Privacy Policy

(Effective: February 21, 2016)

1. What is this document?

This Privacy Policy governs the manner in which FinLocker, LLC, a Delaware limited liability company, together with its affiliates and subsidiaries, (“FinLocker”, “we”, “our”, or “us”), collects, uses, discloses, and protects your personal information collected or provided through our websites and devices or applications (“Sites”) and how we use personal information in connection with our services offered through the Sites (“Services”). It applies to any Sites where this Privacy Policy is referenced or linked to.

THIS IS AN IMPORTANT LEGAL AGREEMENT BETWEEN YOU AND US. BY USING OUR SITES, SERVICES, OR PROVIDING US YOUR PERSONAL INFORMATION, YOU AGREE TO THIS PRIVACY POLICY AND AGREE TO BE BOUND AND ABIDE BY OUR TERMS OF SERVICE FOUND at https://www.finlocker.com/terms-of-service/. IF YOU DO NOT AGREE WITH ANY TERM IN THIS PRIVACY POLICY, PLEASE DO NOT PROVIDE US YOUR PERSONAL INFORMATION OR USE THE SITES OR SERVICES.

2. Changes to this Privacy Policy.

We reserve the right, at our discretion, to change, modify, add or remove portions of this Privacy Policy at any time by posting such changes to this page. You understand that you must check this Privacy Policy periodically for changes, and you agree to periodically review this Privacy Policy for such changes. Changes are effective immediately upon posting. Your continued use of the Sites following the posting of changes to this Privacy Policy means you accept those changes. The date these Privacy Policies were last revised appears at the top of this Policy.

3. About Us.

We are committed to informing you of how and when we collect personal information from you and to safeguarding the personal information you give us or give us permission to get. Remember, your use of the Sites is always subject to our Terms of Service, which is a part of this Privacy Policy, and can be found at https://www.finlocker.com/terms-of-service/.

4. What Is Personal Information?

“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.

5. Your Information Abroad.

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.

6. Your Ability to Contract with Us.

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.

7. How Do We Collect Information?

We collect information from you in several different ways:

  • directly from you when you provide it to us;
  • from third parties when you have given us permission to;
  • automatically as you navigate through the Sites.

If you are browsing the Sites without registering an account or affirmatively providing personal information to us, you do so anonymously.

8. What Information Do We Collect?

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:

  • Registration information. When you register for a Service, you will be asked for basic registration information, such as an email address, password, cell phone number, and answers to security questions.
  • Identification information. You may also be asked to provide identification information to confirm your identity, including your first and last name, and phone number.
  • Third party credentials. You may also enter in certain passwords, usernames, account numbers, and other account information for third party sites and Internet services (“Third Party Sites”).
  • Information from Third Party Sites you register with us. In order to display information to you through the Service and to share with parties authorized by you, we may collect, on your behalf, your account and other personal information from Third Party Sites that you register under your account via the Service. For example, if you register your Bank of America® account with us, we will access your Bank of America® information via our Sites in order to present it to you and to share it with other parties authorized by you.
  • Information from Third Parties. In order to display information to you through the Service and to share with parties authorized by you, we may collect, on your behalf, financial and other personal information from the parties you have authorized us to share information with, and from other parties where we have your authorization to retrieve information from but do not require any form of registration action to be taken by you (e.g. Credit Bureaus, and other third party information providers).
  • Information provided by you. In order to display information to you through the Service and to share with parties authorized by you, you may upload documents and files to the Service. For example, you may upload tax return documents to allow us to provide more comprehensive services to you, and to enable us to share these documents with other parties authorized by you.
  • Contests and surveys. From time to time, you may be offered an opportunity to participate in a survey or promotion. We may collect or you may submit information in connection with one of these promotions.
  • Technical and navigational information. We collect information about your interaction with our Sites such as computer browser type, pages visited, average time spent on our Sites, IP address, unique identifier of the device, operating system version and app version.
  • Location information. If you choose to use a location-enabled Service, we may collect location information from your device. You may control or disable the sharing of location information via your device setting and/or the Sites.
  • Other information. We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. In such instances, you will be given the opportunity to provide or decline that information.

We may collect the following categories of non-personal information about you through the Sites, including, but not limited to:

  • your IP address, GPS coordinates, or other unique identifiers that are automatically assigned to your computer, mobile or other device used to access the Sites;
  • the type of browser you are using (e.g., Internet Explorer®, Firefox®, Safari®, etc.);
  • the website from which your visit originated or the operating system you are using (e.g., Chrome®, Windows XP®, Mac OS®, etc.);
  • the domain name of your Internet service provider (e.g., Charter®, AT&T®, etc.); and
  • the search terms you use on our Sites; the specific areas within our Sites that you visit; and the time of day and duration of your visits.

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.

9. How We Don’t Use the Personal Information We Collect.

We will not, without your permission, sell, publish or share your personal information.

10. How We Use the Information We Collect.

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:

  • to provide you with products and Services and respond to any inquiries you may have about the Services;
  • to contact and access Third-Party Sites you have told us we can access to get information needed by the Services;
  • to share personal information you selected with third parties you have authorized for the period of time you have indicated;
  • to share personal information with other third parties who are affiliated, transacting or working with, or otherwise providing services on behalf of one of the parties you have authorized to receive your information (for example, a mortgage lender may transfer their access to your personal information to a third party they may sell or assign your mortgage to, or to a third party they use to originate your loan or service your loan);
  • to analyze Sites usage and improve the Services provided through the Sites;
  • to alert you to software compatibility issues and to improve our web design and functionality and detect and protect against errors, fraud, or other criminal activity;
  • to deliver to you any administrative notices or alerts and communications relevant to your use of the Services;
  • to offer you other products, programs, or services that we believe may be of interest to you;
  • to perform market research, project planning, product development, troubleshooting problems, analysis of user behavior, marketing and promotions;
  • to pre-fill form fields on the Sites for your convenience;
  • to confirm your accounts are valid and verify your identity;
  • enforce our Terms of Service and as otherwise set forth in this Privacy Policy; and
  • in anticipation of and otherwise in connection with a merger, sale, of substantially all of our assets, or corporate reorganization under terms of security and confidentiality customary for such a transaction.

11. Your Personal Information Provided to and Accessed by Third Parties and Their Use.

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.

Notwithstanding anything in this Privacy Policy to the contrary, all information in possession of an Authorized Third Party or Other Third Party, and their use of such information, will not be subject to this Privacy Policy and we will not be responsible for such possession or use.

12. How We Disclose Information We Collect.

– 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:

  • to respond to subpoenas, court orders, or legal process;
  • in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites or Services;
  • to respond to claims that any posting or other content violates the rights of third parties;
  • in an emergency, to protect the health and safety of our Sites’ users or the general public; or
  • as otherwise required or allowed by any applicable law.

– If we are bought or sold. If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Sites and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.

Additionally, We may share or make available anonymous or aggregate information that cannot be used to identify you individually with:

  • third parties for their research, product offerings, marketing and promotional purposes and those third parties may publicly report the findings of their research or analysis;
  • organizations that conduct research into consumer spending and other financial habits; and
  • users of the Service for purposes of comparison of their personal financial situation relative to the broader community.

13. How We Protect Information We Collect.

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.

14. Third Party Offers & Advertisements.

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.

If you choose to use these separate products and services, provide information to the third party, or allow the third party to otherwise collect information about you, then their use of your information is subject to the applicable third party’s privacy policy and terms of service. You should review the practices of the third party before deciding to use their service or provide them with any information.

15. Data Collection.

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online promotions or analyze Sites activity. We may permit these service providers to use cookies and similar technologies to perform these services. We do not share any personal information about you with these third party service providers, and these service providers do not collect such information on our behalf. For example, we may use service providers such as Google Analytics® and Adobe’s® analytics services on parts of the Sites to determine age, gender, interest and other data to better serve our customers. If you prefer to not have your data used by these service providers, you may visit the Google Analytics opt-out page or Adobe’s analytics service page.

16. Blogs & Other Forums.

We may offer bulletin boards, blogs, chat rooms, message boards, or similar public forums (collectively referred to as “Forums”) where you can communicate with us or other users. Any information that you submit or post to these Forums or other forums could be viewed by other viewers or may otherwise be publicly available. We strongly discourage posting of personal information to these Forums or other forums. If you choose to post personal information, other viewers may use this information to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these Forums and other forums. If you would like to request removal of your information from our Forums, please contact us using the information provided at the end of this Privacy Policy. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so.

17. How We Use Technology.

– 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/.

18. Your California Privacy Rights.

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 info@finlocker.com or write FinLocker, LLC at 7801 Forsyth Boulevard, Suite 200, St. Louis, Missouri 63105.

19. Changing Your Personal Information.

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.

20. Opting Out.

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.

21. Removing Your Personal Information.

You may choose to close or request that we delete your account for a Service at any time. We will use commercially reasonable efforts to remove your information from our Sites and Services. For example, some information may be retained on a backup server or media, which is necessary to help ensure continued availability of our Service. Please note that in certain circumstances, we may not be able to completely remove your information from our systems. For example, we may retain your personal information for legitimate business purposes, for account recovery purposes, as retained in our data backup systems or cached or archived pages, if it may be necessary to provide access to data previously retrieved and/or made available to third parties as authorized by you, as transferred to or shared with other parties by the third parties authorized by you and as necessary for the third party to provide their services or product to you. Additionally, we may retain personal information to comply with law, prevent fraud or future abuse, resolve disputes, trouble shoot problems, enforce our Terms of Service, and as permitted by applicable law. All retained personally identifiable information will continue to be subject to the terms of this or any successor Privacy Policy.

22. Have Questions?

If you have questions or concerns regarding this Privacy Policy, our security practices, or our information handling practices please contact us at:

FinLocker, LLC
7801 Forsyth Boulevard, Suite 200
St. Louis, Missouri 63105
info@finlocker.com

© 2016, FinLocker, LLC or its affiliates. All product names, logos, and brands are property of their respective owners. All company, product and service names used in this website are for identification purposes only. Use of these names, logos, and brands does not imply endorsement.