Finaco Privacy Policy

End User Privacy Policy

Effective Date: March 14, 2022

Privacy and security are very important to us at Finaco. This End User Privacy Policy (“Policy”) is meant to help you (the “End User”) understand how we at Finaco collect, use, and share end user information to operate, improve, develop, and help protect our services, and as otherwise outlined in this Policy. Please take some time to read this Policy carefully.

Please note this Policy applies to Finaco Systems Limited and its subsidiaries (collectively, “Finaco”, “we”, “our”, and “us”).

Policy Goal and Coverage

Our goal with this Policy is to provide a simple and straightforward explanation of what information Finaco collects from and about end users of our services (“End User Information”), and how we use and share that information. We value transparency and want to provide you with a clear and concise description of how we treat your End User Information. Please note that this Policy only covers End User Information that Finaco collects, uses, and shares. It does not explain what associated organizations that are also our customers do with any End User Information we provide to them (or any other information they may collect about you separately from Finaco). This Policy also does not cover any websites, products, or services provided by third-parties.

Information We Collect

Finaco may collect the following information depending on the services you use or access on the Finaco Platform:

Identifiers (for example, name, email address, phone number, and username);
Location information (for example, physical addresses, timezones and device location);
Financial information (for example, financial account name and number, balance, and transaction history);
Commercial information (for example, data relating to which of our services you use through developer apps and the dates and times of your use);
Electronic network activity information (for example, your device hardware model and operating system, and browser data);
Professional information (for example, information about your employer and payroll information); and
Inferences that we have derived from the information we’ve collected (for example, we may derive location from IP address or your annual income from your pay stubs).

Information You Provide

When you register or enroll on the Finaco Platform we collect some information about you such as your National Identification Number, date of birth, phone number, email address, next of kin information, home and office addresses, etc.

Information From Financial Records

We may receive information from operators in the informal financial services industry that we serve and with which you have accounts or are associated. Such information varies depending on a number of factors, including what and how information is made available by those operators or in cases where we offer services directly to you, the Finaco services you use. Depending on these factors, the information we collect may include identifiers, commercial information and financial information from the operators. More specifically, this may include the following types of information:

Account information, including financial institution name, account name, account type, account ownership and account number;
Information about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
Information about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
Information about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity and price;
Identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information; and
Information about account transactions, including amount, date, type, location, involved securities, and a description of the transaction.

Information From Other Sources

We may also receive identifiers and information about you directly from the associated organizations who are also our customers or other third parties, including our service providers, credit bureaus and identity verification services.

How We Use Your Information

We use End User Information principally for our business purposes which include to operate, improve and protect the services we provide and to develop new services. More specifically, we use your End User Information as follows:

Provide Services: To operate, provide, and maintain our services.
Develop Existing Services: To improve, enhance, modify, add to, and further develop our services.
Help Prevent Fraud or Protect Privacy: To help protect you, our partners, Finaco, and others from fraud, malicious activity, and other privacy and security-related concerns.
Develop New Services: To develop new products and services, and in some cases insights based on the data we’ve collected about you.
Provide Support: To provide customer support to you, including to help respond to your inquiries related to our services.
Investigate Misuse and Misconduct: To investigate any misuse of our service, including violations of our terms of service, criminal activity, or other unauthorized access to our services.
For Legal Purposes: To comply with contractual and legal obligations under applicable law and for other legal purposes such as to establish and defend against claims.
With Your Consent: For other notified purposes with your consent or at your direction.

How We Share Your Information

We share End User Information strictly for our business purposes:

With other customers on the Finaco Platform based on your consent or direction;
To enforce any contract with you;
With our data processors and other service providers, partners, or contractors in connection with the services they perform for us;
With your connected financial institution(s) to help establish or maintain a connection you’ve chosen to make;
If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
Between and among Finaco and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;
As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, our partners, Finaco, and others; or
For any other notified purpose with your consent or at your direction.

We may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research to the extent permitted under applicable law.

Our Retention Practices

We retain End User Information for no longer than necessary to fulfill the purposes for which it was collected and used, as described in this policy and the terms of service, unless a longer retention period is required under applicable law. As permitted under applicable law, even after you stop using our service, we may still retain your information (for example, information provided through another customer). However, your information will only be processed as required by law or in accordance with this Policy.

Protection of Information

Finaco implements security policies and practices designed to protect the confidentiality and integrity of information about you, including the information you provide to us (such as National Identification Number and other identifying information), as well as any other information we collect about you. Finaco implements control measures designed to limit access to this information to personnel who have a business reason to know it and prohibits its personnel from unlawfully disclosing this information.