“Primary Account” means the Primary Accountholder’s Virtual Card Account.
“Primary Accountholder” means the individual that opens and is responsible for the Card(s), Primary Account and Sub-Account(s).
“Sub-Account” means a Virtual Card Account that is a sub-account of the Primary Account, established by the Primary Accountholder and utilized for the purpose of identifying, monitoring and approving Card transactions by a Sub-Accountholder.
“Sub-Accountholder” means any individual authorized by the Primary Accountholder to use a Sub-Account.
“Virtual Card Account” means the records the Bank maintains to account for the value of claims associated with each Card.
What information about me is collected?
Is information submitted to the public areas of the Service private?
Does Finnest collect information from children under 13 years of age?
What does Finnest do with the information it collects?
When does Finnest disclose information to third parties?
Is the information collected through the Service secure?
Could my information be transferred to other countries?
What choices do I have regarding the collection, disclosure and distribution of personally identifiable information?
Can I update or correct my personally identifiable information?
Who do I contact if I have any privacy questions?
WHAT INFORMATION ABOUT ME IS COLLECTED?
Depending on your use of the Service, we may collect two types of information: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information
Personally identifiable information is information that identifies you or can be used to identify or contact you. Such information may include the Primary Accountholder’s name, username, password, address, e-mail address and telephone number and the Sub-Accountholder’s name, user name, password, telephone number and email address. Additionally our Outside Contractor (as defined below) that is responsible for billing and account services (the “Account Services Provider”) may collect Primary Accountholders’ social security numbers and bank account information (collectively, “Funding Information”) from Primary Accountholders directly. Finnest may receive or have access to such bank account information but does not store Funding Information (except with respect to any Primary Accounts and/or Sub-Accounts).
Non-Personally Identifiable Information
Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including demographic information (such as age, profession, gender, current location, zip code, birth date, or year of birth), IP addresses, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Service, including purchases and financial behavior. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences).
We will collect personally identifiable information that you submit to us. We may also receive personally identifiable information about you from third parties providing credit and debit card authorization and fraud screening services as part of your use of the Service.
Registering to Use the Service and in the Course of Using the Service.
You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us with information (including personally identifiable information and non-personally identifiable information) such as name, user name, password, postal address, e-mail address and birth date and you will be required to provide information, including the Funding Information, directly to the Account Services Provider. We may also receive personally identifiable information about you from third parties providing credit and debit card authorization and fraud screening services as part of the registration process. In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments. Also, we will have access to any personally identifiable information that you choose to share through the Service.
Cookies and Action Tags.
We may collect non-personally identifiable information passively using “cookies” and “action tags.”
“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your Web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings or to determine the popularity of certain content.
In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services. In the course of providing such services, such third-party analytics providers could place or recognize unique cookies on your browser.
You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.
For the avoidance of doubt, this Service uses third-party service platforms (including to help analyze how users use the Service). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.
Here are links to the main third-party platforms we use that employ such cookies:
"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including e-mail sent on our behalf, may contain action tags.
By using cookies and action tags together, we are able to gain valuable information to improve the Service.
We also collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.
Any information you share in a Public Area (including personally identifiable information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot control or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personal information in a Public Area you can send us an e-mail to request that we remove it by contacting us at firstname.lastname@example.org. You should understand that in some cases, we may not be able to remove your information.
IS INFORMATION SUBMITTED TO THE PUBLIC AREAS OF THE SERVICE PRIVATE?
DOES FINNEST COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?
WHAT DOES FINNEST DO WITH THE INFORMATION IT COLLECTS?
In general, we use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, and, unless you “opt out, so that we and third parties can contact you about products and services that may be of interest to you.
We may use your information to send you a welcoming e-mail that may confirm your user name and password. Unless you opt out, we and third parties may send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences. If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Service.
WHEN DOES FINNEST DISCLOSE INFORMATION TO THIRD PARTIES?
We may disclose personally identifiable and non-personally identifiable information (including personally identifiable information) about Sub-Accountholders to the applicable Primary Accountholder, including information pertaining to purchases and financial behavior.
We may disclose personally identifiable and non-personally identifiable information (including personally identifiable information) about you to the Bank for the purpose of providing the Primary Account or any Sub-Accounts, including information pertaining to purchases and financial behavior.
Funding Service Provider
Laws and Legal Rights.
We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Finnest Terms of Service, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.
Third Parties Generally.
We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. Unless you opt out we may also provide to third parties personally identifiable information. In addition to the above, when users use our Service, third parties (including without limitation third-party analytics providers and commercial partners) may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include providers of products or services (including analytics service providers, vendors and providers of hosting services and cloud storage and website tracking services), Card program managers, merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties.
Please note in particular that the Service uses Google Analytics, including its data reporting features, and that we use Google AdWords, including for remarketing to users. Information collected by Google includes but is not limited to web metrics. For information on how Google collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.For information on Google AdWords’ currently available opt-out options, we encourage you to visit Google’s website.
Sale of Business.
IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?
We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.
Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.
COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?
Personally identifiable information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.
WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?
DO NOT TRACK
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.
CAN I UPDATE OR CORRECT MY PERSONALLY IDENTIFIABLE INFORMATION?
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
By postal mail or courier:
Attn: Privacy Agent
695 Atlantic Ave, 9thFloor
Boston, MA 02111