Privacy Policy

This Privacy Policy (the "Privacy Policy") serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use the Services. Finfuego, Inc., a Delaware corporation (together with its subsidiaries and affiliates, "Finfuego," "we," "our," or "us"), operates the finance intelligence platform and related services. "Finley" is a trade name / doing business as name under which Finfuego markets and offers certain Services, including this website at tryfinley.ai. References to Finley in our products, marketing, or URLs describe the same Services offered by Finfuego, Inc. "Site" means tryfinley.ai and other Finley-branded websites we operate. "Services" includes the Finley product, software, content, and related offerings made available on the Site and through other Finley-branded channels. Finfuego believes that the privacy of its users is paramount and strives to use Personal Information (as defined below) only in ways outlined in this Privacy Policy. The Privacy Policy is incorporated by reference into our Terms of Service, currently available at https://tryfinley.ai/terms (the "Terms of Service"). By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service, that you are a resident of the United States and that you are over 18 years of age.

PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY

For purposes of this Privacy Policy, "Personal Information" means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source.

Information you provide to us

When you use the Services or otherwise communicate with us, we collect information that you provide to us directly. For example, we collect information in the following circumstances: you (i) visit the Site; (ii) register for the Services or create an account or profile or accept the creation of an account or profile on your behalf (an "Account"); (iii) access the Services through social networking sites or third party services; (iv) subscribe to newsletters; (v) purchase a product or service on the Site; (vi) invite your friends to join the Services, "share" the Services on social networking sites or perform other similar actions; (vii) request technical support; (viii) otherwise use our online Services where Personal Information is required for such use and/or participation; and (ix) when you contact us via the Site or when you otherwise communicate with us. You can choose not to provide information that is requested of you by us; however, this may limit your ability to use or access the Services.

The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information:

Moreover, if you contact us, a record of such correspondence may be kept.

Additionally, if another user refers you to us by providing us with your e-mail address, we may send you a message. However, we will use your e-mail address only to send such other user's message unless you otherwise affirmatively provide your information to us.

Automatically collected information

Most of the data we collect in and through the Site and the Services is technical in nature and is collected and processed automatically through so-called application programming interfaces, software development kits, cookies and similar software-based technologies. Alone or in combination with other data, such automatically collected data may constitute Personal Information. The data we may collect by automated means may include, without limitation:

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Information you share on third party websites or through social media services

The Services may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services.

How we use cookies and other technologies

Some of the features on the Site and the Services require the use of "cookies" - small text files that are stored on your device's hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Site to meet the needs of our visitors.

The following sets out how we may use cookies and your options for managing cookie settings:

Required cookies

Required cookies enable you to navigate the Site and use their features, such as accessing secure areas of the Site and using the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.

Managing Settings

Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.

We and our service providers may also use "pixel tags," "web beacons," "clear GIFs," or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of users, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.

We use the information you provide to us for the following purposes: (i) to further our legitimate interests in providing the Services, including without limitation to collect and remit payment for paid features, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi) to perform tasks on behalf of and according to instructions of a third party, such as payment processors, third party-service providers or our advertising partners, (vii) to enforce our Terms of Service, (viii) to resolve any disputes between users of the Site or between such users and us, (ix) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (x) to further our legitimate interest in protecting our rights, property, or safety and the rights, property and safety of the Services, our users or the public, and (xi) to contact you to obtain feedback from you regarding the Site and the Services.

In addition to the purposes described above, we use the information collected automatically to (i) to further our legitimate interests in monitoring and analyzing the use of the Services and for the technical administration of the Site, (ii) improve the Site and the Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify that users of the Services meet the criteria required to process their requests. We and or our advertising partners may use demographic and geo-location, as well as information logged from your hardware or device, including data such as IP address, device model and ID, MAC address, operating system, application usage data, device time zone, region and language, and click ID, to ensure relevant advertising is presented within the Services.

We may disclose Personal Information you provide to us or that we collect automatically on the Site and in and through the Services with the following categories of third parties:

We frequently make content or services from other websites available to you from links located on the Site. We may present links in a format that enables us to keep track of whether these links have been followed. In addition, you may opt to link your Account to your social media account or other accounts, such as Google, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to the Site and the Services. We do not exercise control over third party services or other websites that provide information, or links from within the Site or the Services. Your interactions with these third party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer's browser, collect data or solicit Personal Information from you. Other websites and services follow different rules regarding the use or disclosure of the Personal Information that you submit, and the collection and use of such information and access of any third party websites are subject to such third party's privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.

We understand the importance of privacy and security of Personal Information to our users and have made them a priority. Finfuego uses a variety of industry-standard security technologies and procedures to help protect Personal Information collected through Finley-branded experiences (including the Site and product) from unauthorized access, use, or disclosure and trains Finfuego employees on privacy and security issues. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes, and we do not promise that Personal Information about you or private communications will be protected from unauthorized disclosure or use.

We keep your data on your behalf and for your benefit. You can correct or terminate and delete your Account information by following the instructions on the Services or by e-mail at hello@finfuego.com (including for questions about Finley or tryfinley.ai), which you may also access for further assistance and questions regarding the Privacy Policy or for a copy of your Account data. If you cancel your Account or request us to delete your information, Finfuego will limit its access to Personal Information to perform what is requested by you and will delete information accessible to Finfuego within seven business days.

For purposes of this section, the business that collects Personal Information is Finfuego, Inc., which offers the Finley-branded Services described in this Privacy Policy. California Civil Code Section 1798.83 requires certain businesses that share customer Personal Information with third parties for the third parties' direct marketing purposes to respond to requests from California customers asking about the businesses' practices related to such information-sharing. We currently do not share or disclose your Personal Information to third parties for the third parties' direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.

Furthermore, subject to certain exemptions, California residents have the following rights with respect to Personal Information we may have collected about them:

Requests to know

You have the right to request that we disclose:

You may submit a request to know by e-mail at hello@finfuego.com. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

We do not sell, and have not in the prior 12 months sold, Personal Information about California residents. Therefore, we have not included a "Do Not Sell My Personal Info" link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law. We do, however, disclose Personal Information for business purposes as described in the "Third Parties We Share Personal Information With" section above.

Requests to delete

You have the right to request that we delete any Personal Information about you that we have collected. Upon receiving a verified request to delete Personal Information, we will do so unless otherwise required or authorized by law. You may submit a request to delete Personal Information via e-mail at hello@finfuego.com.

Authorized agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

Methods for submitting consumer requests and our response to requests

You may submit a request for access and requests to delete Personal Information about you by emailing hello@finfuego.com.

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within 10 days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of Personal Information about you, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government issued ID.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

The right to non-discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above. Unless permitted by the CCPA, we will not:

Finfuego, Inc. is based in the United States. As a result, Personal Information that we collect in and through Finley-branded Services (including the Site and product) may be transferred to our U.S. offices. In addition, we may work with third party service providers in the U.S. and in other countries to support our business activities. Thus, Personal Information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the Personal Information was initially collected. In all such instances, we use, transfer, and disclose Personal Information solely for the purposes described in this Privacy Policy and in compliance with applicable laws.

We keep Personal Information related to your Account for as long as it is needed to fulfill the purposes for which it was collected, to provide our services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information about you in accordance with your request.

Our security and Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy might change as we update and expand the Services. You can tell when this Privacy Policy was last updated by reviewing the Last Updated-legend on top of this page. We will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. We also encourage you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of our policies, you may inquire regarding the same via email at hello@finfuego.com. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.

If you have any concerns or questions about this Privacy Policy, Finley, or tryfinley.ai, please contact Finfuego, Inc. at hello@finfuego.com.