Privacy Policy

FinClusive knows the importance of personal privacy and that you take it seriously. We in turn take privacy very seriously. We are providing this notice to explain our online information practices, the collection and use of information (including personal identifying information) you submit or is requested from you directly, via our website, and our other related mobile applications, services, tools, and other communications and engagement channels (collectively, the "Platform"), and the choices you have regarding the submission of this information to FinClusive.

Summary and Terms

A list summarizing the contents of this privacy policy ("Privacy Policy") appears below, followed by the policy in full. Should there be any discrepancy between the summary and the full Privacy Policy, the language of the full Privacy Policy shall govern.

Scope and Consent

  • By using the FinClusive website, mobile or web-based applications, tools or products and services offered by or through FinClusive (collectively, “FinClusive services”), you expressly consent to our collection, use, disclosure, and retention of your personal information and other information as described in this Privacy Policy.
  • Your use of FinClusive services is also governed by the Terms of Use.

Information Collection

  • We collect the following information when you use FinClusive services.
    1. Registration and Profile Information: When you create an account or profile with FinClusive, you voluntarily give us personal information.
    2. Information to Respond to Your Requests: You may also give us your personal information to sign up for our newsletters and other communications.
    3. Information About associates, members, constituents, clients, employees or friends (collectively, “referred parties”) you invite to use FinClusive services: If you invite referred parties to join use FinClusive services, you may give us their personal information.
    4. Information From Other Sources: We may, on occasion, combine information from outside sources to customize your experience on the FinClusive platform, risk management, compliance, regulatory and for know-your-customer and customer due diligence purposes, including for authentication and identity verification purposes. FinClusive may, in the future, also collect and store for such purposes various biometric information.
    5. Information You Post to FinClusive: You may provide us with information regarding yourself by completing a profile.
    6. Mobile Information: We may collect additional information from you if you access FinClusive through a mobile device (e.g. your unique device identifier, your device's operating system, or the mobile carrier for your phone).
    7. Technical Usage Information: We use tracking technologies such as cookies and other similar technologies to measure usage.
    8. Geolocation: By using FinClusive services you expressly consent to our use of your geolocation to respond to your requests, improve your customer experience, or fulfill risk management, security and/or compliance related requirements.

Uses and Retention

  • FinClusive may use information collected from you based on your authorized access, for utilization of FinClusive’s services and platform, and to contact you. This information is retained by us as long as is necessary to provide services, and for up to seven (7) years following the time at which any services to you have been terminated or expired as required by regulatory authorities for compliance purposes.

Disclosure of Information

  • We may share your personal information and other information we collect with the following entities: (a) FinClusive Capital, Inc., and the rest of our corporate family; (b) our service providers; (c) Partner Banks; (d) other entities with your consent; (e) legal and law enforcement; and (f) others if there is a change of control.

Your Choices

  • You can control how and when you want to receive notifications from FinClusive from our website, mobile applications or by following instructions within the notices.

Cookies and Tracking Technologies

  • We use tracking technologies (including cookies) to recognize you, protect your privacy, and customize your experience with FinClusive.

Access and Review Options

  • You can review and edit your personal information by accessing your profile on our site.

California Privacy Rights

  • If you are a California resident, you may request information about our practices related to disclosing your personal information and how we respond to Do Not Track signals.

Third-Parties

  • We are not responsible for the privacy practices of third-party websites that are linked to or from our Site.

Children's Privacy

  • The Platform is not intended for children under the age of 18.

Notification Regarding Updates

  • You agree that we may notify you about material changes to this Privacy Policy by posting notices on our platform or through our mobile application.

Contact Us

  • For more information about our privacy practices, please continue to our full Privacy Policy below or send an email to support@finclusive.com.

Scope and Consent

  • When you use FinClusive services, you are contracting with FinClusive Capital, Inc. By using FinClusive services, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

Information We Collect

  1. Registration and Account Information: We collect personal information, such as your name, date of birth, postal or email addresses, telephone, mobile numbers, name of the financial institution where you hold accounts and financial account numbers, from you when you request information from FinClusive, register as a User or update your information throughout our website or mobile applications (or in written form where it may apply), or channel partner organizations with whom you may or may not have a formal relationship or affiliation. If you are a registered User and have a bank account at one of our Partner Banks, we may also collect personal information from that Partner Bank if it receives a notification that your bank account information in our database is inaccurate and needs to be changed. Additionally, if you are a registered User and have a bank account at one of our Partner Banks, your bank's privacy policy may also apply to the information that we collect through our website, mobile applications and to the information that your bank provides to us. In addition, we may collect personal information from consumer reporting agencies in order to process your registration, verify your identity, verify you bank account information and protect against or prevent actual or potential fraud or unauthorized use, and ensure compliance with federal, state, local rules and regulations.
    • You may browse our website and mobile applications without telling us who you are or revealing any personal information about yourself.
    • You may also upload photographs for your User account/profile.
  2. Information to Respond to Your Requests: You may provide us your personal information so we can send you newsletters and other communications. Details of how you can opt-out of receiving any communications from us are detailed in the section headed "Your Choices" below.
  3. Information About Others: You may choose to submit personal information about other people to invite them to join the FinClusive community, to initiate a money transfer to or from another person, or to send information or other forms of stored/economic value. You should receive your friend’s consent to your sharing of their personal information before submitting it to us.
  4. Information From Other Sources: The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, and/or additional contact information) that we have acquired in accordance with the law and which will be used to customize your experience with FinClusive, for authentication and identity verification purposes. We may also, on occasion, combine information that you post in social media regarding the FinClusive app and/or services to address any customer service issues that you identify or to further customize your experience with FinClusive.
  5. Content You Associate With Your Profile: We collect any information you enter into your User profile. This includes your contact information, your bank account information, and information related to any transfers of funds you make between you and your contacts. Also, your profile may contain a photograph or other information that identifies you.
  6. Mobile Information: We may collect additional information from you if you access FinClusive services through a mobile device (e.g. your unique device identifier, Cell ID, location or GPS/geo-location, mobile number, Wi-Fi base identifier (BSSID) mobile phone number, email address, user name, mobile device name, contacts/address book, financial or payment information, apps downloaded or used so our app can appear seamlessly in participating Partner Bank’s apps, photos (paired with the contacts you access within our website or mobile applications to make it easier to find your friends), your phone’s name (e.g., John’s phone) so we can identify you, biometric data (i.e., Touch ID/Fingerprint/retina/etc.) to verify your identity, health information (only if you voluntarily provide this information to us through the Platform in the open comment areas even though we do not ask you for this) and passwords (e.g., passwords you create to access FinClusive services, and those that may be associated with your banking credentials with your permission).
  7. Technical Usage Information: When you use FinClusive services, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using our services, including tracking technologies as well as logs, annotated screenshots, and other relevant device information during quality assurance and bug testing for the Platform, collectively (“usage information”). We use tracking technologies (including cookies (including cookies stored in HTML-5), flash cookies, web beacons/GIFs, embedded scripts, e-tags/cache browsers), unique device tokens, deterministic finger-printing technologies, probabilistic finger-printing technologies, device graph, unique device identifier, and unique identifier header to collect usage information and we also collect your IP address.
    • We may use tracking technologies for a variety of purposes, including:
      1. Operationally Necessary. We may use tracking technologies required for system administration, to prevent fraudulent activity, improve security, or provide for essential business intelligence for purposes of enhancing your experience or develop and/or source additional products and services for you. We are not required to obtain your consent to tracking technologies that are operationally necessary.
      2. Performance-Related. We may use cookies or other tracking technologies to assess the performance of the online services, including as part of our analytic practices to improve the content offered through the online services.
      3. Functionality-Related. We may use tracking technologies to tell us, for example, whether you have visited the website before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
      4. Targeting-Related. We may use tracking technologies to deliver content, including ads, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content as well as track the content you access (including video viewing).
    • The use of such tracking technologies and data has been further described and set forth in Section 3 below.
    • We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.
    • Advanced Analytics / Artificial Intelligence / Machine Learning: We may use advanced analytics software and tools – proprietary and third party vendor-based for analysis purposes and/or as required for system administration, to prevent fraudulent activity, improve security, or provide for essential business intelligence for purposes of enhancing your experience, develop and/or source additional products and services for you, or to provide feedback and analysis to related parties, such as government/regulatory authorities, our partner banks, or clients.
    • Our goal is to collect and use only that information that we think is required for our legitimate business interests, in order to authenticate and verify your identity, and to improve your experience of using FinClusive services.
  8. Geolocation Information: When you use FinClusive services, we may collect geo-location information to provide certain location-based services that you request (e.g., maps or nearby functionality to identify FinClusive App users near you and allow other FinClusive users to be notified that you are near them), verify your identity, or any of the reasons set forth in this Privacy Policy. We disclose the geolocation data in the manner set forth in this Privacy Policy.
  9. Uses and Retention:
    • Operations / Usage of FinClusive Services: Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:
      1. Provide the services and customer support you request;
      2. Process transactions and send notices about your transactions or your network activity;
      3. Resolve disputes, collect fees, and troubleshoot problems;
      4. Prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
      5. Create a new account or connect to an existing account connection between your FinClusive account(s) and a third-party account or platform, including with our Partner Banks;
      6. Customize, personalize, measure, and improve our services and the content and layout of our website;
      7. Provide customer service and obtain your feedback regarding the Platform (e.g., to resolve disputes, problems with your User account/profile or the Platform);
      8. Send you updates about new products and services that we are offering to customers;
      9. Provide you with a safe, efficient, and customized experience;
      10. Compare information for accuracy and verify it with third parties; and
      11. Perform other duties as required by law.
    • Analyze and Aggregate Non-Personal Information: We use aggregated information about our users and non-personal information to analyze services, website, mobile application and user behavior and for general business purposes, including but not limited to data analysis, audits, developing new products, enhancing our Platform, identifying usage trends, and improving services.
    • Prevent Fraud: We use information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Use.
    • Communicate With You: We use your information to contact you to maintain FinClusive services, our website and mobile applications, your FinClusive profile, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications about FinClusive, or contact you for other purposes (e.g. customer service purposes as identified by your social media posts on third-party platforms, with our channel partners with whom you may or may not be affiliated), or otherwise authorized by law.
    • Mobile Data: When you access the Platform on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy. For example, we may use this information to provide you with location-based services, advertising, search results, and other personalized content. Such data may also be used for the purposes set forth above.
    • Maintaining Operations and Services: We retain information as long as is necessary and relevant for our operations. Additionally, we retain information as long as is necessary to provide you services, and for up to seven (7) years following the time at which any services to you have been terminated or expired as required by regulatory authorities for compliance purposes.
    • Disposal of Information: You may terminate services with FinClusive and cease use and engagement with FinClusive’s platform as per your contractual obligation with FinClusive. Should you choose to terminate services, you may request that your personal information be disposed of by FinClusive. However, FinClusive may not be able to fulfill such a request at the time of termination due to regulatory requirements. On receiving such a request, FinClusive will dispose of all personal information not required to be retained by law or regulation. Personal information no longer needed by FinClusive for the purposes outlined in this Privacy Policy is disposed of or made anonymous in a manner that prevents loss, theft, misuse, or unauthorized access.
  10. Disclosure: Information collected on the Platform may be shared with:
    • FinClusive Capital and its family of companies: We may share the information we collect about you with the FinClusive Capital corporate family, including our affiliates and subsidiaries, as well as with third-party suppliers, partner banks, channel partners, specified program partners, and other affiliates. The information may be disclosed to: (i) provide our services (e.g., registration, transactions, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) guide decisions about our products, sites, applications, services, tools and communications. Members of our corporate family will use this information to send you marketing communications about FinClusive services and you will have the opportunity to opt-out in email communications.
    • Our Partner Banks: We may share personal information of Users with Partner Banks and affiliates for the purposes described in this Privacy Policy.
    • Service Providers and Other Third Parties: We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, verifying your identity, validating and issuing a LEI, fraud investigations, website, usage and behavior analytics, marketing as permissible, and operations).
    • Other Entities with Your Consent: Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Platform, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request.
    • Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, our Partner Banks, or any other User to legal liability. In this regard, we may share your information with third parties in response to a subpoena, other legal process and/or as permitted by law. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation or that may otherwise be requested of us.
    • Change of Control - New Owners: We may share your information with other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice.
    • Companies in The Mobile App Industry: If you access the Platform through a mobile device, we may also share your information with carriers, operating systems and platforms.
    • Ad Partners: On the Platform, we may work with third parties to serve advertisement, provide us with data collection, reporting, ad response measurement and platform analytics and assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit or set their own tracking technologies/cookies. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. They might also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit and other information about you or your device in order to analyze and serve anonymous targeted advertising on the Platform and elsewhere. For more information about third party ad servers at our Platform and your ability to opt-out of targeted advertising from such third parties, please visit Ad Choices and our Cookies and Tracking Technologies Policy.
    • Social Media Plug-ins: When you interact with our Platform through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.
  11. Your Choices: You can control how and when you want to receive notifications from us by following instructions within the notices. To opt out of marketing communications, use the options in the communications we send and/or visit Ad Choices (for targeted marketing) as per above. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account. You can also update your User profile and registration information, including your bank account, personal information and email addresses/mobile numbers. Keeping this information up-to-date is very important. If this information is incomplete, inaccurate, or not current, please update your information by looking into your profile.
    • You can review and update your personal information in your account settings at any time by logging in to your account.
  12. Cookies and Tracking Technologies: When you use FinClusive services, we and our business partners may use cookies and other tracking technologies (collectively “Cookies”) for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our services, for when you later return to FinClusive.
    • When you visit our website, use our mobile application or FinClusive Services, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies. We use Cookies to recognize you as a customer; customize FinClusive Services, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our sites and FinClusive Services.
    • Certain aspects and features of the FinClusive Services and our website are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the websites and FinClusive Services may be limited or not possible.
    • Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.
    • A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):
    • We use both session and persistent tracking technologies. Cookies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of FinClusive services. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
      1. We use cookies with your prior consent as obtained through your use of FinClusive services.
      2. You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Platform that assist us with various aspects of our Platform operations and services, such as Google Analytics.
  13. Accessing, Reviewing, and Changing Your Personal Information: Registered Users can review and change personal information at any time by accessing their accounts on the platform. You may request information collected about you through or by third parties for due diligence purposes, which shall be made available to you unless not permitted by law or regulatory compliance purposes. You should promptly update your personal information if it changes or becomes inaccurate, and we shall inform and update all relevant third parties as we are required. If a request for such correction is denied, you may request reasons for such denial, which we shall provide, unless not permitted by law or regulatory compliance purposes. We may retain some information from closed accounts/p so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account is terminated or suspended, we may maintain some information to prevent re-registration. In jurisdictions in which relevant data and privacy authorities may request cooperation for disclosures or in aid of investigation related to you and your personal information, we will work with such authorities on such requests to the extent the law requires.
  14. Third Parties: Our Platform may contain links to other third party websites, such as Partner Banks, due diligence providers or channel partners. We are not responsible for the privacy practices or the content of these third party sites.
  15. Security: We store and process your information on our servers located in the United States. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account/profile registration information are secure and not shared with third parties.
  16. Children's Privacy: The Platform is a general audience platform and it is not intended for anyone under the age of 18. We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group.
  17. Notification Regarding Updates: This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party. From time to time, we may update this privacy policy, and we reserve the right, at any time and without notice, to add to, modify, change or update this Privacy Policy, simply by posting such change, update or modification on www.finclusive.com. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on our website or through our mobile application(s). Any such change, update or modification will be effective immediately upon posting. You should check the Website frequently for updates.
  18. Other information:
    1. We may transfer personal information to other countries, for example, for customer service or to process transactions.
    2. California: If your FinClusive account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.
    3. Vermont: If your FinClusive account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.
  19. Contact Us: