shared or disclosed, will not contain any personally identifiable information.
How we use your information
We will use the information you provide in a manner consistent with this Privacy Statement. The following are examples of how we use the information we collect from you:
- To verify your identity, which is required to give you access to our Services;
- To verify your accounts and establish the requested service with the financial institutions, brokerage houses, and credit card companies of your choice;
- If you subscribe to a Service requiring payment, to process the initial payment and all subsequent payments;
- To help us improve and personalize the content and functionality of our Services;
- To help us understand your usage of the Services to improve the Services;
- To communicate with you regarding customer service matters, questions and other various comments you may send to us;
- To inform you about products, services, offers, and events we offer or sponsor, and to provide news and other information we believe may interest you;
- To communicate various technical and administrative messages regarding the Services, including notices of technology updates; and
- To offer you the option to participate in contests or surveys regarding the Services.
When we send you promotional information, we give you the opportunity to opt-out of receiving further information. Simply use the unsubscribe feature provided within each e-mail or contact Finicity (email@example.com). If you opt-out from receiving promotional materials, you may continue to receive important service announcements, which contain information about the Services to which you subscribe.
How we share your information
We will share your information with third parties only as described in this Privacy Statement. We will not share your information with entities located outside of the United States of America. The information you provide us will be shared only in limited circumstances, including:
- With Finicity-approved partners with whom you have enrolled for services after coming to Finicity;
- With third party service providers whom Finicity employs to provide marketing, security, development or other business processes or to provide services on our behalf;
- When we reasonably believe such disclosure is required to comply with the law, an investigation or other legal process, such as a court order or a subpoena;
- In connection with a sale, merger, transfer, exchange or other disposition of all or a portion of a business operated by Finicity.
How we handle / secure Your Information
- Finicity encrypts all data at rest using rotating AES 256bit keys, created and stored without human involvement.
- Finicity transmits all data using TLS1.2 with strong cipher suites and only uses legitimate SSL certificates.
- Our services and systems are audited for our handling of security and confidentiality by a 3rd party independent audit firm twice annually; once for SOC2, Type 2 and another for PCI Level 1 RoC.
Our Legal Basis for Handling Your Information
Some jurisdictions require us to disclose the legal basis on which we rely to use or disclose your information. To the extent those laws apply, our legal basis are as follows:
- Consent: Where required by law, and in some other instances, we handle your information on the basis of your consent, whether express or implied.
- Our contractual obligations to you: Our handling of your information is to meet our contractual obligations to you, or to take steps at your request in anticipation of entering into a contract with you. Our contractual obligations to you may include the creation of your account and the provision of the Services to you.
Correcting/Updating Personal Information
We provide you with the opportunity to update, correct or erase your account, financial and credit card information on our webstie. You may review and update your contact information (name, address, and email address) by contacting Finicity Support via email (firstname.lastname@example.org), phone (801) 984-4200, or the chat function within the Services.
Access to your information
In some jurisdictions, you have the right to: (i) know if we have collected information about you under this Privacy Statement; (ii) request access to the personal information we have in our custody and control (subject to certain legal limitations); and (iii) have the right to have it corrected if you believe there are any errors in your personal information. To obtain access to your information, please contact us at the contact details listed below. We may require additional information to verify your identity, which will be used solely for that purpose.
Updates to this Privacy Statement
We may revise this Privacy Statement or our practices with respect to how we use personally identifiable information at any time in our sole discretion. We will post the revisions to the Privacy Statement to our website and indicate the date of the last revision.
Questions regarding this Privacy Statement, our information practices or other aspects of privacy in connection with the use of our Services should be directed to Finicity’s Data Privacy Officer, who can be reached by email at email@example.com.
434 West Ascension Way, Suite 200
Murray, UT 84123