Effective Date: March 17, 2020
Hereby, you agree and accept our Gramm-Leach-Bliley Privacy Notice for a summary of privacy options related to some features of the Service.
We may collect and store various information about you, including information that you provide to us, information that we automatically collect through your use of the Service, and information from publicly-available sources or third parties, as follows:
A. Information you provide us directly
The information (including the personal data) we collect from you may vary depending on the products offered by the lending partners in our network („Provider“). When creating a FINZMO account, filling in the loan request or as otherwise requested, the following information may be requested from you in the course of providing the Services to you:
B. Information That Is Collected Automatically
In addition to the information you provide to us directly, we may automatically collect information about your use of the Service, as described below.
Cookies. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser or stores information or settings on your device. Cookies let us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. Our Service may use HTTP cookies, HTML5 cookies and other types of local storage (such as browser-based or plugin-based local storage).
Clear gifs/web beacons. When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened, which links are clicked by recipients, and whether our emails are forwarded. The information allows for more accurate reporting and improvement of the Service.
Web analytics. We may use third-party Web analytics services on our Service, such as those of Google Analytics. These service providers use the technology described above to help us analyze how users use the Service. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these service providers. For example, Google may use the collected data to contextualize and personalize the ads of its own advertising network. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page: http://www.google.com/intl/en/policies/privacy/.
Third-Party Ad Targeting. We sometimes use the above technologies for interest-based advertising, which may be based on your device or browser’s signals received across websites or applications, and over time. Please see the section titled “Digital Advertising” to learn how you can opt out of these marketing methods and technologies.
We may use this information in a number of ways, including: (a) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site or the mobile application; (b) to provide custom, personalized content and information; (c) to provide our Service and monitor its effectiveness; (d) to monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in and; (g) to deliver advertising to you.
C. Information from Third-Party Sources
We may receive information about you from publicly and commercially available sources, as permitted by law which we may combine with other information we receive from or about you.
A. Processing on the basis of the performance of the agreement between us. As the main substance of our Service is to choose the Provider(s) who, based on the information about its lending principles would provide you with a loan offer, we mainly process your personal data for the purpose of connecting you with the Provider for the loan offer purposes. This includes providing you with a loan offer(s), as requested by you every time, as well as pre-filling the loan application in case of a repeated application and improving your credit profile and score, as the case may be, if you already have an a FINZMO account. This also includes providing customer support and contacting you otherwise as regards the Services. This also may include taking steps to verify on the basis of your identification number and address whether you are allowed to use our Services under our Terms of Service. For avoidance of doubt, we retain any personal data processed in using our Services. Hereby, you expressly consent to share your personal data with the Providers.
B. Processing on the basis of legitimate interest.
We process the data received from your use of our Site (e.g. information about how you move around on and use the Website) to improve the user experience in using our website and mobile application so that we can make it more intuitive. The legal basis for this is our legitimate business interest to improve our Services provided via our Site and the user experience. Taking into account the nature of the data and that we use the data in an aggregated manner, your interests or fundamental rights and freedoms do not override our legitimate interests. We also process the data received from your use of the Site and the Services (e.g. information about how you move around on and use the website) to prevent fraud and misuse of our Services (e.g. prevent robots from using the Site and the Services).
We may need to process your data to consult asset and credit solvency files to evaluate your economic solvency in accordance with the applicable regulations in the matter.
We may also process your personal data to safeguard our rights (e.g. establishing, exercising and defending legal claims, debt collection). The legal basis for this is our legitimate interest to protect our legal rights and ensure the performance of the agreement between us. In such a case, your interests or fundamental rights and freedoms do not override our legitimate interests.
C. Processing on the basis of our legal obligation. We may also process your personal data to fulfil our obligations arising from the law (e.g. when we are obligated to share personal data with the authorities). The legal basis for this is compliance with our legal obligation.
We do not process any special categories of personal data or personal data of children.
E. Automated decision-making and profiling. We may use profiling and automated decision-making in the following manner:
Since the profiling as described herein is the substance of the Service we provide our clients (including you), such profiling is necessary for the performance of the agreement concluded between us.
As a result of such profiling, we may conclude that there are no offers. Please note that in this case, you can change the terms of the desired loan (e.g. reduce the sum), which may result in us find you a loan offer. Furthermore, you always have the opportunity to turn to each of the Providers directly and request for loan with your desired conditions. Therefore, the results of our profiling cannot be regarded as significantly affecting you or your interests, including depriving you of your chances to receive a loan. You have the right to obtain human intervention, to express your point of view and to contest the decision. For that, please contact the Provider directly.
We may use third-party advertising technologies that allow for the delivery of relevant content and personalized advertising on the Site, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. This type of advertising is known as interest-based advertising.
Also, third-parties whose products or services are accessible or advertised via us may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Service as discussed above. We may also allow other third-parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Site, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access our Service. FINZMO does not sell, rent, or share the information we collect directly from you or about you from third-parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.
You may visit www.aboutads.info or the Network Advertising Initiative’s Consumer Opt-Out link to learn more about interest-based advertising and how to opt out of this advertising from companies participating in industry self-regulatory programs. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choice. We adhere to the Digital Advertising Alliance Self-Regulatory Principles.
Please note that to the extent advertising technology is integrated into the Service, you may still receive advertisements even if you opt out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
We may use your information and/or combine any or all elements of your information for a number of purposes, including:
We may share the information we collect or receive from you in a variety of circumstances, including:
The provision of FINZMO Services includes sharing your personal data and other information you have provided with the Providers in order for them to decide whether they are able to provide you with a loan offer. The purpose and legal basis for such sharing is the performance of the Agreement between us and the provision of the Services by us. The Provider will use the personal data for the sole purpose of deciding on providing you a loan offer. However, please note that after we have transferred your personal data to the Provider for the purpose of either deciding on whether they are able to provide you with their loan product, the Provider is solely responsible for the processing of your personal data. You should familiarise yourself with the privacy policies of a specific Provider.
You understand that Provider may keep your information that relates to any submission of information that you may make through your use of our Service and any other information provided by us to the Provider in the processing of any submission of information, whether or not you are eligible for the Provider’s products or services. You agree to notify any particular Provider directly if you no longer want to them to keep your information.
We may also share certain automatically-collected information, including information obtained through tools such as cookies, log files, and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with Providers as described in the section titled “Information that is collected automatically."
A. Storage and Processing
B. Keeping Your Information Safe
FINZMO cares about the security of your information, and takes reasonable technical and organization measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures vary depending on the sensitivity of the information we have collected from you. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. FINZMO is not responsible for the functionality or security measures of any third-party or Provider.
To protect your privacy and security, we take steps (such as requesting a unique password) to verify your identity before granting you access to your FINZMO Account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from FINZMO, at all times. Do not share your password with anyone and do limit your access to your computer or other devices by signing off after you have finished accessing your account.
A. Your Account Information and Settings
If you choose to set up a FINZMO Account, you may update your account information at any time by logging into your account and changing your profile settings.
B. Email Promotions
You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, and technical and security notices).
Providers may also send you email communications. If you wish to opt out of promotional email communications from Providers, you will need to contact the individual Privider. If you have any questions about reviewing or modifying your account information, you can review our frequently asked questions page available on the Site, or contact us directly at email@example.com.
Following termination or deactivation of your FINZMO Account, FINZMO may retain your profile information for an additional period of time for backup, archival, or audit purposes. In certain circumstances, we are required by Federal and State regulations to store various information. In order to comply with those requirements, we may be unable to delete your information from our database until the expiration of the applicable period.
The Site is intended for individuals who are at least 18 years of age and are accessing the internet from a physical location within the United States of America. By using or accessing the Site, you acknowledge that you are 18 years of age or older and are accessing the internet from a physical location within the United States of America.
If you believe that we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.