“Clients” means Merchants and Publishers.
“Merchants” means financial service businesses able to access non-public areas of our Site, connect with Publishers, and otherwise use our Services.
“Personal Information” means information about an identifiable individual, and includes information that is reasonably capable of identifying a particular individual when combined with other information. Some examples of Personal Information include names, addresses, e-mail addresses, phone numbers and online identifiers such as IP addresses.
“Process” or “Processing” means any action that a person can take with respect to Personal Information, such as collecting, using, sharing, and altering Personal Information.
“Publishers” means affiliates and marketing partners able to access non-public areas of our Site, connect with Merchants, and otherwise use our Services.
“You” means any individual who is accessing and using our Site and/or Services either on their own account or on behalf of any person.
2. Table of Contents
3. Why We Collect Personal Information
We may collect your Personal Information for the following purposes (collectively, the “Purposes”):
(a) to provide our Site and Services to you;
(b) to collect and process payments for Services;
(c) to respond to your communications with us;
(d) to contact you about updates to the Site and Services, internal marketing and promotional offers, and other service-related communications;
(e) for internal statistical and operational purposes to better understand how our Site and Services are used;
(f) to improve the security and operation of our Site and Services; and
(g) to carry out any other purpose which is disclosed to you and for which you consent, or as is otherwise permitted by applicable law.
4. What Personal Information We Collect
We may collect Personal Information through your use of the Site, the Services, and any of your communications with us in order to fulfill one or more of the Purposes. Specifically:
(a) Publishers. Information we collect from Publishers may include, without limitation: (i) first name, last name, address, email address, and password; (ii) phone number, tax number (in Canada), and Form W-9 (in United States); (iii) payment information (e.g., for PayPal, direct deposit); (iv) information on the use of the Site and Services, such as usage analytics, web logs of user activity, IP addresses, and device identification; (v) website traffic and performance information relating to promoted brands; and (vi) financial information relating to commissions earned and paid.
(b) Merchants. Information we collect from Merchants may include, without limitation: (i) first name, last name, address, email address, and password; (ii) phone number and tax number; (iii) uploaded campaign content such as files and images; (iv) information on the use of the Site and Services, such as usage analytics, web logs of user activity, IP addresses, and device identification; (v) financial information relating to commissions tracked and paid; and (vi) data on campaign success.
Other Persons. We may collect information from persons other than our Clients through directed traffic from Publishers to Merchant campaigns, and/or general visits to the Site. Such information may include, without limitation, usage analytics, web logs of user activity, IP addresses, and device identification.
5. How We Collect Personal Information
(a) Collection through Services. We may collect Personal Information from you and any devices that you may use when you:
- communicate with us;
- subscribe to our mailing lists; and
- otherwise access and use our Site and Services.
Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. Your computer provides you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the Site and/or Services if you block or disable our cookies. For more information about cookies, please see: https://www.allaboutcookies.org/.
(c) Web Analytics. We may use web analytics services (e.g., Google Analytics) in order to better understand the user experience on our Site, including:
- how you reached our Site;
- the website you came from;
- how long you stayed on our Site;
- what pages you looked at;
- how many pages you looked at;
- what buttons you clicked;
- what browser you are using; and
- what device you are using.
We may also use additional web analytics advertising features (e.g. Google Analytics Advertising) in order to offer you personalized advertising. The analytics provider may collect information about your demographics and interests in order for us to offer this personalized experience.
Any use of such analytics services by us will be governed by the terms of service of the web analytics provider and any contract between us and such provider. The analytics providers may collect your Personal Information when you access and use our Site and Services. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your device identifier, site usage information, and related information about you.
If you do not wish to participate in web analytics, you may be able to download an opt-out browser add-on. Your web browser may also allow you to set a “Do Not Track” signal when you use online services. To learn more about “Do Not Track” signals, visit http://www.allaboutdnt.com/. You may also contact us at the “Contact Us” section below regarding any questions about web analytics services that we may use.
6. Consent for Processing Personal Information
We will not process your Personal Information without your consent, unless we are permitted or required to do so by applicable law. Your consent may be express or implied, depending on the nature and sensitivity of the Personal Information. The type of consent we may rely on in processing your Personal Information will vary based on your reasonable expectations, the sensitivity of your Personal Information, and the circumstances surrounding the collection of your Personal Information. Express consent is when you willingly agree (e.g., orally, in writing, or electronic agreement) to the processing of your Personal Information for particular purposes. Implied consent is when: (a) you do not expressly give consent, but you rather volunteer Personal Information for obvious purposes that a reasonable person would consider appropriate in the circumstances; or (b) you are given notice and a reasonable opportunity to opt-out of your Personal Information being processed for specified purposes, and you do not opt-out.
7. Disclosure of Personal Information
(b) Service Providers. We may provide your Personal Information to third party service providers in order to help us fulfill the Purposes. For example, we may use third party service providers to help us process payments, analyze usage of our Services, track the effectiveness of our marketing strategies and communications, assist with the prevention, detection and investigation of potentially illegal acts and security breaches, collect and process error and crash reports, and store data. These third parties have access to Personal Information to the extent necessary to provide services to us. We take reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
(c) Corporate Transactions. We may also disclose or transfer your Personal Information to affiliates or third parties in the event of a proposed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity, subject in each case to customary confidentiality agreements.
(d) Legal Disclosure. We may disclose Personal Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This includes the disclosure of Personal Information where necessary for the establishment, exercise, or defense of legal claims, or as otherwise permitted by applicable law. Fintel will have no liability associated with any such disclosures made in good faith.
8. Retention of Personal Information
If we use Personal Information to make a decision that directly affects you, we will retain that Personal Information for at least one year, so that you have a reasonable opportunity to request access to it. In any event, we will retain your Personal Information only as long as necessary to: (a) fulfill the Purposes; (b) protect our legal rights; and (c) comply with applicable law. We will securely delete or anonymize the Personal Information once it is no longer necessary for us to hold it. We are not responsible for any liability or loss you experience as a result of any such disposal of Personal Information.
9. Security of Personal Information
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable and commercially acceptable security procedures and practices appropriate to the nature of the Personal Information we collect, use and store. We protect your Personal Information using appropriate technical and organizational measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Such measures include hashing IP addresses and further encrypting all data tracked and collected through the provision of our Services. We take steps designed to ensure that only those employees who need access to your Personal Information to fulfil their employment duties will have access to it. While we maintain a strong system of data protection, no method of transmission over the Internet is 100% secure. Therefore, we cannot guarantee its absolute security. We encourage you to also take steps to protect Personal Information by, for example, closing all web browsers after using our Site and Services.
10. Rights Relating to Personal Information
(a) General. You have certain rights relating to your Personal Information, subject to applicable law:
- Right to be Informed. To know how your Personal Information is collected, how it is used, and how it is disclosed and stored. This further includes:
(A) Right to Withdraw Consent. To withdraw your consent to the processing of your Personal Information at any time. Please be advised that withdrawing your consent to the processing of Personal Information may impact the provision of Services. For further information on this, please contact our Privacy Officer as provided in the “Contact Us” section below.
(B) Right to Make a Complaint. To make a complaint about the processing of your Personal Information.
2. Right to Access. To receive a copy of your Personal Information.
3. Right to Rectification. To request correction of your Personal Information.
(b) Exercising Your Rights. If you would like to exercise your rights listed above, please refer to our “Contact Us” section below. When doing so, please tell us which right you are exercising and provide us with contact information to direct our response.
We may verify your identity before fulfilling requests to exercise any applicable rights. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
(c) Client Websites. If you are a customer of one of our Clients, or a visitor to their website, please contact the applicable Client to request access to your Personal Information, or to otherwise correct or have such Personal Information deleted. We do not associate data that we process on behalf of our Clients with any particular individual. Any access and use of Client websites will be governed by the terms and conditions set out therein, and we disclaim any liability associated with the access to, and use of, the Client websites.
11. Third-Party Materials
Occasionally, we may include or offer third party products, services, links and/or applications through our Site and Services (collectively, the “Third-Party Materials”). These Third-Party Materials are not owned, maintained, operated or controlled by Fintel. If you engage any Third-Party Materials, such third-party’s privacy notices and practices will apply. We cannot guarantee the privacy or security of your Personal Information once you provide it to a third-party and we encourage you to evaluate the privacy and security policies of each such third-party before any such engagement or disclosure. Fintel is not responsible for the content of such Third-Party Materials and does not make any representations, warranties or guarantees regarding the content or the privacy practices of such third parties. For certainty, Fintel disclaims any liability associated with your access to, use of, download of, or reliance on, such Third-Party Materials and their content. If you decide to access, use or download any such Third-Party Materials, you do so at your sole risk.
To opt-out of receiving certain communications from us through your use of the Site and/or Services (the “Communications”), you may either contact us as provided in the “Contact Us” section below, or, if applicable, click the “Unsubscribe” link in the relevant Communication. Please note that certain Communications may be necessary for the proper functioning and use of the Site and Services, and opting out of those Communications may prevent the proper use of the Site and Services.
13. Personal Information About Other Individuals
Before providing any Personal Information on behalf of another person, you confirm that you have received all necessary authorizations to do so.
14. Children’s Privacy
We do not knowingly collect or solicit any Personal Information from children. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that data. Only persons who are age 19 or older have permission to use our Services.
16. Contact Us
Email Address: firstname.lastname@example.org
Phone Number: 604-566-8020