Privacy Policy

Effective Date: March 17, 2020

This Privacy Policy describes how Fiizy, Inc. („FINZMO“, „we“ or „us“) processes the personal data of its users (you) in relation to their use of the application and website and the Services (as defined in the Terms of Service) offered by us. This Privacy Policy explains how we collect, use and share your personal data, and what are your rights in respect of your personal data.

Hereby, you agree and accept our Gramm-Leach-Bliley Privacy Notice for a summary of privacy options related to some features of the Service.

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service.

When you use the Site and our Service, you consent to our collection, use, disclosure, and protection of information about you as described in this Privacy Policy.

1. Collection of Your Information

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:

  • Identification data (gender, first and last name, birth date, social security number, civil status);
  • Contact data (e.g. email address, phone number, address);
  • Employment data (e.g. information about current employer, the type of employment relationship, employment history);
  • Education data (e.g. level of education);
  • Financial data (e.g. income, expenses, bank account);
  • Communications data (e.g. e-mails, messages sent to us);
  • Account log-in data (e.g. username related to your FINZMO Account).

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.

  • Log file information. Log file information is automatically reported by your browser each time you access the Service. When you use our Service, our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
  • Location information. When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, features and/or products made available via the Service.
  • Cookies and other technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, beacons, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, deliver tailored advertising, and improve the products and services we provide. You can choose to accept or decline certain cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the Services.

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:

Profiling and automated decision-making as a part of our Service. On the basis of your desired loan terms and the personal information you provide us when setting up the Account / filling out the loan request, the information we gather from the sources listed in this Privacy Policy, and your history in using our Services (e.g. whether and which Provider has provided you a loan), we draw up your profile and/or complement your credit profile and score that is assigned to your Account. We compare your profile with the conditions each Provider has set for their clients and based on the results of this comparison, we provide you with the loan offers from the Providers that are most likely to conclude a loan agreement with you on the conditions you have pre-selected. Our result is based on the information we have received from the Providers about the conditions they set for their clients, as well as our best estimation on a specific Provider based on the Provider’s prior conduct.

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.

3. Digital Advertising

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.

4. Use of Your Information

We may use your information and/or combine any or all elements of your information for a number of purposes, including:

  • To provide you with and manage the Site. We use your information to operate, maintain and provide to you the features and functionality of the Site. This may include customization and tailoring the Service features according to the information that you provide.
  • To communicate with you. We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers about the Service or other services or products which we think may be of interest to you. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails.
  • To improve the Service and advertise. We may use the information we collect to analyze and improve our Service, the Site, and to provide advertising to you.
  • To protect our rights and others. We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of FINZMO, its employees or agents, or other users and to comply with applicable law.
  • When collecting information across personal devices, and applications. Sometimes, we (or our service providers) may use the information we collect – for instance, log-in credentials, IP addresses and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computer), or work with providers that do this, in order to better tailor advertising, content, and features, and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
  • With your consent. We may otherwise use your information with your consent or at your direction.
  • To aggregate/de-identify data. We may aggregate and/or de-identify information collected through the Site. We may use de-identified and/or aggregated data for any purpose and without any restrictions, including without limitation for research and marketing purposes, and may also share such data with any third-parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
5. Sharing of your information

We may share the information we collect or receive from you in a variety of circumstances, including:

  • Providers
  • Affiliates. We may share information with our FIIZY family of companies and affiliates. These companies and affiliates may use your information in the same way we can.
  • Service providers. We may share information with third-parties that help us operate our business and provide our services, such as parties that provide us with technology, services, data or content. For example, we may share information with third-party service providers who assist in the verification of your identity. This may include (but is not limited to); credit bureaus, service providers that provide access to your existing accounts (at your request), and other parties. We also remind you that under our Terms of Service you authorize the use of your third-party Account Information to help complete your requests and submissions.
  • Marketing partners. We may also share your information with our marketing partners. For example, we may share your information with a marketing partner who maintains a link to our Site on their site and you click from its site to our Site or with a marketing partner where we maintain a link on our site and you click through to its site.
  • Other parties when required by law or as necessary to protect our users and services. FINZMO may share your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Site; and/or (c) exercise or protect the rights, property, or personal safety of FINZMO, our Users or others.
  • Business transfers. We may buy or sell/divest/transfer FINZMO (including any shares in FINZMO), or any combination of its products, services, assets and/or businesses. Your information such as user names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of FINZMO.
  • Information you post on our Site. Any information or content that you voluntarily disclose to us, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If we remove information that you posted to the Site, copies may remain viewable in cached and archived pages of the Site, or if other Users have copied or saved that information. We are not responsible for the information that you choose to submit in your User Content.
  • Aggregated or de-identified information. We may also aggregate or de-identify data and may share that data without restriction.
  • Advertising. We may also share certain information with our business partners to deliver advertisements that may be of interest to you. The FINZMO Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers directly in the event that you are communicated with in connection with the Site.
  • Otherwise with your consent or at your direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third-parties whenever you consent to or direct such sharing.

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."

6. How We Store and Protect Your Information

A. Storage and Processing

Your information collected within providing the Services to you may be stored and processed in the United States or any other country in which FINZMO or its parent, subsidiaries, affiliates or service providers maintain facilities. FINZMO may transfer information that we collect about you, including personal information, to affiliated entities, or to other third-parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. You consent to the transfer of information from the U.S. or any other country in which FINZMO or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

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.

7. Your Choices About Your Information

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 support-us@finzmo.com.

8. How Long We Keep Your User Content

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.

9. Children’s Privacy

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 support-us@finzmo.com.

We are not responsible for the practices employed by third-parties (including Lenders) and their websites, or other websites or services linked to or from the Service or to which you direct FINZMO to retrieve information, including the information or content contained therein. Please remember that when you use a link to go from our Site to a Provider’s website or another website, our Privacy Policy does not apply to any third-party websites or services. Your browsing and interaction on any third-party website or service, including Providers or those that have a link or advertisement on our website, are subject to that third-party’s own rules and policies. In addition, you agree that we are not responsible and we do not have control over any Providers or other third-parties that you authorize to access your information. If you are using a Provider or other third-party website or service and you allow such a third-party access to your information, you do so at your own risk. FINZMO is also not responsible for sites directing you to FINZMO. Our Terms of Service and Privacy Policy do not apply to those Provider or third-party sites either.

11. Complaints and How to Contact Us

To make a complaint about a privacy-related matter, or to request access or correction of your personal information, or if you have any questions about this Privacy Policy or the Service, please contact us at support-us@finzmo.com or at FIIZY Inc.,12 E 49thStreet, New York, NY 10017. We will review all complaints and determine whether the matter needs further investigation.

12. Changes to Our Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. If we make a material change to this Privacy Policy, we will notify you as required by law. Your continued use of the Service or the Site following any changes signifies your acceptance of our Privacy Policy as modified.