Finobi Inc. and Finobi Pty Ltd (“Finobi,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). For the purposes of this Privacy Policy “User”, “your” and “you” shall also refer clients of our customers such as Financial Advisors, or others who may use our Platform, App and services (“Customers”). 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 meetings assistant and financial modeling assistants and interactive report generator (“Services”).
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. is collected on behalf of our Customers at their direction) 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.
Finobi directly collects, processes and stores PII related to its Customers, which consists of only their first and last names, email addresses, screen names, and geolocation information, defined below (“Customer PII”). HOWEVER, PLEASE NOTE THAT FINOBI DOES NOT DIRECTLY COLLECT ANY OTHER PII, FINANCIAL INFORMATION, SENSITIVE INFORMATION OR HEALTH DATA. All of this information is processed by Finobi on behalf of its Customers at their direction, in providing Services to them such as for generating client review document, generating email to send to their clients, performing financial modeling. Customers are responsible for collecting and obtaining consent of its end users in relation to all PII which is not Customer PII.
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, on behalf of our Customers and at their direction.
c. Sensitive Information. We may collect the following sensitive personal information on behalf of our Customers and at their direction to provide you our Services: (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. Such information is collected by Finobi only if its Customers provide the information the Finobi App and Platform, and is only used by Finobi to provide its Customers its Services. Further, Finobi does not use or access any of this Sensitive Personal Information for any other purpose, other than as set forth in this Section 3.c of this Privacy Policy.
d. Health Data. On behalf of our Customers and at their direction, we may collect general health data, PHI and certain substance/stimulant consumption habits. Such data is collected when Finobi is providing its Services such as meeting recordings and transcription, or if the User enters this details on Finobi either via written or in audio form. This information is only retained for such period that is longer of (a) the time User deletes it or delete their account on Finobi, or (b) for the time required for Finobi to comply with applicable data retention and other laws. This data is used by Finobi to create workflows on Finobi, which are performed by the Customer (e.g. generating client review document, generating email to send to their clients, performing financial modeling for their clients). This information is not used or accessed by Finobi for any other purpose, other than as set forth in this Section 3.d of this Privacy Policy.
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 Customer PII 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 on our Website, App, and Platform features;
k. Process transactions;
l. Anonymize data and aggregate data for statistics and process improvement;
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 13, 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.”
You can set your browser to refuse all or some browser Cookies, but it may affect your user experience and will turn off some of the features of the Website, and the App will not work without the cookie authorizations. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies.
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. We use industry-standard encryption protocols (e.g., TLS/SSL) to protect data in transit and at rest. Sensitive personal information, if collected, is encrypted using AES-256 encryption. Access is granted on a need-to-know basis and is regularly reviewed and audited. We maintain next-generation firewalls and intrusion detection/prevention systems to protect our networks and systems from unauthorized access and cyber threats.
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. Specific retention timelines include:
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, if you gave us an email address to contact you regarding this Agreement or its terms.
g. We may only disclose personal information as described in this Privacy Policy or your consent.
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.
a. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice, and obtain your consent. If we require any personal information for internal maintenance, we will provide you with advance notice and seek your consent for the same. 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 (our “Service Providers”), so long as those parties agree to keep this information confidential. The respective terms of service for our Service Providers are listed in Section 15.
b. We do not provide non-personally identifiable visitor information for marketing purposes.
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. Inc. 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. We are fully committed to complying with the Privacy Act and the APPs as applicable to us, 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:
We will not collect any sensitive information unless required for a legal basis and only with your express consent. As such, we may process certain health data relating to your general health as part of our “record meeting" functions, and only on the direction of Customers who are responsible for collecting such information and seeking the applicable consent from its end clients.
If we collect sensitive personal information, we will implement additional safeguards, including:
We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by law. When we no longer need to retain your personal information, we will take reasonable steps to destroy or de-identify it using secure deletion methods that comply with industry standards.
You have the following rights in relation to your Personal Information:
To exercise any of these rights, or if you have any questions or concerns about this Privacy Policy or our handling of your personal information, please contact our Privacy Officer using the details provided in Section 17.
Data Breach Notification: In the event of a data breach that is likely to result in serious harm to you, we will:
We are committed to resolving any privacy-related issues promptly and fairly. We will acknowledge your inquiry within 5 business days and aim to resolve it within 30 days. If we require more time to resolve your inquiry, we will notify you and keep you informed of our progress.
If you are not satisfied with our response, you can also contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au
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:
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. include the physical address of Finobi Inc., which is 1111B S Governors Ave STE 28120 Dover, DE 19904 d. monitor third-party email marketing services for compliance, if one is used; e. honor opt-out/unsubscribe requests quickly; and f. give an “opt-out" or "unsubscribe" option.
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@finobi.app and we will promptly remove you from all future marketing correspondences.
Finobi reserves the right, at its sole discretion, to change or modify this Privacy Policy at any time. In the event we modify this Privacy Policy, such modifications shall be binding on you only upon your acceptance of the modified Privacy Policy. We will inform you about the modifications on our Privacy Policy page on our Website, App, or Platform by posting a modified version of the Privacy Policy page, or by a comparable means within a reasonable time period. Your continued use of our Website, App, or Platform shall constitute your consent to such changes.
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
| Name of Third-Party Service Provider | Contact Information |
|---|---|
| Stripe, Inc. | Email: info@stripe.com Address: 510 Townsend St, San Francisco, CA 94103 |
| 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 |
| MongoDB, Inc. | Email: https://www.mongodb.com/services/support Address: 1633 Broadway, 38th Floor, New York, NY 10019 |
| Okta Inc. | https://www.okta.com/agreements/#termsofservice Address: Suite 600, 100 First Street, 6th Floor, San Francisco, CA 94105. |
Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@finobi.app.
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.
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
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.