(Effective: February 21, 2016)
“Personal information” is information that can both identify and be associated with a particular person. Personal information does not include information that is anonymous or aggregated. It also does not include information that cannot be associated with or be used to identify a particular person.
Information we process may be transferred to, stored, and processed in, the United States or any other country in which Finlocker or its affiliates, subsidiaries, or service providers maintain operations. By using and providing personal information to us through the Sites or Service, you agree and consent to the transfer, storage, and processing of your personal information to any such country in order to provide the Sites and Service.
Our Sites and Services are not intended for children under the age of 13 or if you are not of a legal age to form a binding contract with us. We do not knowingly collect personal information from these individuals. If you use the Sites or Services, you hereby represent and warrant that you are at least 13 years of age. In compliance with the Children’s Online Privacy Protection Act, any personal information we receive from users we believe to be under the age of 13 will be purged from our database.
We collect information from you in several different ways:
If you are browsing the Sites without registering an account or affirmatively providing personal information to us, you do so anonymously.
Our Sites has the ability to collect two types of information from and about you: (1) information that you provide that may be used to personally and specifically identify or contact you, or personal information; and (2) information that does not personally identify you, or non-personal information. In addition to the personal financial information that you may provide, we may collect the following categories of personal information about you through the Sites, including but not limited to:
We may collect the following categories of non-personal information about you through the Sites, including, but not limited to:
Non-personal information collected by us (such as patterns of utilization) is exclusively owned by us and may be used as we see fit in accordance with applicable law.
We will not, without your permission, sell, publish or share your personal information.
We use the information you enter into our Sites to produce results you ask for, like financial information gathering, reports on how you spend your money, and more. Here are some examples of how we might use your personal information:
Third parties you have authorized to receive your personal information in our possession (“Authorized Third Parties”) can receive your personal information in two ways. First, using our Services, you can select what information you want us to provide to an Authorized Third Party. Second, you can grant Authorized Third Parties direct access to your personal information we possess through options you select within the Services. You are in control of how long Authorized Third Parties have this access. An Authorized Third Party may only directly access your information we possess as long as they remain in good standing with us and as long as you have authorized them to.
All the information we provide to an Authorized Third Party or that an Authorized Third Party directly accesses from us will be in their possession and generally becomes part of their “file” or “loan file” on you. While we control the provision of and access to your personal information we possess, we do not control how an Authorized Third Party uses your personal information once in their possession. Your personal information in the possession of an Authorized Third Party, and their use of that information, will be governed by the privacy policies and other applicable policies of that Authorized Third Party.
In addition, an Authorized Third Party is typically permitted to share your personal information (such as your loan file) with other third parties, such as third parties who are affiliated, transacting or working with, or otherwise providing services on behalf of a Third Party Partner (“Other Third Parties”). Authorized Third Parties may also be permitted to share or delegate to an Other Third Party their access to your personal information we possess. An Other Third Party may only access your personal information we possess for as long as you allowed the Authorized Third Party to. As you may restrict access or terminate an Authorized Third Party’s access to your personal information we possess at any time, you may also terminate an Other Third Party’s access to your personal information we possess at any time. However, you acknowledge and agree that terminating such access to your personal information we possess before our Services or the services being provided by the Authorized Third Party or Other Third Party are complete may mean our Services or the other services may be interrupted or may not be completely provided to you.
– For the Services. In addition to disclosures of your information that may occur as part of your use described above, we may disclose your personal information to our parent, subsidiary, third parties and other related companies, including, but not limited to, our partners, vendors, consultants and professional advisors, trusted affiliates, independent contractors and business partners who will use the information only as necessary for them to perform or provide the Services and for the specific purposes for which the information was collected. For example, if we have a co-brand partner and you access the Service as brought to you by one of those partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.
Also, we may share your personal information with third party service providers (other than Authorized Third Parties and Other Third Parties) to enable them to assist in fulfilling the requests you make or the transactions you conduct via the Sites, including the operation of certain Sites functions and Services. Such third parties acting on our behalf that are given access to your personal information are contractually obligated to abide by our privacy practices and are not allowed to use the information for any other purposes.
– As legally required. We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other third parties:
Additionally, We may share or make available anonymous or aggregate information that cannot be used to identify you individually with:
We take the security of your information seriously. We use technical and administrative security measures, such as but not limited to, firewalls, encryption techniques, and authentication procedures, among others, to maintain the security of your online session, the information we store, and the information we share with others.
You should be aware that your information is transmitted across the Internet and that no method of transmission over the Internet is 100% secure. You also need to take appropriate steps to protect your information. Your information may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to or from us. Please be advised that we cannot and do not ensure, represent, guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information.
In the unfortunate event that your personal information is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
We may offer a number of separate products and services offered by third parties advertised to you on our Sites and through the Service. These third party offers may be complementary to your use of the Sites and may be personalized based on information you provide to us, we have collected about you, queries made through the Sites, or other information.
– Cookies. To help operate the Sites, enhance your experience, and collect information about online activity, we may place small data files on your computer or other device. These data files may be in the form of cookies, pixel tags, local shared objects, or other similar technologies. Cookies and similar technologies enable us to personalize our Sites and Services for you. These technologies may allow us to store and manage your preferences and settings, measure and analyze how you use our Sites and effectiveness of our communications, offer targeted products, programs and services, and help us improve our products, services, and security. Most browsers provide you with the ability to block, delete, or disable these technologies. If you choose to reject cookies or similar technologies, some Services may not be available or some functionality may be limited or unavailable. Please review your browser manufacturer’s help pages for assistance with changing your settings.
– Device IDs. When you use the mobile application or mobile versions of our Sites, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system called a Device ID. Device IDs allow app developers, advertisers, and others to uniquely identify your device for purposes of storing application preferences and other data. We may use your Device ID for security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Sites is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact you to ensure that such access has been authorized by you.
– Do Not Track notices. Without an industry or legal standard of interpreting Do Not Track Signals (“DNT”) sent to us by your browser, we do not respond to DNT signals at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
California Civil Code Section 1798.83 permits users that are residents of California to request certain information regarding our disclosures of personally identifiable information to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email us at firstname.lastname@example.org or write FinLocker, LLC at 7801 Forsyth Boulevard, Suite 200, St. Louis, Missouri 63105.
Whether or not you provide personally identifiable information is completely your own choice. You may access, review, and update much of the information you have submitted to us at any time via the Sites or Service. To the extent applicable, your personal information changes (such as your email address), or if you no longer want to receive non-account specific information from us, you may update and/or remove your personal information.
Remember, you authorize how long any party you have given access to may retrieve new and/or updated personal information, financial information, files, and documents. You may terminate a third party’s access to your information at any time. It is possible the third party may have given you a benefit for being able to access this information for a certain period of time, and terminating that access pre-maturely could cause you to lose that benefit.
We may send periodic Sites related alerts, weekly summaries, notifications, newsletters, promotions, or other information via email. You may choose to stop receiving alerts, notifications, summaries, newsletters and promotions by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in the email you receive. Please note that certain Services-related messages that we send are necessary for the proper functioning and use of the Services and you may not have the ability to opt-out of those messages.
Last Review April 9, 2018
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