Finlight
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Privacy Policy

Effective date: May 25, 2018


Finlight (“us”, “we”, or “our”) operates the www.finlight.com website. This page informs you of our policies and practices regarding the collection, use and disclosure of information which personally identifies you (“Personal Information”) when you use our Services. We will not use or share your information with anyone except as described in this privacy policy (the “Privacy Policy”). We use your Personal Information for providing and improving the Services. By using the Services, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

Information Collection and Use: Personal Information

We may ask you to provide us, or third parties may provide us, with certain Personal Information that can be used to contact or identify you. Personal Information may include, but is not limited to, your name, postal address, email address, and employer. We collect Personal Information for the purpose of providing the Services, identifying and communicating with you about the Services, responding to your requests/inquiries, servicing your purchase orders, improving our Services, and communicating with you about our Services, discounts, and promotions.

During the course of the Services, you may upload documents, data, numbers, assets allocations or details of your investment universe. You have to be aware that we will keep these information confidential but we may usethem on a no-name basis and aggregate them to create benchmarks, high water marks, observe asset allocations, prices, behaviour and more generally to create or gather data which are then used to offer other Services, information or data for third parties.

How long we keep your personal information

How long we keep the information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account information

We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, it will be anonymized and used to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Marketing Information

If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. Every marketing email we send will provide you with the option to opt out of receiving future emails.

Accessing and Correcting Your Personal Information

We acknowledge individuals’ rights to access their personal information. You may access, update, correct or have removed from our systems and records the Personal Information you provided to us by emailing a request to contact@finlight.com or contacting us by telephone or postal mail as further specified in the How to Contact Us clause of this Privacy Policy. To protect your privacy and security, we will also take reasonable steps to verify your identity before updating or removing your information.

Accessing and Correcting Your Personal Information

We collect information about you when you provide it to us and automatically when you use the Services.

Log Data

We collect information that your browser sends whenever you visit our website or use our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Services’ functionality. These third-party service providers have their own privacy policies addressing how they use such information. When you access the Services by or through a mobile device, we collect certain information automatically, including 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, the type of mobile Internet browser you use, and your general location information as described further below.

Location Information

We use and store information about your general location. We use this information to provide features of our Services and to improve and customize our Services.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information in order to improve our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Services and we recommend that you leave them turned on.

Do Not Track Disclosure

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.

Notwithstanding such legal and contractual obligations between us and such service providers, we remain potentially liable for any misuse of your Personal Information. We will only disclose Personal Information when we are required to do so in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Communications: Your Options

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by emailing contact@finlight.com.

Disclosure

We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:
Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Finlight is acquired by a third party, personal data held about its clients will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Finlight, our clients, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Children’s Privacy

Only persons who are age 18 or older have permission to access our Services. Our Services are not intended to be used by anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.

As further specified in this Privacy Policy, we will adhere to the following practices:

Notice

When we collect your Personal Information, we’ll give you timely and appropriate notice describing what Personal Information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it. This Privacy Policy serves as such notice, and any changes to our collection, use or disclosure of your Personal Information will be reflected in revisions to the Privacy Policy posted on our website.

Choice

As established and described in this Privacy Policy, we’ll give you choices about the ways we use and share your Personal Information, and we’ll respect the choices you make.

Accountability for Onward Transfer

If we transfer your Personal Information to another country, we may remain liable and will take appropriate measures to protect your privacy and the Personal Information we transfer.

Security

We’ll take appropriate physical, technical, and organizational measures to protect your Personal Information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.

Data Integrity and Purpose Limitation

We’ll collect only as much Personal Information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent. We’ll take appropriate steps to make sure the Personal Information in our records is accurate.

Access

If you wish to confirm the accuracy of your Personal Information or have it removed from our systems and records, you may contact us at the email address, telephone number or postal address provided in the How to Contact Us clause of this Privacy Policy.

Recourse, Enforcement and Liability

We’ll regularly review our continued adherence to these privacy obligations, and we’ll provide and maintain the independent mechanism specified in this Privacy Policy as a way to resolve complaints about our privacy practices.

Further, we acknowledge our potential liability for misuse of your Personal Information by us or our third-party service providers, as further set forth in this Privacy Policy.

Controller of your Personal Information:

Money-Peasy.com ltd 2 Mill Road Haverhill Suffolk CB9 8BD

We only process your information when we have the legal basis to do so. That is, we will only process your Personal Information when:
We need it to provide you the Services;
You give us consent for a specific purpose; or
It satisfies Finlight’s legitimate interests (which are not overridden by your data protection interests), such as for improving, marketing, and promoting the Services and protecting our legal rights;
We need to process your data to comply with our legal obligations.
Transfer of EU Users’ Personal Information Outside the EU

EU Users’ Rights to Control Personal Information

You have control over your Personal Information. Below are the rights you have and the steps you can take to exercise them. Please note that your rights may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep, and it may take time for us to investigate your request. If you believe that we are not respecting your rights with regard to your Personal Information, you may lodge a complaint with your local supervisory authority.

Right to Access

You have a right to request a copy of the Personal Information that Finlight holds. To request this information, please email us at contact@finlight.com.

Right to Rectification

If you believe that any Personal Information that Finlight holds is incorrect, you have the right to correct that information. Please email us at contact@finlight.com.

Right to Erasure, Restriction, or Objection to Processing

If you believe we do not have the right to process your information or you object to our processing for a particular purpose, or if you want us to erase your Personal Information altogether, please email us at contact@finlight.com.

Right to Withdraw Consent

If you gave us consent to process your Personal Information for a particular purpose, you have the right to withdraw that consent by emailing us at contact@finlight.com. Your withdrawal of consent does not affect the lawfulness of our processing of your Personal Information prior to the withdrawal.

Changes to This Privacy Policy

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

How to Contact Us

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Money-Peasy.com ltd 2 Mill Road Haverhill Suffolk CB9 8BD