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Finloc 2000 Inc. (the “Company” or “we”) values its customers, respects their privacy and recognizes that it must maintain and use their personal information responsibly. We have created this Privacy Policy to demonstrate our firm commitment to your privacy and security, and to advise you about how we collect, use and disclose your personal information in connection with our apps, websites, features, and services (collectively, the “Services” or “FinPark”). This Privacy Policy applies to all users of FinPark, including all customers, prospects and job applicants. This Privacy Policy also provides you with information regarding your ability to “opt out” of providing certain personal information that you do not wish to provide and to access, rectify, request the deletion of or withdraw consent to the communication or use of personal information already collected.

You are responsible for ensuring that your access to FinPark and material available on or through it is legal in each jurisdiction in or through which you access or view FinPark or such material.

The terms “Company,” “we”, “us”, and “our” used in this Privacy Policy refer, collectively, to the Company and its affiliates, divisions, successors and assigns and their respective employees, workers, mandataries and agents (collectively, the “Company Affiliates”).

Due to the global nature of our Services, our data processing practices may vary among the jurisdictions in which we operate in order to comply with applicable legal requirements. Please note that certain rights, requirements and disclosures in this Privacy Policy may be subject to exemptions or otherwise may not apply to you based, for example, on applicable laws or regulations. If you reside in a relevant geographic location, please see the section relating to that geographic location for more information.

  1. WHAT INFORMATION IS COLLECTED BY THE COMPANY?
    Any time you use our Services or introduce any information, content or other materials through FinPark or otherwise provide personal information to the Company (including via mail or email in
    regular correspondence), it may be collected, used and disclosed by the Company for various purposes as described herein.

    Information collected when you use our Services:

Information you provide:

We do not knowingly or intentionally collect any personal information concerning individuals’ health, ethnic and racial origins, political opinions, genetic and biometric data, sex life or sexual orientation, or religious/philosophical beliefs (“sensitive personal information”) through FinPark. You must not send us sensitive personal information of any kind through FinPark.

Children’s Privacy: In light of the importance of protecting children’s privacy, we do not intend FinPark for child audiences and do not collect, process or use on FinPark any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent, guardian or other legal representative. If a parent, guardian or other legal representative discovers that their child has provided us with personal information, such parent, guardian or other legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records. In such a case we ask the parent, guardian or other legal representative of the child to contact us at the contact information provided in the “Contacting Us” section below (Section 14).

  1. HOW IS YOUR PERSONAL INFORMATION USED?
    We may use the information we collect for the following purposes:

We may also use information collected from FinPark to measure interest in the various areas of FinPark, to ensure that links on FinPark facilitate easy navigation and to render FinPark more interesting and user friendly.

You acknowledge and agree that the Company shall also have the right to incorporate, use and reproduce any texts, images, videos, audios, or any information, content or other materials you provide through FinPark, in whole or in part, in connection with the operation, marketing and promotion of the Company’s business. You always have the right to revoke such consent in the manner described in the section “HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?” below (Section 5).

In order to better serve you as well as maintain and improve our product and service offering, we may combine and aggregate information we collect directly or indirectly from you through your use of the Services. We may also combine such information with readily available personal information we obtain from third parties, including demographic or geographic information in order to enable us to communicate with you, subject to your consent to receive communications from us, by telephone (including by way of automated dialing answering device), email, mail, text, or otherwise.

We may use personal information and other information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access the Services, or other analyses. De-identified and/or aggregated information may, depending on the jurisdiction in which you reside, not be considered personal information, and in such cases we may use, disclose, and retain such information as permitted by applicable laws and regulations.

  1. TO WHOM MAY YOUR PERSONAL INFORMATION BE DISCLOSED?
    We may disclose your personal information as provided below:
  1. WHAT ARE “COOKIES”, “WEB BEACONS” AND SIMILAR TECHNOLOGIES, AND HOW DOES THE COMPANY USE THEM ON THE SERVICES?

    We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, web beacons, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Our uses of these Technologies fall into the following general categories:

See the section below titled “HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?” (Section 5) to understand your choices regarding these Technologies.

  1. HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF
    YOUR PERSONAL INFORMATION?

    We will collect, use and share your personal information for the purposes and in the manner described in this Privacy Policy, including in order to contact you and provide you with promotional communications. We want you to know that you have choices about how we collect and use your personal information, including the choice to refuse to provide us with personal information and withdraw any consent you have provided us, in accordance with applicable laws and/or as described below.

    General: You have the choice simply not to submit any personal information to us, however this may limit our ability to serve you as it may prevent you from using or restrict your use of the Services. You may also choose only to submit information constituting required fields. In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may be able to subsequently “opt out” at any time, in accordance with applicable laws or contractual restrictions and upon reasonable notice, by contacting our Privacy Officer as described in the section entitled “Contacting Us” below (Section 14). Our Privacy Officer will also be able to provide you with additional information regarding the implications of withdrawing consent.

    Promotional Communications: You can opt out of promotional communications from us by following the opt-out instructions provided in the promotional materials sent to you. If you send us a request not to receive promotional communications from us, please be sure to include your full name, address, telephone number and any email address you used when you signed up on FinPark or otherwise communicated with us. It may take up to ten (10) business days to process your request, during which period you may continue to receive communications from the Company or the Company Affiliates. Privacy Policy

    Text Messages: You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

    Mobile Devices: We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device.

    With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

    “Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. The Company does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to or honor Do Not Track (DNT) signals or similar mechanisms transmitted by web browsers.

    Cookies and Interest-Based Advertising: You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for
    Android, iOS and others.

    The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice
    and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, and the
    Digital Advertising Alliance of Canada
    .

  2. HOW CAN YOU ACCESS OR RECTIFY YOUR PERSONAL INFORMATION OR MAKE INQUIRIES OR COMPLAINTS IN RELATION TO THIS PRIVACY POLICY AND THE COMPANY’S PRIVACY PRACTICES?

    In accordance with applicable laws, you may be entitled to request access to and/or rectify your personal information collected by us. In order to make such a request, please contact our Privacy Officer in writing. See the “Contacting Us” section below (Section 14).

    You can also contact our Privacy Officer for any questions about or to make any complaint in relation to this Privacy Policy, or the Company’s privacy practices in general. See the “Contacting Us” section below (Section 14).

  3. HOW LONG IS YOUR PERSONAL INFORMATION RETAINED?

    Your personal information is maintained on our networks or on the networks of our service providers. We retain personal information only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. 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 requirements. To satisfy regulatory requirements, certain personal information may be retained for at least seven (7) years, after which all documentation will be destroyed in a manner commensurate with its sensitivity, unless legal requirements stipulate its further retention.

  4. HOW SECURE IS YOUR PERSONAL INFORMATION?

    We use commercially reasonable efforts to adopt physical and technological processes and procedures designed to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. Furthermore, each Company employee, worker, mandatary or agent must abide by the Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any personal information we process. To the fullest extent permitted by applicable law, we do not accept liability for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data.

    The Company also strives to offer its customers a secure environment. FinPark uses PCI compliant third-party payment processors for all payment processing services and thus all credit card information will be secured in accordance with their own security practices and your payment information and credentials are not stored on our servers. FinPark reserves the right to change third-party payment processors from time to time without any obligation to provide notice to users.

    You also play an important role in protecting your privacy and the confidentiality of your personal information. For example, it is strongly recommended that you:
  1. CALIFORNIA PRIVACY PROVISIONS

    The following provisions supplement the information contained in this Privacy Policy and apply solely to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”) in our role as a business. Any terms defined in the CCPA have the same meaning when used in this section.

    Information We Collect

    The CCPA provides California residents with the right to know what categories of personal information the Company has collected about them and whether the Company disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve (12) months. California residents can find this information below:
CategoryExamplesCollectedCategories of Third
Parties Personal
Information is
Disclosed to for a
Business Purpose
Identifiers.Name, alias, postal address, unique
personal identifier,
online identifier,
Internet Protocol
address, email
address, account
name, Social Security
Number, or other
similar identifiers.
Yes– Other users
– Service providers
– Company affiliates
– Advertising partners
Commercial
information.
Records of personal
property, products or
services purchased,
obtained, or
considered, or other
purchasing or
consuming histories
or tendencies.
Yes– Other users
– Service providers
– Company affiliates
Internet or other
electronic network
activity.
Browsing history,
search history,
information on a
consumer’s
interaction with an
Internet website,
application, or
advertisement.
Yes– Other users
– Service providers
– Company affiliates
– Advertising partners
Geolocation data.Physical location or
movements is
collected as part of
administering the
Services.
Yes– Service providers
– Company affiliates
Personal information
categories listed in
the categories above,
but referenced in the
California Customer
Records statute (Cal.
Civ. Code §
1798.80(e))
A name, signature,
Social Security
Number, physical
characteristics or
description, address,
telephone number,
passport number,
driver’s license or
State identification
card number,
insurance policy
number, education,
employment,
employment history,
bank account
number, credit card
number, debit card
number, or any other
financial information.
Personal Information
does not include
publicly available
information that is
lawfully made
available to the
general public from
federal, State, or
local government
records. Note: Some
personal information
included in this
category may overlap
with other
categories.
Yes– Other users
– Service providers
– Company affiliates
Professional or
employment-related
information.
Current or past job
history.
Yes– Other users
– Service providers
– Company affiliates
Inferences drawn
from other personal
information to create
a profile about a
consumer.
Profile reflecting a
consumer’s
preferences,
characteristics,
psychological trends,
predispositions,
behavior, attitudes,
intelligence, abilities,
and aptitudes.
Yes– Other users
– Service providers
– Company affiliates
– Advertising partners


Categories of Sources from Which Personal Information Is Collected

We obtain the categories of personal information listed above from the types and categories of sources described above in this Privacy Policy.

Business or Commercial Purposes for Collecting Personal Information

We may use or disclose the personal information we collect for the business purposes described above in this Privacy Policy.

Sales of Personal Information

In the preceding twelve (12) months, we have not disclosed your Personal Information to any third party in a manner that would be considered a sale under the CCPA, nor do we have actual knowledge of any sale of personal information of minors under sixteen (16) years of age under the CCPA.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Exercising Your Rights

To exercise the access and deletion rights described above, or if you have any questions about these rights, please submit your request to us at privacy@finloc.com or contact us in writing at the address listed below in this Privacy Policy. We will process such requests in accordance with applicable laws.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification

When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

California’s “Shine the Light” Law (Civil Code Section § 1798.83) permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below in this Privacy Policy (see section 14).

10. NEVADA PRIVACY PROVISIONS

If you are a resident of the State of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

  1. INTERNATIONAL TRANSFERS

    All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States of America, Canada or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
  2. PRIVACY POLICY CHANGES

    We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable laws. Following the effective date of such changes, you will be bound by such changes unless you advise us in writing, by phone or by email before the effective date of such changes that you do not agree to the changes, in which case you may not be able to continue using the Services. You are responsible for regularly reviewing this Privacy Policy and any changes thereto.
  3. OTHER WEBSITES/APPLICATIONS

    FINPARK MAY CONTAIN LINKS TO OTHER WEBSITES/APPLICATIONS THAT ARE NOT OPERATED BY THE COMPANY. THE POLICY DOES NOT APPLY TO THE PRACTICES OF THIRD PARTIES AND THE COMPANY DOES NOT ASSUME ANY RESPONSIBILITY FOR ANY SUCH THIRD-PARTY PRACTICES OR FOR THE PRIVACY PRACTICES OF THE WEBSITES/APPLICATIONS THAT IT DOES NOT OPERATE. BY USING FINPARK AND/OR ACCESSING A THIRD PARTY’S WEBSITE/APPLICATION FROM FINPARK, YOU RELEASE THE COMPANY OF ANY RESPONSIBILITY FOR THE ACTIONS, PRACTICES AND OMISSIONS OF THIRD PARTIES. BY CLICKING ON ANY HYPERLINKS TO OTHER WEBSITES/APPLICATIONS FROM FINPARK, YOU MAY AUTOMATICALLY SUBMIT TO THE PRIVACY PRACTICES OF THOSE WEBSITES/APPLICATIONS. PLEASE CHECK THE PRIVACY POLICIES OF THESE THIRD-PARTY WEBSITES/APPLICATIONS. IN NO EVENT SHALL THE COMPANY OR ANY COMPANY AFFILIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES OR INJURY WHATSOEVER (INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES) ARISING OUT OF OR IN CONNECTION WITH THE MISUSE OF PERSONAL INFORMATION BY THOSE WEBSITES/APPLICATIONS.
  4. CONTACTING US

    The Company has appointed a Privacy Officer. The Privacy Officer is accountable for the Company’s compliance with the principles of any applicable privacy legislation and this Privacy Policy.

    If you have questions or complaints with respect to our Privacy Policy and practices or if you wish to request access to, or rectify your personal information under the Company’s care and control, please contact the Privacy Officer at:
BY EMAILBY PHONEBY POST MAIL
privacy@finloc.com418-227-838411505, 1st Avenue
Suite 500
Saint-Georges, Québec
Canada, G5Y 7X3

Last updated: January 17th, 2024.
Effective date: Jan 17, 2024.

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