At Finwello, Inc. (“Finwello” also referred to as “we,” “us,” or “our”), our mission is to help individuals set financial goals, track budgets, and manage their financial health.  We take you through the journey of managing your financial picture in one place.

7. Your Choices to Control Your Information

8. Cookies and Similar Technologies

9. Links to Other Sites

10. Children’s Privacy

11. Updates to this Privacy Policy

12. Contact Us

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL DATA. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU SHOULD NOT ACCESS OR USE OUR SITES, SERVICES, OR OTHERWISE INTERACT WITH US.  BY USING OR ACCESSING OUR SITES, REGISTERING OR SUBMITTING YOUR INFORMATION THROUGH OUR SERVICES, OR INTERACTING WITH FINWELLO, YOU CONSENT TO THIS PRIVACY POLICY AND TO OUR COLLECTION AND SHARING OF YOUR INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY.

What is “Personal Data”? “Personal Data” means information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, contact information, email address, phone number, device IDs, certain cookie and network identifiers, and other categories described below.

We may de-identify, aggregate and/or anonymize your Personal Data by excluding and removing data components (such as your name, email address, or linkable tracking ID) through obfuscation, or through other means so that the resulting dataset is no longer personally identifiable to you (such resulting dataset is known as “Aggregated Data”). Our use of Aggregated Data is not subject to this Privacy Policy.

The information we collect depends upon things such as the nature of our relationship, the method you communicate with us, and the purpose of your interaction with us. We may collect the following information:

• • General Identification Information, such as your name, date of birth, age, gender and marital status.

• • Contact Information, such as your email addresses, mailing addresses, telephone numbers, professional title and business name.

• • Account Information, such as your username, email address, and/or password to login to your online account with us.

• • Government-Issued Identifiers, such as your Social Security Number, driver’s license number, passport number, tax identification number, or other identification numbers issued by government bodies or agencies

• • Financial Information, such as your bank account numbers, debit card numbers, credit card numbers, and account credentials, account balances, account transactions, or information from linked third-party accounts according to your settings with that account.

• • Professional or Employment-Related Information, such as employment history, current or prior employer, job title, compensation information, employment benefits, employment status, and professional certifications.

• • User preference information regarding personality data, Our platform identifies personality data such as (1) financial-related personality data and (2) work-related personality data obtained by completing the validated personality assessment. As it relates to financial-related personality data this means your natural approach to savings habits, budgeting, setting goals, and risk appetite. We collect this information through your responses to the validated personality assessment to deliver a more customized experience to fulfill your financial goals. We will never share your financial personality data with your employer other than in a highly-aggregated and de-identified format. As it relates to work-related personality data, this means communication preferences, work talents (strengths, struggles), career insights (role-alignment), and work rewards (non-financial motivators). We also collect this information through your responses to the validated personality assessment, and we may provide your employer with your work-related insights at your employer’s option. These insights can be used for hiring decisions, team and talent development, and career and leadership coaching. We do not share your character assessment with your employer other than in a highly-aggregated and de-identified format.

• • User preference information regarding their financial health data, Your financial health can be measured using financial health indicators such as whether you spend less than income, pay bills on time and in full, have a sustainable debt load, have enough savings to cover short term emergencies, and have sufficient long-term savings. We collect this information using transaction data from your connected financial accounts to deliver a more customized experience to fulfill your financial goals. This data is a measure of the impact of our platform on the overall financial health of your employer’s workforce, and to help address specific areas of opportunity for general employee financial health through additional resources, benefits and programming. This category of Personal Data is strictly available to the Users.  We do not share your financial health data with your employer other than in a highly-aggregated and de-identified format.

• • User-Generated Content, such as any content uploaded to the Services (such as text, images, audio, and video, along with the metadata associated with the information you upload or submit).

• • Communications, Support, and Related Data, such as information you provide through our online web forms, when you contact us with questions, feedback, surveys, request customer support, or otherwise choose to provide when you correspond with us online. We may also keep a record of any comments or content you submit in public areas of the Sites.

• • Audio/Video Recordings or Similar Information, such as audio recordings of telephone calls with us for quality assurance and training purposes, details about your visits to our offices (including CCTV), photographs or videos captured during meetings, events or calls with you.

• • Device Information, such as information that is automatically assigned to your devices used to access our Sites and/or Services including IP address, unique device identifier (UDID), device type, browser type, location information, and other information about your browser.

• • Usage Data, such as information (including inference based on such information) about how you use the Services and interact with us, including information you provide when you use any interactive features of the Sites or Services, the URL that referred you to our Sites, the areas within our Services that you viewed and your activities there, IP address, domain name, a date/time stamp, Internet service provider (“ISP”), operating system, language, clickstream data and similar device and usage information.

• • Social Media Information, such as name, username, email address, or other profile information in connection with your social media account, such as Facebook, Instagram, Twitter, or LinkedIn. (each, a “Social Media Site”).

• • Marketing Data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

• • Other information that you voluntarily share with us, authorize us to obtain from third parties, or otherwise where permitted by applicable law to facilitate your use of our Services, which is not specifically listed here. We will use such data in accordance with this Privacy Policy, as otherwise disclosed at the time of collection, in accordance with our agreement, or to the extent necessary for performing the services.

Is entry of Personal Data required? The entry of Personal Data is required to access certain portions of the Services.  You may choose not to provide us with any Personal Data and may still access certain portions of the Services.  However, you may not be able to fully utilize all functionalities and features of our Services if certain categories of Personal Data are required in order for us to delivery that functionalities.  For example, providing your email to sign up for our whitepaper and newsletter is voluntary, but if you choose not to provide your email, then we are not able to deliver this content to you via email.

• • Verifying Identity. We use your Personal Data to verify your identity and/or to confirm that individuals are authorized to access, use, or share information related to claims or other Services. 

• • Provide Our Services. We use your Personal Data to provide you with, maintain, and/or modify our Sites or Services, such as to verify your identity, connect a third-party account or financial institution, help you transfer money, show your account information, manage our relationship with you, confirm your account and financial information is accurate, provide customer care, respond to your inquiries and/or otherwise communicate with you. 

• • Manage Our Business Operations and Improve our Services and other Offerings. We use your Personal Data to manage, evaluate, analyze, improve, and develop our Services such as performing safety and quality controls of the Services, develop new products or offerings, improve, enhance, and facilitate your use of our Services, including research and development, offer location customization, and deliver personalized guidance to improve your financial health, including a validated personality assessment to understand your natural approach to savings habits, budgeting, setting goals, and risk appetite.  We may also use your Personal Data in connection with our regular business operations, such as maintain accounting records, analyze financial results, comply with internal audit requirements; or obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.

• • Personalized Support and Services. We use your Personal Data to personalize your experience on the Services, including suggesting and offering you relevant content and recommendations.

• • Legal Requirements. We use your Personal Data to enforce our terms and conditions or protect our business or our Customers, and to comply with our contractual and legal obligations, such as complying with national security or law enforcement requirements, discovery requests, or where otherwise required or permitted by applicable laws, court orders or regulatory authorities; or to establish, exercise, or defend legal claims, whether in court, administrative, or other proceedings, including disputing a claim or recovering a debt.

• • Marketing. We use your Contact Information for direct marketing and promotional purposes, to send you newsletters, contact you about our Services and information we think may interest you, to communicate with you about events, promotions, and campaigns, including by email, LinkedIn, and mail. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you messages if you opt-in to receive them. 

• • Security and Fraud Prevention. We use your Personal Data to protect, investigate, mitigate, and deter against fraudulent, malicious, unauthorized, infringing, or illegal activity relating to our Services, assets, or products or monitor and ensure the safety and security of our premises, property, employees and visitors.

• • Corporate Activities. We may use your Personal Data in connection with evaluating, conducting or implementing a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us is among the assets transferred.

We may use your Personal Data for other purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Privacy Policy, for which your Personal Data was provided to us.  We may also combine or aggregate any of the information we collect through our Sites and Services or elsewhere for any of these purposes or for analyzing usage statistics and trends.

When permitted by applicable law, including in cases that require your consent, we may disclose your Personal Data to our affiliates, business partners, service providers, and others, as follows:

• • Service Providers: We may share your Personal Data with service providers who perform functions on our behalf such as payment transfer providers, payment processing vendors, payroll providers, financial service providers, Human Resources Information Systems (HRIS) providers, survey providers for financial personality assessments, financial education services, customer service, information technology, cloud service, web hosting, document management providers, , and marketing and advertising, among other service relating to our products and Services, and perform billing and payment functions.

• • Business Partners: We may make Personal Data available to third parties such as customers, brokers, employers, plan sponsors, or payment processors, and others who may play a role in facilitating money transfers and other related transactions or the Services provided by us. We will obtain consent prior to disclosing such information if required by applicable law.

• • Corporate Affiliates: We may share your Personal Data with our subsidiaries or affiliates within the Finwello group, so that they may provide and improve Services, send you information about special offers or products and services that may be of interest to you based on your purchase history, activity on our website and other information that you have given us.

• • Acquisitions and Similar Transactions: If we sell, transfer or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may transfer your Personal Data as a part of the assets transferred as a result of the transaction without your consent.

• • In Response to Legal Process or Defending Legal Claims: We may disclose Personal Data as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the law and the reasonable requests of regulators, law enforcement, or other public authorities or quasi-government authorities, including fraud detection agencies. We may also disclose the information to establish, protect, or exercise our rights; to defend against a legal claim; to detect, investigate, prevent, or take action against illegal activities or potential threats to the rights, property, or safety of any other person; or as otherwise required by law.

• • Professional Advisors: We may share your Personal Data with our insurers, underwriters, actuaries, claims handlers and investigators, surveyors, loss adjustors/assessors, accident investigators, specialist risk advisors, pension providers or trustees, banks and other lenders (including premium finance providers), health professionals, health service providers, and other professional advisors, including attorneys, accountants, auditors, tax advisors, investment advisors, financial institution, and other fiduciaries and consultants that need access to your information to provide operational or other support on our behalf.

• • With Your Consent or at Your Direction: We may ask, from time to time, if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy.  We may disclose your information in this context with your permission or upon your direction.

We take reasonable steps to delete the Personal Data we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Data, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations.  We may also decide to delete your Personal Data if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Data is contrary to our legal obligations or business objectives.  When we delete your Personal Data, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.

While our security measures seek to protect the Personal Data in our possession, no security system is perfect, and no data transmission is 100% secure.  As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to or from the Services.  The safety and security of your Personal Data also depends upon you.  Where you use a password for access to restricted parts of the Sites or Services, you are responsible for keeping your password confidential.  Do not share your password with anyone.

We take reasonable steps to delete the Personal Data we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Data, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations.  We may also decide to delete your Personal Data if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Data is contrary to our legal obligations or business objectives.  When we delete your Personal Data, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.

Managing Communication Preferences. If you no longer wish to receive marketing communications from us via email, you may opt-out of certain types of communications by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at the “Contact Us” details provided at the end of this Privacy Policy and providing your name and email address so that we may identify you in the opt-out process.  Once we receive your instruction, we will promptly take action.

Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities.   We adhere to the standards set out in this Privacy Policy and do not currently respond to “Do Not Track” signals on the Services or on third-party websites or online services where we may collect information.

Accuracy and Updating Your Personal Data. If any of the Personal Data you have provided to us changes, or if you become aware of inaccurate Personal Data about you, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Privacy Policy.  For instance, if your email address changes, you may wish to let us know so that we can communicate with you.  We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Data that you provide to us.

1. First and Third-Party Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.  You can block and control cookies using the information noted below. If you block all cookies, certain functionalities on our Services may not work.

b. Other Third Party Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), HTML Local Storage, Social Widgets, or UTM Codes that can be used to collect data as users navigate through and interact with a website.

We do not control these third parties’ technologies or website or how they may use your Personal Data once you are referred to these third-party websites.  If you have any questions, you should contact the responsible party directly or consult their privacy policies.

c.  What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

Google Analytics. Where you have explicitly consented, or have not disabled third party advertising cookies (depending on your location), we may use Google Analytics to collect and process statistical data about the number of people using the Services and to better understand how they find and use the Services. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Services. Any data collected is used in accordance with this Privacy Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting:

https://policies.google.com/technologies/partner-sites and;

https://support.google.com/analytics/answer/6004245.

You can learn more about Google’s restrictions on data use by visiting the Google privacy policy at: https://policies.google.com/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).

d.  Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Services.

If you decline the use of cookies, you may not have access to the full benefits of the Services. Further, your opt-out only applies to the web browser you use, so you must opt out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again. In addition, adjusting the cookie settings on the Services may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Services.

Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers (PLEASE NOTE: these third party links are provide for your convenience, and we may not actively monitor the content of these links):

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.

Our Services may contain links to websites or mobile applications operated and maintained by third parties.  These links are to external websites and third parties that have their own privacy policies. If you follow any links that direct you away from the Sites or Services, including links to social media sites or to other websites, this Privacy Policy will not apply to your activity on the other sites you visit.  Because of the dynamic media capabilities of the Sites, it may not be clear to you which links are to the Platform and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Sites to the external third-party website.  You can check the URL to confirm that you have left this Platform.

We cannot (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control the privacy policies or the privacy practices of any third parties regarding their independent collection or use or your Personal Data, or (iii) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site.

Any Personal Data provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Privacy Policy prior to using the Services, and from time to time, so that you are aware of any changes.  Your continued use of the Sites or our Services after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your Personal Data according to the terms of the then-current Privacy Policy.  If at any point you do not agree to any portion of this Privacy Policy, then you should immediately stop using the Services and the Services.  Because this Privacy Policy contains legal obligations, we encourage you to review this Privacy Policy carefully.