Fintel Ventures- Privacy Policy

Fintel Ventures, LLC Privacy Policy

Last updated on February 2, 2022

This Fintel, LLC Privacy Policy (the “Privacy Policy”) describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. We refer to Fintel, LLC collectively as “Fintel”, “we” or "us”. Together with our Terms and Conditions, this Privacy Policy governs your use of our platform and services.

Fintel is committed to the protection of our Visitors, Users, and Premium Subscribers (also referred to as “you” or “your”) privacy. We understand that keeping your information secure and confidential is critical to earning and keeping your trust. Fintel does not rent, sell or trade your Personal Information.

How to Use this Privacy Policy

This Privacy Policy describes how we collect and use your Personal Information and how we address other privacy matters & such as deletion of your Personal Information upon request and opting-out of marketing communications. We also describe how to contact Fintel.

The information that we collect, and how we use it, depends on your relationship with us and as your relationship evolves with us. This Privacy Policy is organized based on those different types of relationships – Visitors, Users, and Premium Subscribers.

  • Visitors - Individuals who visit our public website without logging into an account or using our services
  • Users - Individuals who establish a free account with us or otherwise use our services offerings, including our dashboard
  • Premium Subscribers - Individuals who are paid subscribers to Fintel

You may fall into more than one category concurrently depending on your relationship with us. For example, a User may also be a Visitor before they log into their Fintel dashboard.

How We Collect & Use Your Information

“Personal Information" means your personally-identifiable information such as your name, email or mailing address, phone number, account credentials (User id and passwords), credit card account data, and other information that can be used to identify you personally.

We also collect and use other information that we obtain from your activities using our services. This includes information that you do not explicitly provide to us, but which may be implicitly provided to us as part of such activities. More information on this is provided below under the Visitors use case.

Your personal information is contained behind secured networks and is only accessible by a limited number of Fintel representatives who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a User or Premium Subscriber enters, submits, or accesses their information to maintain the safety of personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

The following describes in further detail the information we collect at various stages of our relationship with you.

Visitors

When you visit our website, we consider you a Visitor. For Visitors we collect cookie information about your visit (both Fintel and Third-Party cookies) as well as basic information about your IP address and browser metadata. We collect this information to create a better experience for return visits, to run our advertising programs for Visitors, and to understand our engagement from Visitors, Users and Premium Subscribers.

Users & Premium Subscribers

When you register, create a User Account on our Dashboard and begin using our services, we consider you a User. Users are also considered Visitors, so this section describes information that we collect in addition to what was described for Visitors.

For Users we collect your email, first and last name, username, password and phone number. This data allows you to login to Fintel and enables us to communicate with you by email and by text (sms). Fintel does not call Users or Premium Subscribers (except as requested during a support incident) but may use phone numbers for text alerts where the User or Premium Subscriber has requested to receive Fintel Alerts by text/sms. For Premium Subscribers we collect credit card information as well.

Fintel also offers an optional third party financial account linking service to both Users & Premium Subscribers, currently managed via Plaid (www.plaid.com. When a User or Premium Subscriber connects their accounts to Fintel via Plaid, Fintel is able to obtain information about brokerage account transactions, balances, assets held, and other account information. It is important to note that Fintel does not have any access to User and Premium Subscriber account credentials at the third party financial institutions connected via Plaid. Usage of third party financial account information is used by Fintel to offer value-added services to Users and Premium Subscribers including, but not limited to, automatically updating your Fintel dashboard to reflect the securities held in your linked accounts. Fintel also uses holdings information to generate anonymized retail holding analytics which can be viewed by Users and Premium Subscribers (as long as they have connected to their brokerage account), providing insight into trends in security ownership by Users and Premium Subscribers of Fintel.

What Information Do We Share and Why?

Fintel’s core business is security analysis. Fintel does not rent, sell or trade your Personal Information. We do share some information with third parties as needed to maintain our technology platform and run our business.

Personal Information

We may share necessary personal information with our service providers to deliver some of our services. For example, we may deliver email and text alerts via a third party and to do so we share email addresses and phone numbers. Our contracts with those third parties prohibit them from using your data for any purpose other than to provide services to you.

Fintel also reserves the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the services we provide and any facilities or equipment used to make those services available, (v) comply with any law or regulatory requirement, including pursuant to a subpoena, court order or other legal process, or (vi) protect our property or other legal rights.

Anonymized Information

We will share anonymized aggregated information that is summarized or derived from information that you provide to us as explained below. Anonymized aggregated information is information that does not include any personally identifiable information.

Anonymized aggregated information about security positions and transactions (provided via the optional third-party financial account linking service) will be used by Fintel to provide analytics to Users and Premium Subscribers who connect financial institution accounts to Fintel via Plaid. Users and Premium Subscribers who choose not to connect any third-party financial accounts will not be able to view these analytics as access to this data is limited to Users and Premium Subscribers participating in this program.

Fintel also publishes research from time to time and anonymized aggregated data regarding security positions and transactions may be included in research publications or in discussions with the media.

Additional Privacy Information and Your Privacy Rights and Resources

Third-Party Links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google Analytics

We use Google Analytics to help us understand how you interact with our website and mobile app, market our products and services to you, and to improve the User experience. To do this, we share a unique identifier with Google. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see “How Google uses data when you use our partners’ sites or apps” linked here. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On, here.

Google AdSense

Fintel serves advertisements to Visitors on its free website using Google AdSense. Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy. We have implemented the following:

  • Remarketing with Google AdSense
  • Google Display Network Impression Reporting
  • Demographics and Interests Reporting
  • DoubleClick Platform Integration

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Opting out: Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

Other Use of Tags, Pixels, Cookies and Other Trackers

In addition to Google Analytics and Google AdSense, we also use other tags, pixels and cookies, which are bits of code that gather information that helps us operate and measure engagement with our site. Some cookies help us measure user experience, or identify errors or other technical issues on our site. Other cookies help us track the effectiveness of advertising and other marketing programs. The cookies use a unique identifier that does not contain any personally identifiable information.

To implement the features described above, Fintel contracts with trusted service providers to place tags, web beacons, cookies, and similar technologies on the Fintel site and applications, which collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. These service providers are prohibited from using any Personal Information they collect on our behalf for any purpose other than providing services to Fintel. Some of our service providers are members of the Network Advertising Initiative, an AdTech self-regulatory organization. You may learn more about the Network Advertising Initiative and the opt-out of interest-based advertising that they offer by visiting http://www.networkadvertising.org/managing/opt_out.asp and following the opt-out instructions therein.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify you via email within 7 business days. We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

How to Request Deletion of the Personal Information We Collect

Fintel allows you to delete your account. When you delete your account we delete your personal information (except for it’s inclusion with respect to aggregated anonymized historical information). Any connection to third-party accounts will be removed as well, which will lead to no further updates from third-party financial accounts. We will retain anonymized data on past positions and transactions in anonymized aggregated analytics based on past refreshes, and Fintel will retain information on deleted accounts as required for legal, regulatory and security purposes.

Email Records

Fintel keeps business records, including emails you send to us, for five (5) years to meet our regulatory compliance requirements. This includes any email you send to our support teams.

Data Residency

Our services and data are hosted in the United States and are intended for individuals located in any geography.

US State Residents Privacy Notices

To exercise any of your rights described below, please create a support ticket for us at https://fintelio.atlassian.net/servicedesk/customer/portals.

Vermont Residents

Under Vermont law, we will not share any Personal Information we collect about Vermont residents with third parties, unless the law allows.

California Residents

Residents of California have the right to request a disclosure describing what types of Personal Information (if any) we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year.

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”) provides a number of rights to California consumers. For a full description of your rights under the CCPA, please see our CCPA notice at the end of this Privacy Policy.

Protecting Children’s Privacy Online

Fintel is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our websites or applications. We do not knowingly collect information from children under 13 without parental consent. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website.

Modifications to our Privacy Policy

We change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy Policy, and will post the revised document on our website with the effective date.

When changes to this Privacy Policy are material, we will provide email notice to Users and Premium Subscribers

California Consumer Privacy Act (“CCPA”) Disclosures

Who does the CCPA apply to?

The CCPA provides certain rights to California residents.

What rights do I have under the CCPA?

Broadly speaking, the CCPA grants California residents the following rights:

  • a right to request that a business disclose the personal information that the business collects, uses, discloses and sells;
  • a right to request that a business delete the personal information that the business has collected from them;
  • a right to opt out of having their personal information sold by a business; and
  • a right not to receive discriminatory treatment by a business for exercising their rights under the CCPA.
What personal information does Fintel collect about California consumers?

We describe below the categories of personal information that Fintel has collected over the past 12 months, as well as the categories of sources from which the information was collected, the business purpose for which the information is collected, and the types of third parties with whom Fintel shares personal information.

Please note that we also disclose the types of information we collect earlier in our Privacy Policy. However, the CCPA requires that we provide this information with reference to certain categories described in the CCPA, so we are restating the information here.

  • Identifiers: We collect your name, email address, IP address, and other similar identifers. We use this to support return visits to Fintel as well as to receive communications from Fintel.
  • Personal information: We collect your name, email address, telephone number, credit card information (for Premium Subscribers). We use this data in a similar fashion as Identifiers, and use credit card information for billing purposes for Premium Subscribers.
  • Internet or other electronic network activity: We collect search and browsing history activity on Fintel, as well as geolocation information information. This data allows us to improve Fintel services and understand where our services are being used by Users.

Note that Fintel does not collect any information with respect to age, sex, ethnicity, education, biometrics, commercial information on products purchased, employment-related information, or create any inferences on consumer profiles.

Categories of Sources of Information

Most of the personal information that we have is provided by you either (a) through our website, including information you enter into our web site as well as information provided by your web browser or device, or (b) when communicating with a Fintel customer service agent via email or live chat.

We receive information from service providers, such as financial account aggregators, who help us provide services to you.

In some instances, we purchase information from third parties, such as direct mail collection agencies and affiliate marketing vendors. For example, we may purchase addresses for direct mail campaigns and sales leads from referral partners.

Business or Commercial Purpose for Collecting the Personal Information

We collect personal information for one or more of the following business or commercial purposes:

  • Site customization to enhance Visitors usage of our website
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information.
  • Creating anonymized aggregated analytics (on an opt-in basis) to enhance the data available to Users and Premium Subscribers and for marketing purposes
Categories of Third Parties with Whom We Share Personal Information

We share the information described above with service providers to the extent necessary to provide the services you have requested and for the business purposes described above. Fintel will also share anonymized aggregated analytics on an ad-hoc basis with media for marketing purposes.

How Can I Exercise My Right to Opt Out of the Sale of My Personal Information?

Fintel does not sell any consumers’ personal information and has not sold consumers’ information in the past 12 months.

How Can I Exercise My Rights Under the CCPA?

Create a support ticket at https://fintelio.atlassian.net/servicedesk/customer/portals, select “Other Questions”

We will authenticate your request by matching the information you provide against any information that we have collected about you. However, in some cases, we may not have collected sufficient information about you to authenticate your request. In certain circumstances, if we believe it is necessary to authenticate your request and protect the security of your information, we may require additional information.

How Can I Designate an Authorized Agent to Exercise My Rights Under the CCPA?

You may use an authorized agent to submit a request on your behalf. To do so, the authorized agent should create a support ticket using the link above and must provide a copy of your signed authorization. You will also be required to verify your identity directly with us and confirm that you have provided the authorized agent with your permission to submit a request on your behalf.

Contact Information

If you have any questions about your rights under the CCPA, please contact Fintel by creating a support ticket via https://fintelio.atlassian.net/servicedesk/customer/portals.