Effective Date: January, 2021
Information We Collect and Categories of Sources
As explained in greater detail below, we may collect identifiers, electronic network activity information, professional information, location information, and other types of information.
Information you provide to us directly. We collect the information you provide directly to us, such as the information you provide when you create a developer account, update your profile, fill out our “contact us” form, sign up for our emails, request customer support, enroll in billing, execute an end user license agreement with our end users, complete a compliance questionnaire, or otherwise communicate with us. The types of information we collect include identifiers (such as full name, email address, postal address, phone number, and taxpayer identification number), professional information (such as company name and title), and any other information you choose to provide (such as date of birth or personal information you may disclose to us in support messages).
Information we receive when you test our technology. You may provide us with information for to test and evaluate how our technology will operate with your application.
Information we collect when you use our Services. When you use our Services, we automatically collect information about you as follows:
– Log Information: We collect log files when you use our Developer Portal, which includes identifiers and electronic network activity information, such as the type of browser you use, access times, pages viewed, and your IP address.
– Approximate Location: We derive the approximate location of the device you use to access our Developer Portal from your IP address.
– Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect identifiers and electronic network activity information when you use our Services, including cookies and web beacons. Cookies are small data files stored by your web browser, on your hard drive, or in device memory that help us improve our Services and your experience, determine usage of parts and features of our Developer Portal, and monitor for and detect potential harmful conduct.
Information we collect from other sources. We also collect information about you from other sources. For example, we may collect information from third parties that help us identify new application developers, including identifiers, such as your name, email address, and social media profile URL.
How We Use Your Information
We use the information we collect for the following business and commercial purposes:
– To operate, improve, and develop our Developer Portal and the rest our Finconecta Offerings;
– To verify your identity and the identities of other members of your company;
– To bill end users and to transmit payment;
– To comply with law, such as for tax reporting purposes;
– To send you technical notices, updates, security alerts, and administrative messages;
– To respond to your comments, questions, inquiries, and customer service requests;
– To communicate with you about products, services and offers, and to provide news and other information we think may be of interest to you;
– To monitor and analyze trends, usage, and activities in connection with our Developer Portal;
– To detect and prevent fraud, malicious activity, and other illegal activities;
– To protect the rights, privacy, safety, or property of Finconecta and others; and
– For any other purpose described to you when the information was collected.
Our Lawful Bases for Processing (EEA and UK Only)
Our legal basis for processing the information we collect related to individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”) will depend on the information concerned and the context in which we collected or processed it. Generally, however, we will normally only collect and process information where:
1. we need to fulfill our responsibilities and obligations in any contract or agreement with you or with the end users that subscribe or license the use of your application;
2. to comply with our legal obligations under applicable law;
3. the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to provide or update our services); and
4. you have given your consent to do so.
How We Share Information
– With our data processors and other service providers, partners, contractors, or vendors in connection with the services they perform for us;
– If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena), including in connection with requests from law enforcement or other governmental authorities;
– If we believe your actions are inconsistent with our agreements or policies, or to protect the rights, privacy, safety, or property of Finconecta or others;
– In connection with a change in ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy); and
– With your consent or at your direction.
We also collect, use, and share aggregated, de-identified, or anonymized information for any purpose permitted under applicable law.
We do not sell or rent personal information that we collect.
International Data Transfers and Data Retention
We transfer the information we collect about you across international borders, including from the EEA or UK to the United States, for processing and storage. To the extent that the information we collect about you is transferred from the EEA to territories/countries for which the EU Commission has not made a finding that the legal framework in that territory/country provides adequate protection for individuals' rights and freedoms for their personal data, we will transfer such data consistent with applicable data protection laws, including through the use of the EU Commission-approved standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below.
If you are in the EEA or UK, we retain your personal data for no longer than necessary to achieve the purposes for which it was collected, unless a longer retention period is required under applicable law.
– Developer Account Information. You may update information you provide to us as part of your online developer account by logging into your account or by contacting us.
– Marketing Communications. You may opt out of receiving marketing emails from Finconecta by following the instructions in those emails. If you opt out and are one of our developers, subject to limitations and exceptions provided by law, we may still send you other types of emails, such as those about your account or our ongoing business relations under the terms of any specific agreement you may have executed with us.
Your Data Protection Rights
Depending on your jurisdiction, you have certain rights under applicable law regarding the personal data we process, which may include the right to request access or deletion.
In certain jurisdictions, including the EEA and UK, and subject to certain limitations and exceptions, you may have the right to: (i) know how we process your personal data; (ii) request access to or rectification of your personal data; (iii) object to, or request that we restrict, the processing of your personal data; (iv) request that we delete your personal data; (v) request that we provide the personal data you provided to us in a structured, commonly used and machine-readable format, for transmission to another controller; (vi) revoke consent at any time where our processing is based on your consent; and (vii) lodge a complaint with your local supervisory authority (if you’re in the EEA or UK, please see https://edpb.europa.eu/about-edpb/board/members_en for contact details).
If you are a resident of California, subject to limitations and exceptions provided by law, you have the right to: (i) request access to the categories and specific pieces of personal information collected about you in the last twelve months (including personal information disclosed for business purposes); (ii) request deletion of your personal information; (iii) opt-out of any sales of your personal information if a business is engaged in selling your information; and (iv) not be discriminated against for exercising these rights.
As described above in “Your Choices,” if you are one of our developers, you can conveniently access your online account information by logging into your account or by contacting us. To otherwise exercise your data protection rights, please contact us at the contact information provided below. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.
Changes to this Statement
We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on our website at https://openfinance.finconecta.com/privacy-policy/ and update the effective date at the top of this Policy.
If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at email@example.com or by mail at:
727 Crandon Boulevard,
Suite #401, Key Biscayne,