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Fincent Privacy Statement

This Privacy Statement describes in greater detail the privacypractices of Fincent.com, Inc.

If you have questions or complaints regarding our PrivacyStatement or practices, please contact us at support@fincent.com.

1. WHEN THIS PRIVACY STATEMENT APPLIES.

This Privacy Statement (“Statement”) applies to our sites,products, and services (collectively, “Services”) that link to this Statement. We want to be clear about whatinformation we collect, and how we use it to deliverour Services to you, operate our business, and help make our Services workbetter for you. We do not sell or share your Personal Information with thirdparties for their own commercial uses without your consent

2. WHAT WE DO WITH YOUR INFORMATION. We want to be clear aboutwhat information we collect and how we use it to deliver our Services to you,operate our business, and help make our Services work better for you. We do notsell or share your Personal Information with third parties for their owncommercial uses without your consent.

a) Types of Information We Collect. In connection with accessing our Services,we may collect information from you which can be used to identify you(“Personal Information”), such as your name, billing address, email address,phone, username, password, and financial data.

We collect information when you register or open an account,sign in, pay a bill, purchase a Service, call us for support, or give usfeedback. We may also get information from other companies or third parties,such as when you sync a third party account or service with your FincentService, or when we may use service providers to supplement the PersonalInformation you give us (e.g., validate your mailing address) to help us maintainthe accuracy of your data and provide you with better service. Finally, we alsocollect content or other information that you may provide or create when youinteract with our Services. We receive and maintain thisinformation on behalf of you in order to provide its Services, and Fincent doesnot use such information for any other purpose except as set out herein, or asdirected by you, or as otherwise required orpermitted by applicable law.

We may also automatically collect certain log file information which isautomatically reported by your browser each time the website isviewed. When you register information withFincent, its servers automatically record certain information sent by the webbrowser whenever you visit our website.These server logs may include information such as web request, InternetProtocol (IP) address, Analytical Code, Geo Stamp, browser type, browserlanguage, referring/exit pages and Universal Resource Locators (URL), platformtype, number of clicks, domain names, landing pages, pages viewed and the orderof those pages, the amount of time spent on particular page, the date and timeof the request (“Log File Information”). Such Log File Informationcollected is not associated with any Personal Information and is only tagged tothe unique identifier for a particular device usage information when youaccess our Services (“Usage Data”), such as Internet Protocol (“IP”) addresses,log files, unique device identifiers, pages viewed, browser type, any links youclick on to leave or interact with our Services, and other usage informationcollected from cookies and other tracking technologies. For example, we maycollect IP addresses to track and aggregate non-personal information, such asusing IP addresses to monitor the regions from which users navigate to ourServices. We may also collect IP addresses from users when they log into theServices as part of our log-in and security features. We may also, when youenable location-based Services, collect Global Positioning System (GPS)location data and/or motion data.

Our Services may change over time and we may introduce newfeatures that may collect new or different types of information.

b) Usage of How We Use Your Information. We may use your information, includingyour Personal Information, for the following purposes:

Account Registration. Wemay use your name, address, phone number, and email address to register youraccount for certain Services we provide and to communicate importantinformation to you. We may obtain additional Personal Information about you,such as address change information, from commercially available sources, tokeep our records current. If you set up an account that may be accessed bypeople other than you, please note that they may see and have the ability tochange or delete your Personal Information.

To Provide Our Services and OperateOur Business. We may use your information to operateour business, including providing Services you requested, provide you withsupport related to our Services, and to help us protect our Services, includingto combat fraud and protect your information.

Customer Service and Technical Support. Wemay use your name, address, phone number, email address, how you interact withour Services, and information about your computer configuration to resolvequestions you may have about our Services and to follow up with you about yourexperience. We may also offer various Internet chat services, for example, tospeak with an Fincent support representative. Internet Chat transmissions areencrypted but you should not supply more Personal Information, including taxdata, than is required to address your specific issue. A transcript of thesession may be retained to resolve questions or issues related to our Services.

Inform YouCommunicatewith You and Tell You About Other Services. Wemay use your information to send youmarketing information, recommendations and other non-transactionalcommunications (e.g., marketing newsletters) about Fincent and its affiliatesand partners, including information about its promotions or events as necessaryfor Fincent and its legitimate interestscommunicatewith you about our Services and to give you offers for third party products andservices that we think may be of use to you. Please see below under “WhatYou Can Do to Manage Your Privacy” for the choices you have regarding thesecommunications.

To Improve Services and Develop New Services. Wewill use your information to personalize or customize your experience and theService, develop new features or services, and to improve the overall qualityof Fincent’s Services.

Feedback. We may use any information you volunteerin surveys you answer for us and combine them with answers from other customersin order to better understand our Services and how we may improve them.Answering any survey is optional.

Research, Including Publishing or Sharing Combined Informationfrom Many Users, But Only in a Way that Would Not Allow You or Any Other Personto be Identified. Only in a way that would not allow you or any other person tobe identified, we may prepare and share information about our customers withthird parties, such as advertisers or partners, for research, academic,marketing and/or promotional purposes. For example, we may share demographicdata that describes the percentage of our customers who use mobile services orwho use a particular operating system. We or our third party partners maypublicly report the aggregated findings of the research or analysis, but onlyin a way that would not allow you or any other person to be identified.

c) How We Share Your Personal Information. From time to time, we may need to shareyour Personal Information with others.

Third Party Service Providers. We may share yourinformation, including Personal Information and Log FileInformationUsage Data, with third party service providerswho perform various functions to enable us to provide our Services and help usoperate our business, such as website design, sending email communications,fraud detection and prevention, customer care, or performing analytics. Ourcontracts with these third parties require them to maintain the confidentialityof the Personal Information we provide to them, only act on our behalf andunder our instructions, and not use Personal Information for purposes otherthan the product or service they’re providing to us or on our behalf.

Response to Subpoenas and Other Legal Requests. Wemay share your information if requiredto do so by law or regulation, to its legal counsel, law enforcement officers,governmental authorities who have asserted their lawful authority to obtain theinformation or where Fincent has in good faith reasonable grounds to believethat such disclosure is reasonably necessary to enforce its Terms of Servicewith courts,law enforcement agencies, or other government bodies when we have a good faithbelief we’re required or permitted to do so by law, including to meet nationalsecurity or law enforcement requirements, to protect our company, or to respondto a court order, subpoena, search warrant, or other law enforcement request.

Protection of Fincent and Others. Wemay share account information, Personal Information and Log File InformationUsage Datawhen we believe it is appropriate to enforce or apply our products’ Terms ofService and other agreements; or protect the rights, property, or safety ofFincent, our Services, our users, or others. This includes exchanginginformation with other companies and organizations for fraud protection andcredit risk reduction. This does not include selling, renting, sharing, orotherwise disclosing Personal Information of our customers for commercialpurposes in violation of the commitments set forth in this Privacy Statement.

Reporting to Credit Bureaus. We may share yourinformation with credit bureaus, consumer reporting agencies, and card associations.Late payments, missed payments, or other defaults on your account may bereflected in your credit report and consumer report. We may also share yourinformation with other companies, lawyers, credit bureaus, agents, governmentagencies, and card associations in connection with issues related to fraud,credit, or debt collection.

Sale of Our Business. In case of a merger with or transfer of business ofFincent to another business entity, Fincent will transfer your information tothe entity which acquires the business. In such cases, Fincent shall requirethat the new business entity to follow this Statement with respectto the Personal InformationIf we sell, merge, or transferany part of our business, we may be required to share your information. If so,you will be asked if you’d like to stop receiving promotional informationfollowing any change of control.

With your Consent. Other than as set out above,we will provide you with notice and the opportunity to choose when yourPersonal Information may be shared with other third parties.

d) Syncing, Linking, Connecting Your Bank Account or Other ThirdParty Services with Your Fincent Service.

You may choose to sync certain Fincent Services with informationfrom other financial accounts. To sync your financial account information, wemust access your online account with your financial institution. We willrequest your user name, password, and any other login data that you have set upwith your financial institution to enable access. We use this information toupdate and maintain the account information you download, to assist with thedownload process, and to enhance the Services we may provide in the future.

We work with other companies or developers to offer you productsand services and you may choose to sync, link or connect other third partyservices with your Fincent Service. Sometimes Fincent may let you know aboutthe service or product, or another company may let you know about a Fincentservice or product. It will be clear who is referring the service or product,and who is providing the service or product. If you choose to accept theseservices, providing your consent to either the third party or to us, we mayexchange your information, including your Personal Information, as well as informationabout how you interact with each company’s service or product. This exchange ofinformation is necessary to maintain business operations and to provide theongoing service you’ve requested. By requesting or accepting these products orservices, you are permitting us to provide your information, including yourPersonal Information, to the other party.

One company we work with is Plaid. You hereby consent to givePlaid the right, power, and authority to act on your behalf to access andtransmit to us information from your synced financial accounts. You acknowledgeand agree that such information will be treated by Plaid in accordance withPlaid’s privacy policy, which is available at: https://plaid.com/legal/#Privacy-Policy.

3. WHAT YOU CAN DO TO MANAGE YOUR PRIVACY. You can view and editinformation that identifies you online through your Fincent Service. How youcan access and control information that identifies you will depend on whichServices you use. You have a choice about the use of information thatidentifies you, marketing communications you receive from us, and our use ofcookies and other tracking technologies.

a) Updating Your Personal Information. In connection with your right to manageyour Personal Information you provide to us, you may access, update, change,correct or request deletion of your information either through the Service orthrough our customer support. You can reach our customer support by using thecontact information provided in the “How to Contact Us” section of thisstatement.

b) Managing Marketing Communications From Us. We will honor your choices when it comesto receiving marketing communications from us. Remember that even if you choosenot to receive marketing communications from us, we will continue to send youmandatory service or transactional communications.

c) Cookies and Other Tracking Technologies. The following is a high level summary ofour practices and your controls for cookies and other tracking technologies.

In accordance with applicable law, Fincent and our serviceproviders may use commonly-used tools to recognize your visit and track yourinteractions with our Services such as cookies, web beacons, pixels, localshared objects, and similar technologies (collectively, “Cookies”). Sometimesthis tracking is necessary in order for us to provide you the Service yourequested. Other times, we combine Log File InformationUsage Datacollected from Cookies with that of other customers to improve your and othercustomers’ experience. You have control over some of the Log File InformationUsage Datawe collect from Cookies and how we use it. These Cookies themselves do not personally identifyyou, but they do identify your computer. You can erase or block thisinformation by changing the settings on your computer. If you do erase or blockthis information you may not be able to utilise some features of the websiteInformationon changing your browser settings to opt out of Cookies can be found in yourbrowser settings. If you opt-out and later delete your Cookies, use a differentbrowser, or buy a new computer, you may need to renew your opt-out choices.

d) Do Not Track. Like most other companies, our Servicesare not currently configured to respond to browsers’ “Do Not Track” signalsbecause at this time no formal “Do Not Track” standard has been adopted.

e) Social Media Features. Our Services may use social media features,such as Facebook sharing (“Social Media Features”). These features may collectyour IP address and which page you are visiting within our Service, and may seta cookie to enable the feature to function properly. Social Media Features areeither hosted by a third party or hosted directly on our Services. Yourinteractions with these features are governed by the privacy statement of thecompany providing the relevant Social Media Features.

4. DATA RETENTION AND YOUR ACCESS RIGHTS

a) Data Retention. In accordance with and as permitted byapplicable law and regulations, we will retain your information as long asnecessary to serve you, to maintain your account for as long as your account isactive, or as otherwise needed to operate our business. When you close youraccount, we may continue to communicate with you about our Services, give youimportant business updates that may affect you, and let you know about productsand services that may interest you, unless you have opted out of receivingmarketing communications. We may also continue to use some of your informationfor business purposes and to improve our offerings or in some cases to developnew ones. We will retain and use your information as required by applicableregulations and Fincent’s records and information management policies to complywith our legal and reporting obligations, resolve disputes, enforce ouragreements, complete any outstanding transactions and for the detection andprevention of fraud.

b) Your Access Rights. As required by applicable law, you maycontact us to to request for a copy of, oraccess to your Personal Information held by us. You may be required to proveyour identity before providing the requested information , and you may also directFincent to rectify any inaccurate or incomplete Personal Information.confirmwhether we maintain, or process on behalf of a third party, any of yourPersonal Information and to review it in order to verify its accuracy and thelawfulness of our processing of such Personal Information. Where you havedetermined that the Personal Information we collected about you is inaccurateor processed in violation of applicable law, you may also request that yourPersonal Information be corrected, amended, or deleted. Requestsfor access to your Personal Information and to have it corrected, amended, ordeleted should be sent to support@Fincent.com.

5. SECURITY OF YOUR INFORMATION. Keeping your Information safeis important to us.

We are committed to protectthe security of any Personal Information and use reasonable efforts including avariety of security technologies and procedures to help protect such PersonalInformation from any unauthorized access, loss, use or disclosure. We will takeall reasonable measures in furtherance of the above commitment. However, wecannot guarantee that the Personal Information received and other informationstored on the servers will be absolutely protected. Fincent’s systems and thecommunications networks through which you access Services may besubject to security breaches and failures due to circumstances beyond ourreasonable control. These may include computer “hacking”, data theft or andphysical theft among others. In such situations, Fincent, in compliance withthe applicable data protection laws, will try to rectify the problems as soonas possible.We provide reasonable andappropriate security measures in connection with securing Personal Informationwe collect.

For example, we:

a) Constantly work to update our security practicesto implement accepted best methods to protect your Personal Information, andreview our security procedures carefully.

b) Comply with applicable laws and securitystandards.

c) Securely transmit your sensitive PersonalInformation.

d) Train our staff and require them to safeguardyour data.

e) Transmit, store, protect, and access allcardholder information in compliance with the Payment Card Industry’s DataSecurity Standards.

6. INTERNATIONAL DATA TRANSFERS.

In the process of providingour Services, Fincent may transfer the Personal Information and otherinformation that it collects to affiliated entities or other third partiesacross borders. If you are in the EEA, yourPersonal Information may be processed outside the EEA, in countries which maynot provide for the same level of data protection as in the EEA. In this event,Fincent will ensure that such recipient offers an adequate level of protectionby entering into standard contractual clauses for the transfer of data asapproved by the European Commission (Art. 46 GDPR), or Fincent will ask you foryour prior consent to such international data transfersInaccordance with and as permitted by applicable law and regulations, we reservethe right to transfer your information, process and store it outside yourcountry of residence to wherever we or our third party service providersoperate.

7. HOW TO CONTACT US. If you have questions or comments about thisPrivacy Statement, please contact us. We want your feedback and comments.

a) Via Email. Any grievances or questionsregarding this Statement should be directed to thefollowing e-mail address: If you have questions orcomplaints regarding our Privacy Statement or practices, please contact us byemail at support@fincent.com.

b) Via Direct Mail. Fincent Inc., 1190Miraloma Way Suite P Sunnyvale CA 94085

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8. CHANGES TO OUR PRIVACY STATEMENTS. From time to time we maychange or update our Privacy Statements. We reserve the right to make changesor updates at any time. More information about how we will notify you is below.

Any changes in this Statementby Fincent shall be posted on swww.fincent.com toreflect changes in its Statement so that you are alwaysaware of what information Fincent collects, uses, and under what circumstances,if any, Fincent may disclose itIf we make material changes tothe way we process your Personal Information, we will provide you notice viaour Service or by other communication channels, such as by email or communitypost. Please review any changes carefully. If you object to any of the changesand no longer wish to use our Services, you may close your account(s).All changes are effective immediately upon posting and your use of our Serviceafter a notice of material change or posting of an updated Privacy Statementshall constitute your consent to all changes.

9. COLLECTION AND USE OF CHILDREN’S PERSONAL INFORMATION. We do notknowingly collect information from minors.

Fincent Services are intended for and directed to adults. OurServices are not directed to minors and we do not knowingly collect PersonalInformation from minors.

10. YOUR CALIFORNIA PRIVACY RIGHTS.

We do not share your Personal Information with third parties fortheir marketing purposes without your consent.