Finobi Inc. (“Finobi,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Finobi Platform (the “Platform”) through Finobi’s website at https://finobi.app/ (the “Website”) or Finobi’s mobile application (the “App”).
Finobi is a company that has developed proprietary software and AI products and solutions in the financial services domain focused on Financial Advisory and Wealth Management, and provides services such client meeting and financial modeling assistants and interactive report generator.
Finobi is committed to protecting the privacy of its Users whose information is collected and stored while using Finobi’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.
The capitalized terms have the same meaning as ascribed in our Terms of Use or Terms of Service as applicable, unless otherwise noted here.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM.
IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@FINOBI.APP.
WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO.
Our Website, App, and Platform are only available for use and download outside the European Union. Our Website, App, and Platform are not available for use or download by residents of, visitors to, or your employees who reside in the European Union (collectively a “European”). If you are a European, please do not download, register, and/or use our Website, App, or Platform. If you are a resident of the United States (“US”), the laws of the State of Delaware, United States shall apply. If you are a resident of any other country, please ensure compliance with all local laws prior to using our Website, App, or Platform. You must comply with this Privacy Policy and our Terms of Use and Terms of Service, as applicable.
If you have any questions regarding this Section, please email us at privacy@finobi.app.
When you register to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact information such as your email address or username with the password, phone number, education information (degrees, majors, schools, etc., Professional or employment-related information (medical associations, bar associations, engineering societies, employer, business title, business address, etc.)and other personal information. The information so collected will be stored on our servers. You are able to change your personal information via email by contacting us at privacy@finobi.app or through your profile or account settings on our Website, App, or Platform.
a. Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details.
b. Financial Information. We currently do not collect or store any credit cards or bank information, as we are using a third-party payment processor. However, we collect (a) Credit Card History and (b) Credit Rating and (3) Financial Reports.
c. Sensitive Information. We may indirectly collect the following sensitive personal information on behalf of Financial Advisors to provide your our Services. We do not have access to or request such data: (a) Social Security Number, (b) Passport Number, (c) Driver’s license or ID card number,(d) A photograph, video or audio file containing an image or voice, and (e) Personal Medical and/or Health information (“PHI”) subject to HIPAA Rules.
d. Health Data.
We collect personal information from you in the following ways:
a. At registration on our Website, App, or Platform;
b. In email, text, and other electronic messages between you and our Website, App, or Platform; c. From third-party applications that are integrated with our Website, App or Platform to provide, you our Services.
We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:
a. Usage details;
b. IP addresses;
c. Information obtained through browser cookies;
We use the information that you provide to:
a. Personalize your experience in using our App or Platform;
b. Provide you with information, products, or services requested from us;
c. Present our Website, App, and Platform and their contents to you;
d. Provide you with notices about account and/or subscription, including expiration and renewal notices;
e. Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;
f. Notify you about changes to our Website, App, and Platform and any products or services;
g. Allow you to participate in interactive features on our Website, App, and Platform;
h. Improve the Website, App, and Platform;
i. Improve our customer service;
j. Administer contests, promotions, and surveys or other Website, App, and Platform features;
k. Process transactions;
l. Anonymize data and aggregate data for statistics;
m. Contact you for other purposes with your consent;
n. Contact you about our products and services that may be of interest; and
o. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 14, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.
p. Use of AI for Enhanced Service Delivery: Finobi leverages advanced artificial intelligence and machine learning algorithms to analyze data collected through its Services. These insights are used to:
· Enhance predictive analytics for our AI agents and performance optimization.
· Personalize user experiences by tailoring services and amenities to user preferences.
· All AI training processes are conducted using de-identified data to ensure user privacy. Furthermore, anonymized data is aggregated to develop predictive models that improve operational efficiencies across properties without compromising individual privacy.
Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”
We allow third party behavioral tracking to improve user experience and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform. 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 Website, App, or Platform and welcome any feedback at about these sites. Please contact us at privacy@finobi.app.
Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security
measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third party credit card processor on our behalf. We will implement reasonable security measures every time you (a) enter, submit, or access your information, (b) register, or (c) access our Platform, on our Website and App.
User Account Information: Retained until account deletion or termination of service, subject to a 12-month archival period for compliance purposes.
Device Logs and Usage Data: Stored for a rolling period of 12 months, after which it is anonymized and archived. However, we may retain these details for a longer period if deemed necessary for operational, legal, or compliance purposes.
Financial and Transactional Data: Retained for seven years as required by financial regulations. Users may request the deletion of their personal data at any time by contacting privacy@finobi.app. Requests will be honored within 30 days, except where retention is mandated by law.
Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.
Fair Information Practice Principles. In the event of a personal data breach, we will notify you within fifteen (15) days via (i) email and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally 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 that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
There are times when we may share Personal Information that you have shared with us may be shared by Finobi with others to enable us to provide you over Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Finobi may share such information with
Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:
Disclosure of Personal Information.
a. We may disclose personal information to our subsidiaries and affiliates.
b. We may disclose personal information to contractors, services providers, and other third parties.
c. We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
d. We may disclose personal information in the event of a merger, sale of business, etc.
e. We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
f. We disclose personal information to fulfill the purpose for which you have provided it, for instance,
g. We may only disclose personal information as described in this Privacy Policy or your consent.
Other Disclosure of Personal Information.
a. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use or Terms of Service and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Finobi, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Finobi, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
b. We may share limited personal data with trusted vendors and partners for operational purposes, such as for password management, operational functions (billing, collection), meeting recording and calendar integrations. Vendors must demonstrate compliance with privacy standards and agree to confidentiality terms before receiving data access.
Third Party Disclosure.
a. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
b. We do not provide non-personally identifiable visitor information for marketing purposes.
Choices Users Have About How Finobi Uses and Discloses Information.
a. Tracking Technologies and Advertising. You can set their browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or function properly.
Finobi does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request
certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to privacy@finobi.app or write us at Finobi, 1111B S Governors Ave STE 28120 Dover, DE 19904
Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at privacy@finobi.app or write us at Finobi, 1111B S Governors Ave STE 28120 Dover, DE 19904.
This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website or Platform, who reside in Australia (“consumers” or “you”).
The Australian privacy framework is governed by the federal Privacy Act 1988 (“Privacy Act”) and the Australian Privacy Principles (“APPs”) and certain State and territorial regulations. The Privacy Act and APPs apply to government agencies and certain private sector businesses. As defined under the Privacy Act, Finobi is a small business operators i.e. with an annual turnover of less than AU$3 million and is exempt from the operation of the Privacy Act and APPs. This Privacy Policy is updated from time to time and we will ensure compliance with the Privacy Act and the APPs as required in the future and any terms defined in the Privacy Act have the same meaning when used in this Section.
WE DO NOT SIGN UP CONSUMERS TO RECEIVE OUR SERVICES WITHOUT OBTAINING THE CONSENT FORM.
a) Definition of Personal Information: "Personal information," is defined as “information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(i) whether the information or opinion is true or not; and
(ii) whether the information or opinion is recorded in a material form or not.
"Sensitive information" is a subset of personal information and is defined as: Information or an opinion (that is also personal information) about an individual's:
· Racial or ethnic origin
· Political opinions
· Membership of a political association
· Religious beliefs or affiliations
· Philosophical beliefs
· Membership of a professional or trade association
· Membership of a trade union
· Sexual orientation or practices, or
· Criminal record
· Health information about an individual
· Genetic information (that is not otherwise health information)
· Biometric information that is to be used for the purpose of automated biometric verification or biometric identification
We do not collect any sensitive information and shall not do so unless required for a legal basis and only with your consent.
b) Rights of Data Subjects: Data Subjects have the following privacy rights in relation to their personal information:
(i) right to access the data subject's own personal data
(ii) right to rectify/correct the data subject's own personal data where inaccurate or incomplete
(iii) right to withdraw consent
The Children's Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@finobi.app.
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.
Should we inadvertently receive data belonging to a minor:
Immediate deletion of the data will occur upon detection.
Parents or legal guardians will be notified (if identifiable) and offered assistance in managing the data removal process.
To report potential data collection involving minors, contact privacy@finobi.app
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
a. not use false or misleading subjects or email addresses;
b. identify the email message as an advertisement in some reasonable way;
c. monitor third-party email marketing services for compliance, if one is used;
d. honor opt-out/unsubscribe requests quickly; and
e. give an “opt-out” or “unsubscribe” option.
We will post any changes to this Privacy Policy in a notice of the change at the bottom of our web page with a hyperlink thereto. We will also send you an email describing such changes. Please regularly review this Privacy Policy. Notwithstanding if you continue to use our services, you are bound by any changes that we make to this Privacy Policy.
Finobi uses the following third-party service providers for the provision of services as detailed under the Terms of Use or Terms of Service, as applicable
| Service Provider | Contact Information |
|---|---|
| Google Cloud | Website: www.support@google.com Telephone: (855) 817-0841 |
| Microsoft Azure | Website: https://support.microsoft.com/en-us/contactus/ Address: 1 Microsoft Way, Redmond, WA 98052-6399 |
Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@finobi.app
If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
a. Your physical or electronic signature;
b. Identification of the copyrighted work(s) that you claim to have been infringed;
c. Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove;
d. Sufficient information to permit us to locate such material;
e. Your address, telephone number, and email address;
f. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
g. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining
party to liability for any damages, costs and attorney's fees incurred by Finobi in connection with the written notification and allegation of copyright infringement
Finobi represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws. Company represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an "Official"). Company further represents and warrants that, to its knowledge, neither it nor any of the Supplier Personnel has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving Finobi, or (B) the obtaining or retention of business by Finobi. Supplier further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Supplier Personnel.
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
Privacy Officer
Email: privacy@finobi.app
Address: Finobi, Inc. 1111B S Governors Ave STE 28120 Dover, DE 19904
PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE OR OUR TERMS OF SERVICE, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, APP, OR PLATFORM.