Finhabits Privacy Policy

Policy Effective Date: April 2, 2019

This Privacy Policy sets forth how personal information is collected and used, that is provided on the web site located at www.finhabits.com and our mobile application (collectively, “Finhabits Sites”). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Finhabits Sites by Finhabits Inc., Finhabits Advisors, LLC, or any of their respective affiliates (together, for purposes hereof, “Finhabits”). By using the Finhabits Sites, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future (see "Change to this Privacy Policy" below).

Finhabits is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy Policy explains how we protect personal information provided through the Finhabits Sites and how we use that information in connection with our service offered through the Finhabits Sites (the "Service"). "Personal information" for purposes of this Privacy Policy means information that identifies you, such as your name, address, phone number or email address.

The security of your information is important to us. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.

Personal Information Collected

We collect the following personal information from you:

- Contact information such as name, email address, residential address, phone number;
- Billing information such as credit card number, and billing address;
- Financial information such as bank or brokerage account numbers, types of investments;
- Social Security number or Individual Tax Identification Number;
- Government-issued identification number;
- Unique identifiers such as user name, account number, password;
- Preferences information such as product wish lists, and marketing preferences; and
- Demographic information such as age, education, gender, interests, and zip code.

When you visit the Site or download and use our Services, we may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include the type of device you use, operating system, the device identifier (or "UDID"), your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our website, and other available information. We may also collect information about your use and interaction with the web site, our mobile application, or our Services. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account.

Information Sharing

Finhabits uses and discloses your personal information only as follows:

- To analyze site usage and improve the Service;
- To deliver to you any administrative notices, money alerts, and communications relevant to your use of the Service;
- To fulfill your requests for certain products and services;
- For market research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;
- To third-party contractors that provide services to Finhabits and are bound by these same privacy restrictions;
- To enforce Finhabits’ Terms of Use; and as otherwise set forth in this Privacy Policy.

In addition, we may, from time to time, offer promotions with various businesses, websites, mobile applications or third parties, which may include opportunities for you to earn deposits within the Service. Each such promotion will be subject to and governed by our Terms of Use, this Privacy Policy, and any applicable rules or terms and conditions we may post online, post in our mobile application, include within e-mail or other communications, or otherwise make available to you. To the extent you elect to participate in any such promotion or otherwise make any purchase subject to a promotion, we may share personal information such as name, e-mail address, and other related information with the applicable third party for the limited purpose of allowing the parties the make the promotion available and track participation within such promotion.

We may use information you provide to connect you with people you may already know. For example, through our mobile application we may identify contacts within your address book as potential new users of Finhabits. We may match the contact information you provide to the information provided by other users to improve the Service, including making it easier to find contacts you may refer to Finhabits that are not already customers.

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If Finhabits Inc is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Finhabits Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Third Party Services

Finhabits uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Finhabits and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

User Access and Choice

If the personal information on file for you changes, or if you no longer desire our service, you may correct or update it by making the change on our customer information page or by emailing Customer Service at support@finhabits.com.

We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at the information below.

Cookies / Tracking Technologies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Finhabits Sites. We do not link the information we store in cookies to any personally identifiable information you submit while on the Finhabits Sites.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.

If you reject cookies, you may still use the Finhabits Sites, but your ability to use some areas of the Finhabits Sites, such as contests or surveys, may be limited.

The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and/or service providers use session ID cookies to make it easier for you to navigate the Finhabits Sites.

Surveys and Contests

We may, from time to time, ask you to participate in surveys and contests on the Finhabits Sites. Participation in these surveys and contest is completely voluntary. These surveys and contests may be conducted by our third-party service providers. Such third-party service providers are authorized to use your information only as necessary to conduct these surveys and contests for us. We will use survey and contests results to continue to improve the Service. We will use your personal information from our surveys and contests to send you information about our products and services and about third-party products and services. We may also anonymize and aggregate the survey and contest information and sell it to third parties.

Security

The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Finhabits Sites, please contact us.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on the Finhabits Sites. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued relationship with Finhabits after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by us.

Contact Us

If you have any questions about our Privacy Policy, please contact Finhabits at:

support@finhabits.com

Finhabits Inc.
46 Hester Street, Floor 2
New York, NY 10002