Effective 22 January 2024

Financredits BNK (” FNCD ” or ” We ” ) are serious about protecting the privacy of your personal information. We have implemented strict policies to ensure that the privacy of your personal information is protected while still allowing you to use our website (the “Site“) or any mobile applications or other products or services provided by FNCD (collectively with the Site, the “Services“). We use information collected about you through your use of the Services or on the Site only for the purposes set forth in this policy. The terms of this policy are also incorporated into FNCD’s Terms of Use and Terms of Registration.

What information do we collect?

We collect personal information about you when you register with our service (directly or indirectly through a partner). “Personal information” generally means information that can be used, alone or in combination with other information, to personally identify a company or individual.

This information includes, but is not limited to, your name, email address, mailing address, telephone number, social security number and bank account information, and your photograph and related information (for identity verification purposes, as detailed below). We do not collect any biometric information for identity verification purposes from businesses located in Illinois. Personal information does not include publicly available information or information that has been de-identified, aggregated or in a form that cannot be associated or linked to you.

We also collect information about our transactions and experiences with you, including your payment history. We may also collect information from third party websites or applications, as specified in this policy. We may also collect information automatically through the use of cookies and other technologies, as described below.

If you provide or make available any personal information about any staff members, directors, employees, owners and other authorised persons of the company, you must first obtain their consent to disclose such information to us. You must inform all such other persons how we process personal information and all other terms of this Privacy and Security Policy.

What do we do with the information we collect?

Any information we collect from you may be used in one of the following ways:

• To collect, store, use and analyse your information both in personally identifiable form and in aggregated, non-personally identifiable form;
• To operate, maintain, improve and provide our Services to you, conduct our business and process transactions;
• To verify their identity;
• To register you as a user and identify you when you log in to your account;
• To conduct background checks and determine your eligibility for our products;
• To personalise your experience and improve customer service (your information helps us to better respond to your individual needs, service requests, send marketing communications and send account update notifications);
• To provide you with information about our products, services, third party offers and other opportunities that we believe may be of interest to you, including on other platforms and with our third party banking and lending partners, and to personalise, measure and improve such offers;
• To develop and improve the Site (we continually strive to improve our website offerings based on the information and feedback we receive from you);
• To detect and protect against potential fraud, identity theft, security incidents or other illegal activities; and
• To comply with our legal obligations; to respond to subpoenas, court orders or legal process; and to establish or exercise our legal rights or defend against legal claims.

We will share your personal information with third parties only in the ways that are described in the policy.

Security or how do we protect your information?

We take security seriously and have developed a comprehensive set of practices, technologies and policies to help ensure the security of your data. We take your security and privacy seriously and consider it a priority. As such, we use advanced security technology and implement a variety of security measures to maintain the safety of your personal information.

More specifically:

• All our communications and processes are carried out using Secure Socket Layers (SSL) technology, which ensures that such information is encrypted and secure. Such information is stored in our secure database in an encrypted format, which can only be accessed by FNCD employees and representatives with special access rights. These persons are obliged to maintain the confidentiality of the information.
• We have established a dedicated security team.
• To help prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
• We also use the services of leading companies to process all financial transactions.

While we strive to protect your personal information and use commercially acceptable means to protect it, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, FNCD. cannot ensure or warrant the absolute security of any data or content you transmit to us.

In the event of a suspected breach of the security of your personally identifiable information, to the extent required by law, we will notify you so that you can take appropriate protective measures and to inform you of the steps FNCD. is taking with respect to such suspected breach.

Do we use cookies?

As with most platforms, we use tracking technology (i.e., cookies and similar technologies) to help us make the Site and our services more user-friendly, efficient and secure. We may use such technology for advertising purposes, including to serve ads on other platforms based on your browsing history and other online behaviour. Cookies will not harm your computer or mobile device and do not contain viruses.

If you prefer not to accept cookies, you can disable certain cookies in one of the following ways:

• Via an interactive web form. You can access our interactive web form. Please note that you may need to process the opt-out request from each browser and device you use.
• By browser. Most browsers allow you to (1) require the browser to notify you and allow you to choose whether to accept or reject a cookie, (2) disable existing cookies, and/or (3) set your browser to automatically reject cookies. If you wish to reject cookies on all browsers you use, you will need to do so on each browser on each device you use.

Blocking cookies may adversely affect your experience on the Site. In addition, you may continue to receive advertisements, although they should not be based on your interests. We are not responsible for the effectiveness or compliance of any third party opt-out options or programmes.

Do we disclose any information to third parties?

We may provide your information to our trusted business partners who assist us in operating the Site, conducting our business (including partners who refer you to us) or servicing your account, provided that such parties agree to keep this information confidential. We may also disclose your information to third parties to whom we may refer you or to whom we may refer your enquiry or application for funding or other services, in accordance with the notice we send you and/or your consent. In addition, we may disclose our transactions and experiences with you to credit bureaus.

The following are categories of third parties with whom we may share your information:

• Affiliates, subsidiaries, consultants and agents;
• Our service providers, which may include advertising and marketing companies, social media companies, technology companies, background screening and verification companies, fraud prevention agencies and credit bureaus;
• Entities with whom we have a business relationship, which may include our partners and collection agencies;
• Loans from third parties and banking partners;
• Third party advertising platforms that allow us to show you targeted digital advertisements about our products and services (“Third Party Advertising Platforms“);
• Regulators, government agencies and law enforcement;
• Any other third party with your prior consent to do so.

In addition, we may also disclose your information:

• As required by law, for example to comply with a subpoena, court or administrative order and/or any similar legal process;
• When we believe in good faith that disclosure is necessary to (i) protect our rights or the rights of others, (ii) protect our property and safety or the property and safety of others, or (iii) investigate fraud or respond to a request from a governmental entity;
• If FNCD is involved in a merger, acquisition, transfer, auction (including in a bankruptcy proceeding) or sale of all (or substantially all) of its assets or equity, or of assets related to the divestiture of a particular division or product, in connection with such a transaction;
• In connection with the sale of delinquent debt for collection purposes; or
• With third parties on an anonymous or aggregated basis for marketing, advertising, research or other commercial purposes.

Subscription data and consent of the text message originator will not be shared with third parties.

If you choose to interact with a third party lending partner, apply for their services or
offers through our Site or through your verbal consent, or link or sync your account with a third party lending partner’s product or service, you consent and direct us to share your personal information with the third party lending partner providing the service or offer. These situations include, for example, when we send your personal information to partners to generate financing offers for your review, when we send your application information directly to our partners, or when we send you to the partner’s site to provide the information directly to them.

Any information you provide to a third party lending partner, either through us or on your own, will be subject to their privacy practices and terms and conditions.

Use of third party services and data retention

You allow us to receive information when you use the Services to log in to a third party website or application (for example, Facebook, Twitter or LinkedIn) (the “Third Party Platform“). Please note that we retain the information we receive from your personal profile on the Third Party Platform while you are logged into the Services and even after you have logged out of the Services if such retention is reasonably necessary to enforce this policy and our Terms of Use, in our sole discretion.

FNCD retains personal information only for as long as necessary to deliver the products and services for which it was collected, in accordance with your expressed preferences or as necessary to achieve the purposes described in this Privacy and Security Policy or as required by law. Users may request deletion of data in accordance with the rights described in this Privacy and Security Policy.

Partner policies

From time to time, FNCD may assist you in obtaining products or services from other banks or lending partners. Any information you provide to other banks or lending partners will be subject to their privacy practices and terms and conditions.

Use by minors

We do not knowingly collect personal information from anyone under the age of 18. If we learn of such information, we will delete it as soon as possible. If you believe we may have such information, please contact us.