Privacy Policy

FinPro Holdings, LLC, a Texas limited liability company (together with its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors – collectively, “FinPro”, “Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you access or use the Company’s applications, including any content, products, functionality, and services offered therein or on or through the foregoing or through https://finproholdings.com (collectively the “FinPro Interfaces”), whether as an end user, enterprise customer, or authorized user, and our practices for collecting, using, maintaining, protecting, and disclosing such information. This policy is intended to help you understand what information we may collect, how we intend to use that information, and the legal basis for doing so. We also outline choices that you have regarding your information.

This policy applies to information we collect:

• Through any of the FinPro Interfaces.
• In email, text, or other electronic messages between you and the Company.
• Through integrations and APIs you choose to connect to the FinPro Interfaces.
• Through mobile and desktop applications published by Company that you may download from, or that compose, any of the FinPro Interfaces.
• When you interact with our applications or content on third-party platforms that link to this Privacy Policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party, including through any application or content that may link to or be accessible from or through the FinPro Interfaces.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree to the terms of this policy, you must not access or use any of the FinPro Interfaces and further agree to delete any copies or instances thereof immediately. By accessing, using, or downloading any of the FinPro Interfaces, you agree to this privacy policy and further agree to be bound by the terms incorporated herein. This policy may change from time to time (see Changes to Our Privacy Policy Section below). Your continued use of the FinPro Interfaces after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Terms not otherwise defined herein shall have the meaning ascribed to them in the Terms of Use, found on one or more of the FinPro Interfaces websites or applications and incorporated herein as if fully set forth.

The FinPro Interfaces are not directed to individuals under the age of 18. We do not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from an individual under 18 without appropriate authorization, we will take reasonable steps to delete such information. If you believe we may have collected information from an individual under 18, please contact us.

In order for you to use our FinPro Interfaces effectively, we need to collect and process certain information about you. We collect and process only the information reasonably necessary to provide the FinPro Interfaces. We collect several types of information from and about users of our FinPro Interfaces, including when you contact us. When we ask you for information to, for instance, to set up an account, we will not require anyone to disclose more information than we believe is reasonably necessary to participate in such activity. Depending on your use of FinPro Interfaces and which particular product or service you use, the information we collect and process may include:

• By which you may be personally identified, such as first and last name, postal address, email address, and telephone number (“personal information”);
• About your activity on our FinPro Interfaces, including usage details (features used, pages/screens viewed, and time spent);
• Payment information you provide to us for one-time and/or recurring services (including subscription fees or other paid service), including by and through our processing vendors and partners from time to time. Information regarding purchase history and items purchased; transaction identifiers, timestamps, and related metadata; limited billing details that may be provided to us by our payment processor (for example, billing ZIP/postal code and card brand/last four digits, if applicable); and fraud and risk signals related to payments and chargebacks;
• In some cases, a third party with which we partner may also require that you provide information for identity verification purposes. This may require that you upload an identity document such as your passport, driver’s license, or other government-issued ID, and it may require that you securely enter some or all of your Social Security Number for identity verification and anti-fraud purposes. By using a payment processor, you agree to strictly comply with such processor’s privacy policy as well. Your payment processor’s privacy policy will govern its collection and processing of payment information;
• Profile information you choose to provide;
• Your login details, in connection with the account creation and sign-in process;
• Information you submit through the FinPro Interfaces (for example, support requests, feedback, and other communications you send to us);
• In limited circumstances, information that may be considered ‘sensitive’ under applicable law (for example, account login credentials and payment/identity verification information if required by a payment processor). We do not intentionally collect highly sensitive categories such as racial or ethnic origin, political opinions, religious beliefs, or sexual orientation;
• Settings and preferences (including privacy settings);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our FinPro Interfaces (device type, operating system, app version), and usage details.

We collect this information:

• Directly from you when you provide it to us, enter it into the FinPro Interfaces, and send it to us.
• Automatically as you navigate to or through the FinPro Interfaces. Information collected automatically may include usage details, IP addresses, and information collected through cookies and potentially other tracking technologies such as web beacons.
• From service providers, enterprise customers, or third-party integrations you authorize to connect to the FinPro Interfaces.

The information we collect on or through our FinPro Interfaces may include:

• Information that you provide by filling in forms on our FinPro Interfaces. This includes information provided at the time of registering to use our FinPro Interfaces, creating or updating a profile, subscribing to our services, or requesting further services. We may also ask you for information when we interact with you, including when you use our FinPro Interfaces, or when you report a problem with our FinPro Interfaces.
• Records and copies of your correspondence (including email addresses and other contact information), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions or interactions you carry out through our FinPro Interfaces.

If you choose to connect financial accounts to the FinPro Interfaces, we may receive financial account information through third-party data aggregation providers (such as Plaid or similar providers). This information may include account identifiers, balances, transaction history, and related financial data associated with accounts you authorize to be shared.

We do not collect or store your bank login credentials directly. Authentication credentials are collected and processed by the applicable data aggregation provider in accordance with its own privacy policy and security practices.

We collect and process financial account information solely for the purpose of providing the services you request, facilitating authorized data portability, and delivering services to our enterprise customers consistent with your authorization.

We may use financial account information and related data to generate personal financial statements, projections, simulations (including retirement modeling), and related analytics designed for informational purposes only.

You may disconnect linked financial accounts at any time through your account settings, subject to any ongoing contractual or legal obligations. If you authorize an ongoing connection through a third-party aggregation provider, financial account information may be periodically refreshed until you revoke access.

If you authorize an enterprise customer (such as a financial professional) to access your information through the FinPro Interfaces, that enterprise customer may access and use your information in accordance with its own privacy practices and applicable agreements.

Financial account information is accessed only pursuant to user authorization and in accordance with the applicable data aggregation provider’s terms.

We may use a “privacy by default” approach and may favor server-side event collection over client-side tracking where feasible. Regardless of implementation, we use limited analytics and logging technologies to operate, secure, and improve the FinPro Interfaces. We may use service providers to help us do this. We do not currently engage in cross-context behavioral advertising as defined under applicable state privacy laws. If our practices change in the future, we will update this Privacy Policy and provide any required opt-out rights. Some browser settings and platform controls may limit tracking, but these controls may not work uniformly. As you navigate through and interact with our FinPro Interfaces, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our FinPro Interfaces, including traffic data, location data, logs, labels, and other communication data and the resources that you access and use on the FinPro Interfaces.
• Information about your computer and internet connection, device type, operating system, browser type, and IP address.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our FinPro Interfaces and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our FinPro Interfaces according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our FinPro Interfaces.

The technologies we use for this automatic data collection may include:

We may also use certain tracking technologies in connection with marketing or advertising efforts. Any such use will comply with applicable law, and we will provide required disclosures and opt-out mechanisms where applicable.

We may share personal information with service providers and partners who assist us in operating the FinPro Interfaces, including hosting providers, data aggregation providers, payment processors, analytics providers, and security vendors. These providers process personal information pursuant to contractual arrangements and applicable law. In certain circumstances, such providers may process personal information for their own lawful purposes consistent with their own privacy policies.

We use information that we collect about you or that you provide to us, including any personal information:

• To present our FinPro Interfaces and its contents to you.
• To analyze, improve, and optimize our services.
• To process financial transactions involving our services.
• To enforce the terms of our services, protect the rights of our users, and prevent fraud and abuse of our systems.
• To detect, prevent, and respond to fraud, chargebacks, abuse, and security incidents (including payment-related fraud).
• To provide you with notifications, information, products, or services that you request from us.
• To provide you with notices about your account, which may include expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our FinPro Interfaces or any services we offer or provide through it.
• To operate, maintain, and improve the FinPro Interfaces, including account creation, authentication, feature functionality, and system integrity.
• To process purchases and provide Paid Features.
• To conduct analytics and generate reports about our FinPro Interfaces.
• To fulfill any other purpose for which you provide it or for any other purpose with your consent.
• To provide you certain benefits as may be agreed upon from time to time.
• In any other way we may describe when you provide the information.

We may use your contact information to provide updates about the FinPro Interfaces, product announcements, service-related communications, and other information directly related to our services. You may opt out of marketing communications at any time as described below.

We may use aggregated or de-identified information derived from personal information to improve our services, develop new features, enhance analytics models, and for other lawful business purposes. Such information does not identify you personally.

We may use analytics and marketing tools as described above in compliance with applicable law.

In certain circumstances, FinPro processes personal information on behalf of enterprise customers (such as financial institutions or advisory firms) pursuant to contractual agreements. In those situations, we act as a service provider or processor and process personal information solely in accordance with the instructions of the applicable enterprise customer and our contractual obligations. In such cases, the applicable enterprise customer determines the purposes and means of processing personal information.

If you are an end user interacting with an enterprise customer that uses the FinPro Interfaces, that enterprise customer may have separate privacy practices that govern its collection and use of your information.

FinPro is not a “consumer reporting agency” as defined under the Fair Credit Reporting Act (FCRA) and does not prepare or furnish “consumer reports.”

The FinPro Interfaces are designed to facilitate consumer-authorized data sharing and related financial analysis tools. We do not determine eligibility for credit, employment, insurance, housing, or other FCRA-regulated purposes.

Enterprise customers are solely responsible for ensuring that their use of information obtained through the FinPro Interfaces complies with applicable law.

FinPro does not independently verify the accuracy, completeness, or authenticity of financial information provided or authorized by users.

We may communicate with you electronically regarding your account, the FinPro Interfaces, service updates, or changes to this Privacy Policy. You may opt out of marketing or promotional communications at any time; however, we may still send you non-promotional communications related to your account or services.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support or further our business (including hosting, security, analytics, customer support, authentication).
• To a successor in the event of a transaction involving the Company or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our FinPro Interfaces users is among the assets transferred.
• To investors or potential investors in our Company, subject to confidentiality obligations.
• Your payment processor’s privacy policy will apply to information it collects in connection with processing payments.
• To third-party integrations and API partners, when you choose to connect them and authorize data sharing.
• To fulfill the purpose for which you provide it.
• To third-parties as required by law.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use available on the FinPro Interfaces and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others, including exchanging information with other companies and organizations for fraud prevention and security purposes.
• For any other purpose disclosed by us when you provide the information.

We do not sell personal information and do not share personal information for cross-context behavioral advertising as defined under applicable law. We may share personal information with service providers and partners solely to provide the FinPro Interfaces, operate our business, comply with legal obligations, or as otherwise described in this Privacy Policy.

We provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights Section below for more information.

You can review and change your personal information by logging into the FinPro Interfaces and visiting your account profile page. You may also send us an email at the email address provided in the Contact Information below to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Please keep in mind that we will only comply with this obligation to the extent and in such frequency as required by applicable law. Before we grant you rights to access, correct, or delete personal information, we must verify your identity and, if we are unable to do so, we may restrict your rights to access, correct, or delete personal information. We agree to use commercially reasonable efforts to fulfill your request within 30 days, however, we reserve the right to extend this timeframe as necessary.

Proper access and use of information provided on the FinPro Interfaces, including User Contributions, is governed by our Terms of Use found on our FinPro Interfaces, incorporated herein as if fully set forth.

We will not discriminate against you for exercising any of your rights under any applicable privacy law, expressly including denying you goods or services, charging you different prices or rates, providing you with different levels or qualities of goods or services, or suggesting you may receive a different price or rate for goods or services.

We may deny or limit certain requests where permitted or required by applicable law, including where the request would adversely affect the rights of others, interfere with legal obligations, or prevent us from complying with regulatory requirements. If we deny your request, we will provide an explanation as required by applicable law.

This policy is drafted for individuals residing in the United States. If you live outside of the United States, you may have certain other privacy rights and we comply with applicable laws regarding such privacy. Please contact us to understand our policies specifically aligned with your rights if you are a resident outside of the United States.

If we process personal information on behalf of an enterprise customer, we may direct you to submit access, correction, or deletion requests to that enterprise customer, consistent with applicable law and our contractual obligations.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information, including but not limited to the right to access, correct, delete, obtain a portable copy, and to opt out of certain processing. These state consumer privacy laws may or may not be currently active and may or may not be applicable to our business, endeavors, programs, or our FinPro Interfaces, however, we intend to provide substantially similar rights and controls to all U.S. users where feasible and provide appropriate links to the current state laws to inform you of your potential rights. Residents of certain U.S. states may have additional privacy rights under applicable law. For more information about state-specific privacy rights and how to exercise them, please visit our State Privacy Rights page.

All persons using our FinPro Interfaces have the right to make requests regarding their information, however, the State of California requires an additional disclosure for their residents. We are committed to providing the same freedoms, protections, and rights for all individuals, regardless of state of residence, however, we are providing the following for compliance purposes:

The California Consumer Privacy Act, as amended (“CCPA”) allows California residents to make certain requests regarding their personal information, including rights to know, delete, correct, and opt out of “sale” or “sharing” for cross-context behavioral advertising, and to limit use of sensitive personal information. This section describes your CCPA rights and explains how to exercise them.

California’s Shine the Light Law: Subject to certain conditions and limitations, California residents may ask the Company to provide them with a list of certain categories of personal data collected by us that we have disclosed to third parties for direct marketing purposes during the previous calendar year prior to such request and also to identify those third parties. You may make this request once per calendar year. In order to make this request, simply contact us at the contact information provided in this Policy, affirm that you are a California resident, provide us with a California address for our response, and ensure your request complies with the rights afforded to you. Please allow us up to thirty (30) days to reply. We reserve the right not to respond to such requests submitted to us in any manner other than as provided herein or for certain other reasons, as more fully described herein.

We retain personal information only for as long as reasonably necessary to provide the FinPro Interfaces, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and protect our legal rights. Retention periods may vary depending on the nature of the information and applicable legal requirements, including contractual obligations with enterprise customers.

When personal information is no longer required, we will securely delete or de-identify it in accordance with our internal policies and applicable law.

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We implement commercially reasonable administrative, technical, and physical safeguards to ensure our service providers have protection for electronic technology systems and other necessary restrictions when accessing the FinPro Interfaces and data contained therein. We implement commercially reasonable administrative, technical, and physical safeguards to ensure our staff are trained with respect to security of personal information and logically restrict such data where appropriate. Subject to the terms and conditions set forth herein, we will delete or de-identify personal information when no longer required, in accordance with our retention practices.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our FinPro Interfaces, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our FinPro Interfaces. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the FinPro Interfaces.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes from our privacy policies as to how we treat our users’ personal information, we will notify you by email, through a notice on the FinPro Interfaces home page, or by posting an updated policy and bringing such updated policy to your attention using reasonable means and methods. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our FinPro Interfaces and this privacy policy to check for any changes.

To ask questions or comment about this privacy policy and our privacy practices, to request an export of any data we may have on you or your account, to delete your data, or to exercise any additional rights you may have, please contact us at support@finproholdings.com.