Last Updated: December 234, 2022
Please note that our Services and Site are not intended for minors below the age of 18 years, and we do not knowingly collect data relating to minors.
1. Important information and who we are
The Site may include links to third-party websites, plug-ins, and applications (“Third-Party Sites”). Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control Third-Party Sites and are not responsible for their privacy and data security practices. When you leave our Site, we encourage you to read the privacy notice of every Third-Party Site you visit or use.
2. The information we collect about you
Personal information is a broad term which includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (de-identified data).
The definition of personal information includes the specific pieces of personal information which we have described below. Depending on whether and how you use our Services or Site, we may collect, use, store and transfer different kinds of personal information about you which we have grouped in categories as follows:
|Category of Personal Information||Specific Pieces of Personal Information|
|Technical Data||internet connectivity data, internet protocol (IP) address, operator and carrier data, login data, browser type and version device type, category and model, time zone setting and location data, language data, application version and SDK version, browser plug-in types and versions, operating system and platform, diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and other information stored on or available regarding the devices you allow us access to when you visit the Site, or use the Services or the App.|
|Profile Data||the email associated with your accounts, requests by you for products or services, your interests, preferences and feedback, other information generated by you when you communicate with us, for example when you address a request to our customer support.|
|Usage Data||information about how you use the Site, the Services, mobile applications and other offerings made available by us, including: device download time, install time, interaction type and time, event time, name and source.|
|Marketing and Communications Data||your preferences in receiving marketing from us or third parties, your communication preferences, your survey responses.|
Certain personal information may be sensitive and used only in accordance with applicable law
We may also collect, use, and share information that has been anonymized or de-identified, including statistical or demographic data, for any purpose (“Aggregate Consumer Information”). For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Consumer Information with your personal information so that it can directly or indirectly identify you, we treat the combined data as Personal Information pursuant to applicable law.
If You Refuse to Provide Personal Information
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, including the ability to offer or provide or continue to provide Services or other functionality.
3. How is your personal information collected
We use different methods to collect information from and about you including through:
Direct interactions. You may give us your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, , by email, through the FNL Network mobile application or otherwise. This includes personal information you provide when you:
- Visit the Site
- Subscribe to our publications
- Request marketing to be sent to you
- Enter a competition, promotion, or survey, including through social media channels
- Give us feedback or contact us
Third parties or publicly available sources. We also obtain information about you, including Social Identity Data from third parties or publicly available sources. These sources may include:
- Customer referring you
- Public blockchains
- Marketing partners and analytics providers
- Other publicly available databases and information
4. How we use your personal information
- To provide Services
- When necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- To comply with a legal obligation
- When you use our Services, our authorized partners may collect categories of personal information about you and use this data for their own purposes. This activity may qualify as a sale under the California Consumer Privacy Act (“CCPA”). Under the CCPA, you can make choices to allow or prevent such uses.
Purposes for which we will use your personal information
We have set out below an illustrative example of the common ways we may use your Personal Information:
- To register you as a new customer
- To carry out and comply with legal and compliance obligations
- To process and deliver the Services and any features and functionality
- To prevent abuse of our Services, Site, and promotions
- To keep our records updated and to evaluate how customers use our products/services
- To gather market data for studying customers’ behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business
- To administer and protect our business, the Site, and social media channels including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
- To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
- To make suggestions and recommendations to you about goods or services that may be of interest to you
- To use the services of social media platforms or advertising platforms some of which will use the personal information they receive for their own purposes, including marketing purposes
- To record voice calls and other conversations for compliance, quality assurance, and training purposes
We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.
Promotional Offers From Us
We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you. You may receive marketing communications from us if you have requested information from us or used the Services and have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Further, you can let us know directly that you prefer not to receive any marketing messages by emailing firstname.lastname@example.org.
Sale or Transfer of Business We may need to process your Personal Information in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving all or a part of our shares, business, or assets.
5. Disclosures of Your Personal Information
We may share your Personal Information with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies, and affiliates in order to complete tasks, provide the Services, and use of the FNL Network mobile application to you on our behalf, and otherwise fulfill our obligations. When using third-party service providers, we
request they respect the security of your Personal Information and treat it in accordance with the law.
We may share your Personal Information and other data you provide to us for the following purposes:
- To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.
- To improve our information, technology, and security systems including websites and mobile applications.
- To provide customer service.
- To promote our Services if you submit a product review or post content on public areas of our Services, or social media accounts.
- To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).
The categories of third parties with whom we may share your personal information for the purposes listed above include:
- Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services
- Any third party because of any restructure, sale or acquisition of our group or any affiliates
- Regulatory and law enforcement authorities, where the law allows or requires us to do so We disclose Personal Information to third parties only in accordance with applicable law.
6. Personal Information Security
While there is an inherent risk in any information being shared over the internet, we have put in place commercially reasonable security measures to prevent your Personal Information from being accidentally lost, used, damaged, or accessed in an unauthorized or unlawful way, altered, or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your Personal Information on our instructions. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse such as by maintaining the confidentiality of your Personal Information.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a qualifying breach when required.
If you want to know more about our security practice, please visit this link.
7. Personal Information retention
How long will you use my personal information for?
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal or other requirements.
Please note that under certain conditions, you can ask us to delete your Personal Information.
8. Your legal rights
Under certain circumstances, you may have certain rights in relation to your Personal Information:
- Right to know about Personal Information collected, and how it is used and disclosed.
- Right to request correction of certain Personal Information.
- Right to request deletion of certain Personal Information.
- Right to opt-out of the sharing of certain Personal Information.
When allowed by applicable law and required, we will take steps to disclose and deliver to you, free of charge, your Personal Information accordingly. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you are a California resident, you also have the right to know about Personal Information sold. In addition, you may also opt out of the sale of your personal information by clicking on the “Do Not Sell My Personal Information” link here.
If you are a California resident, please also note that some of your Personal Information is subject to the Gramm-Leach-Bliley Act. Information we collect for the purposes of complying with the GLBA and its implementing regulations is not covered by the CCPA (and therefore may not be subject to deletion requests). However, other Personal Information of yours could still be subject to the CCPA.
You will not receive a discriminatory treatment if you choose to exercise any of the rights conferred to you above.
If you want to make a request under the CCPA through a natural person or a business entity authorized to act on your behalf, please beforehand contact us and in a timely manner we will provide you with a reply on how to designate such a person.
9. Children’s Privacy
FNL Network respects the privacy of children, and we are committed to complying with the Children’s Online Privacy Protection Act (herein called “COPPA”). We do not knowingly collect Personal Information from children under the age of thirteen (13). If you are a parent or guardian and you are aware that your child under the age of 13 has provided us with personally identifiable information, please contact us. If we become aware that we have collected personally identifiable information from children without verification of parental consent, we take steps to remove that information from our servers.
10. Notice to California Residents
This section supplements the information above and applies solely to California residents who use our Sites and Services.
Personal Information Collected and Disclosed
We collect and share personal information that is identified below in addition to the information identified above. The following table describes the collection, use, and sharing of personal information collected by us or our service providers within the last twelve (12) months. For a detailed description of the data included in each category, see Section 2. Personal Information We Collect.
|Categories of personal information collected||Sources of information; purposes of processing||Parties to whom data has been disclosed or shared|
|Personal Identity Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement|
|Social Identity Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement|
|Contact Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement|
|Technical Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement|
|Proﬁle Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement;|
|Usage Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement;|
|Marketing and Communications Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement;|
|Employment Data||Section 4. How We Use Your Personal Information Subsections 1, 6, 8||Regulatory and law enforcement;|
Opting Out of the Sale of Your Personal Information
If you are a California resident, you have the right to know about the sale of your personal information and the right to opt out of the sale of your personal information. When you use our Services, our authorized partners may collect categories of personal information about you and use this data for their own purposes. This activity may qualify as a sale under the California
Exercising Your Rights as a California Consumer
You may request that we:
- Provide you with the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information
- Correct your personal information that is inaccurate
- Provide access to and/or a copy of certain information we hold about you
- Delete certain information we have about you
If you wish to make a request under the CCPA through a natural person or business entity authorized to act on your behalf, please contact us in a timely manner beforehand and we will provide you with information about how to designate such a person.
To exercise any of the above rights, please contact us at email@example.com. You may also contact us at our mailing address at:
1812 West Burbank Blvd
Burbank, CA 91506
Complying with your request to exercise any of the rights above may require us to verify your identity. Any personal information we collect for this purpose will be used only for the purpose of verification or as otherwise required by law.
Please note that some of your personal information is subject to the Gramm-Leach-Bliley Act. Information we collect for the purposes of complying with the GLBA and its implementing regulations is not covered by California law and therefore may not be subject to deletion requests.
11. GLBA Consumer Privacy Notice
Please see our GLBA Consumer Privacy Notice below for disclosures under the Gramm-Leach Bliley Act.
|FACTS||WHAT DOES FNL NETWORK DO WITH YOUR INFORMATION?|
|Why?||Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect, and share depend on the product or service you have with us. This information can include: Technical Data and Usage Data|
|How?||In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons FNL Network chooses to share; and whether you can limit this sharing.|
|Reasons We Can Share Your Personal Information||Does FNL Network Share?||Can You Limit This Sharing?|
|For our marketing purposes – to offer our products and services to you||Yes, we use digital platforms as a service to run our marketing campaigns. This is not third-party marketing.||Yes, you can opt-out of receiving marketing messages.|
|For joint marketing with other financial companies||We do not perform joint marketing with other financial companies||Not applicable|
|For nonaffiliates to market to you||We do not share information with nonaffiliates for marketing purposes.||We do not share information with nonaffiliates for marketing purposes.|
|To Limit Our Sharing||Email us at firstname.lastname@example.org. Please note: If you are a new customer, we can begin sharing information once you have been onboarded. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.|
|Questions||Email us at email@example.com..|
|Who We Are|
|Who is providing this notice?||This privacy notice is provided by FNL Network and is applicable to your use of its Services, Apps, and Sites.|
|What We Do|
|How does FNL Network protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards.|
|How does FNL Network collect my personal information?||We collect your personal information, for example, when you: Visit our Sites or Apps or apply for our Services Subscribe to publications or request marketing materials Give us feedback|
|Why can’t I limit all sharing?||Federal law gives you the right to limit only: Sharing for affiliates’ everyday business purposes – information about your creditworthiness Affiliates from using your information to market to you Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing.|
|Affiliates||Companies related by common ownership or control.|
|Nonaffiliates||Companies not related by common ownership or control. Our nonaffiliates include service providers that perform services or functions on our behalf.|
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.|