Privacy Policy

The use of the website and mobile application (collectively, the “Websites”) operated by [Finch Living Inc.] (“Finch”, “we”, or “us”) and the services offered on and in connection with the Websites (the “Services”) are subject to the following privacy policy (the “Privacy Policy”).  This Privacy Policyexplains what information we collect about visitors and registered user (together referred to as “Users” or “You”) to this website and how we use and protect this information, as well as the choices you can make about the way your information is collected and used. This Privacy Policy does not cover collection or use of information by third parties or linked Websites, which Finch does not control, own or manage.

This Privacy Policy is incorporated into our Terms of Use, and therefore governs your use of the Websites. By using our Websites, you accept the terms of this Privacy Policy.

Data Collection

While you use the Websites, we may collect personal and other information from you. Some of this information is collected voluntarily when you register for the purpose of using the Services offered on the Websites.Such information includes (i) information provided during the registration process, such as personal data used to verify your identity (e.g. your name, contact information,date of birth); (ii) information provided when you upload or submit any materials to the Websites; (iii)information provided when you complete certain forms on the Websites; and (iv) information provided related to contacting us (collectively, the “Personal Information”). The Personal Information is required to open an account, to transact business, to communicate with you, verify your identity and fulfill legal and regulatory requirements.

In order to allow you to view the Websites on your mobile device may require to collect certain additional Personal Information that uniquely identifies your mobile device, including, but not limited to your mobile phone number, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, and the type of mobile Internet browsers you use. Depending on the nature of the mobile device and the network you are utilizing to access the Websites on your mobile device, additional Personal Information about you and your device may be collected as a result of network and device settings, including, but not limited to precise information about the location of your mobile device.

Additional Information is collected as well, including information relating to your visits to the Websites,and as needed from time to time to further assess your needs and preferences. By providing Finch with such information, or through your usage of the Websites, you are giving Finchpermission to use such information and store it consistent with this Privacy Policy.We may combine this data with other information we have about you and treat such combined information as Personal Information in accordance with this Privacy Policy.

Duty to Update Personal Information

By using the Websites, you agree to regularly review your Personal Information to ensure that it is correct and complete and to update any information you believe to be incorrect.

Email Communications from Finch

The receipt of emails from Finch is necessary to use the Websites and the Service. Initially, email confirmations will be required to verify your email address and in order to complete your registration process.

Emails will also be used to communicate with you regarding your continued use of the Websites, including for legal and security purposes. For example, email notifications are sent to ensure that no one is making a change to your account without your knowledge. In other cases, notifications involve changes to various legal agreements or Website policies.  Generally, you may not opt out of such service-related emails.

From time to time, we will also send user surveys, requests for user feedback regarding user experience and Websites operations or marketing offers from us or from us on behalf of our marketing partners.  The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, you may choose to opt out of such emails.

Sharing Information

We may share your Personal Information with companies that provide services to us, including outside contractors or agents who help us manage our information activities, and who may only use your personal information to the extent necessary to provide us with a specific service and not for any other purpose. Similarly, we may engage third parties to help us carry out certain internal functions such as account processing, client services or other data collection relevant to our business. Use of any Personal Information shared with such third parties will be strictly limited to the performance of the task we request from such third parties and not for any other purpose.

We may make certain information related to you publicly available generic manner, including but not limited to your interactions and activities on the Services, your user profile, your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users only in generic fashion, including as part of the “statistics” page of the Websites or in other summaries of aggregate investment data.

Any personally identifiable information you publicly post to the Websites can be read, collected, or used by other users of the Websites, and could be used to send you unsolicited messages. We are not responsible for any personally identifiable information you choose to post on the Websites or for any ramifications arising out of your posting of such information.

Finch reserves the right to disclose your personally identifiable information when we believe that such disclosure is necessary or appropriate to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, including for the purposes of detecting or limiting fraud,to protect the security or integrity of the Websites or our service, or to protect the rights, property or personal safety of Finch, its users, issuers, or others.

Furthermore, in the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Websites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Web-Related Information Collection

We may make use of a standard feature found in browser software, called a “cookie”, to assign each visitor a unique, random number. Cookies allow us to track the pages on this site visited by Users and to collect other statistical information. Using cookies helps us to deliver a more personalized service to our Users and to improve our services. We may further use cookies to monitor potential fraud and abuse of the accounts or use which is not in accordance with the Terms of Use. It is your choice whether to accept or reject cookies and you can set your browser to reject cookies altogether or to reject Finch’s cookies in particular or to delete these cookies. However, if you choose to reject cookies or delete them, it may limit some of the functionalities available or affect your experience with the services.

Through your usage of the Websites, we collect information about your computer or mobile device and your visits to the Websites, including but not limited to your IP address, geographical location, language preference, browser type, referral source, length of visit, page views through the use of log files, and any other web site usage information that we may collect when you visit the Site.  We aggregate this non-identifying information and pool it with other information relating to other visitors to the Websites, to improve the administration of the Websites and optimize its usability, and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies and other marketing activities.

In addition, we use third-party tracking services (such as Google Analytics) that use cookies to track non- personally identifiable information about visitors to our site in the aggregate (e.g. page views, frequency of access) to track the overall site performance. We further use respective web beacons to gather information to allow us to tune and improve our users’ experience with the Websites and the Services, as well as track user responsiveness to various advertising campaigns and promotional activities. As with cookies, the information these beacons collect is aggregated, anonymous “click stream” and transactional data, and is not associated with any users as individuals.

Links to Other Websites

This Privacy Policy will not apply to your activity on the other websites you visit, including any third party websites which are linked to this Websites. We do not control the privacy policies or the privacy practices of any third parties.

International Users

The Websites may be accessed by users located outside the United States, where legally permitted. If you choose to use the Websites or Service from outside the United States where the laws governing data collection and use may differ from U.S. law, please note that you are transferring your personal information outside of those regions to the United States for storage and processing, and that by providing your personal information on or through the Websitesthat you hereby consent to such transfer.

Children’s Privacy

Finch does not intend the Websites and Services to be used by individuals under the age of majority within the jurisdiction within which they reside without the supervision of a parent or guardian of majority age. Finch relies upon such parents or guardians to determine if the Websites and Services are appropriate for the viewing, access, or participation by such individuals under the age of majority. If an individual under the age of majority uses the Websites and Services, such individual may only use the Websites and Services under the supervision of a parent or guardian of majority age.

We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a minor child who has provided us with personal information, you may contact us using the information below to request it be deleted.

Security Policy

Before entering certain portions of the site, Users may be required to authenticate their identity. We follow generally accepted industry standards as we deem fit to protect the personal information submitted to us, both during transmission and while maintaining this information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot and do not guarantee the information’s absolute security.

In the event that the Websites undergoes a security systems breach, we may attempt to notify you electronically through the contact information you provide so that you can take appropriate steps to protect yourself from future harm.  Additionally,we may also post a notice on or through the Websites in such an event.

While it is difficult to guarantee that your personal information is secure, there are steps to take which can minimize such risk. For instance, passwords containing uppercase and lowercase letters, as well as numbers and symbols are viewed as harder to be “hacked”. Similarly, the risk to your computer from external attacks by malicious users can be reduced through usage of an active firewall. As a further means of protection, please logout anytime you are finished with a session.

You should also be aware of fraudulent attempts to gain access to your account information, such as “phishing.”Phishing refers to an email that attempts to fraudulently acquire personal information from you, such as your username, password and/or financial information. These emails appear to be from legitimate companies or individuals, but are not.Finchwill never send you an email asking for your password or login information.  In general, you can protect yourself against phishing by providing personal or login information only on the Websites from which the email is purportedly sent.

Contact

If you have any questions regarding this Privacy Policy, or otherwise wish to contact Finch, please contact us at hello@finchliving.com