Privacy Policy

This Privacy Policy describes the personal information that Fyncr, Inc. (“Fyncr”, “we”, “our”, or “us”) collects when you use the Fyncr website at https://www.fyncr.com/ (the “Website”) and the mobile Application (“Mobile App”) (Website and Mobile App collectively the “Services”), how we use this information, with whom we share it, and the choices you have in connection with this.

1. INFORMATION WE COLLECT AND USE

Through your use of the Services, Fyncr will collect personal information, which is information that identifies you directly or indirectly as outlined below.

1.1. Information Collected From You

As you use the Services, Fyncr will collect personal information when you:

• Contact us: When you contact us with a question or inquiry by email, we collect, from you, your identifiers (name and email address) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you inquire about. If you opt-in, we will also use the provided identifiers to send you marketing communications we feel may be of interest to you. You can unsubscribe any time by clicking the “unsubscribe” link in each message.

• Create an account: When you create an account on the Mobile App, we will collect, from you, your identifiers (first and last name, mobile phone number, address, email address, and selected username and password). We use this personal information to create and maintain your account, communicate with you, and facilitate your access to the account features, including the rewards program. If you opt-in to receive promotional and account-related text messages to your cellular telephone number, we will use your cellular telephone number to send you automated promotional text messages through an auto-dialer. Message and data rates may apply. Reply “STOP” to any promotional text message to stop us from sending you future promotional text messages, or “HELP” for further assistance. If you opt-in to promotional text messages, text message frequency varies based on your use of the Services. Agreement to receive promotional text messages is not a condition of any purchase from us.
• Join our mailing list: If you subscribe to our mailing list, we will collect, from you, your email address to facilitate your request to receive news and special offers from us. You can unsubscribe any time by clicking the “unsubscribe” link in each message.
• Verify your Identity and Account Information: Before we activate your account, we will collect, from you, identifiers (name, date of birth, email, home address, and Social Security number). We provide this information to our identity verification provider, Equifax, the credit bureau, who uses the information in order to authenticate your identity and confirm your eligibility to be provided the Services in accordance with applicable legal requirements. Our data partner Envestnet will use this information to carry out this process on a regular basis throughout the time you use the Services and will retain the information for as long as required by law and per instructions from the bank. We do not retain or access your Social Security number or any of the other financial account information. It is all held encrypted in Very Good Security’s (PCI DSS compliant data security) vault. Yodlee may use other financial information on your usage of its services for its own marketing purposes, and their use of your information is subject to Yodlee’s privacy policy and terms and conditions.
• Link your Financial Accounts: In order to use our Services, you will need to login to your credit card and bank account online accounts through our third party service provider, which provides access to your bank and credit card information (bank account number, bank routing number, credit card number, expiration date). Our service provider may also use information on your usage of its services for its own marketing purposes. The service provider’s uses of your information and its website is subject to its distinct privacy policy and terms and conditions. If you do not link your bank account through the service provider, you will not be able to use our Services. Your bank and credit card information are neither visible to Fyncr Inc. nor directly used by Fyncr Inc. It is stored, encrypted in a third party data vault, and communicated in tokenized form. When you visit your bank or credit card company’s website or mobile application, your interaction with that website or mobile application is not governed by this Privacy Policy or our Terms of Service. Instead, your interactions are governed by the respective bank or credit card company’s Privacy Policy and Terms of Service, which you should carefully review.

• Use our mobile app: When you use our Mobile App, we track all the transactions that you do. We do this in order to helps us confirm that the debit and credits are completed.

Fyncr may also use your personal information collected for the above purposes to efficiently maintain our business, to comply with the law, and for other limited circumstances as described in HOW WE SHARE YOUR INFORMATION.

1.2. Information Collected Automatically

In addition to the personal information you provide, when you use our Website and mobile application, Fyncr collects information via cookies and similar technologies. This information includes your:

• Usage information. This includes information such as: your time of visit to the Services, pages visited, search terms, actions taken, how much time you spend on each page, transactions and payment method and amount, reward redemption information including order details and delivery information, or customer objects throughout the Services and frequency of access. We use this personal information to: (i) conduct analytics; (ii) enhance user experience; (iii) prevent fraudulent use of the Services; and (iv) diagnose and repair errors.

• Error information. In the event of technical errors with the Services, we collect information in connection with an error message including filename, error line number, and any related error message generated by the component that failed.

• Device information: We use strictly necessary, functional, and analytics cookies to collect certain information about the device you use to access our Services, such as browser type, browser language, hardware model, operating system, and your preferences. We use this personal information to: (i) conduct analytics; (ii) enhance user experience; (iii) prevent fraudulent use of the Services; (iv) diagnose and repair errors; (v) remember your preferences; and (vi) provide enhanced functionality.

• Google Analytics. For the Website, we use Google Analytics to collect information on your use of the Services to improve our Services. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Services or to another application which partners with Google is governed by the Google Analytics Terms of Use and the Google Privacy Policy, available for review here. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

• Firebase. To conduct analytics on the Mobile App, we use a tool called Google Analytics for Firebase in order to derive application behavioral analytics and to provide insight on Services usage and user engagement. We use this information to see how users interact with our Services and to improve the Services. In order to collect this information, Google Analytics for Firebase may set cookies and similar technologies to collect information from your mobile device. This information may include your IP address, how often the Services are used, when and for how long you access the Services, your device’s operating system details, your device model, version of the Services, and other technical and statistical information. We do not combine the information collected through the use of Google Analytics for Firebase with personally identifiable information. For more information about the data collected through Google Analytics for Firebase, and how this data is used, please review Firebase for Google’s privacy policy. You can control the information provided to Google and opt-out of certain features by using any of the methods set forth in Google’s Privacy and Terms here.

• Crashlytics: The Mobile App also use a tool called Crashlytics, a software development tool, to track and prevent Services crashes and malfunctions. In case of a crash, a crash report is automatically generated and transmitted to Crashlytics that consists of including the type of device used, the operating system, carrier, network information, IP address, signal strength, battery level and battery-charging state, Services version, and other technical information. The information collected by Crashlytics does not personally identify users of the Services and is not associated with other data available to Google. For more information about the data collected through Firebase Crashlytics, and how this data is used, please review Firebase for Google’s privacy policy. Sharing of information with Crashlytics can be disabled in your mobile device settings.

In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. You cannot disable the tracking of the actions within the Services (after the log-in) as it is necessary for the provision of the Services.

2. HOW WE SHARE YOUR INFORMATION

A. General Sharing

Fyncr may share the personal information identified in this Privacy Policy in the following instances:

• Within Fyncr: Where necessary, Fyncr will share your personal information within Fyncr in order to efficiently carry out business and to the extent permitted by law. We will also share and use your personal information, in an individual or aggregated format, within Fyncr for research and development purposes to improve our Services.

• With service providers: Fyncr will share your personal information with service providers that perform services on Fyncr’s behalf. These service providers include our IT support and security, and identity and account validation providers (sharing your bank and credit card information, and Social Security number).

• In the event of a corporate reorganization: In the event that Fyncr enters into, or intends to enter into, a transaction that alters the structure of Fyncr, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our assets, Fyncr would share your personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. Fyncr would also share your personal information with third parties if Fyncr undergoes bankruptcy or liquidation, in the course of such proceedings.

• For legal purposes: Fyncr shares your personal information where legally required, such as to the acquirer bank, which in turn may be required to share it with U.S. Financial Crimes Enforcement Network (“FinCEN”) for Suspicious Activity Reports, in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.

B. Sharing For A Business Purpose

In the preceding twelve (12) months, Fyncr has disclosed the following personal information for a business purpose with the following categories of third parties:

• We have disclosed internet or other electronic network information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair Mobile Application errors, and to update or improve the Mobile App.

• We have disclosed your personal identifiers, payment information, and internet and other electronic network activity information to service providers that perform services on our behalf. These service providers include our IT support, payment processor, financial institutions related to your credit cards and bank accounts, communications vendor, customer support management provider, cloud provider, and reward program provider.

C. Sale of Personal Information

In the preceding twelve (12) months, we have not sold your personal information collected through the Services.

3. MOBILE APP CHOICES

• Correct or view your personal information: You can access your Fyncr account to correct or view certain personal information of yours in our possession and which is associated with your account.

• Delete your account: You can delete your Fyncr account at any time by emailing us at support@fyncr.com. You can also stop all further collection of your personal information by the Mobile App by uninstalling the Mobile App. Even if you delete your account, we will retain your identifiers (name, telephone number, social security number, email address, zip code and date of birth) to comply with financial laws, regulations, and rules. We also continue to retain bank and credit card account transaction data in case you decide to recover your account by redownloading our Mobile App again in the future. Your bank account identifying information (account number, routing number, credit card number, bank and credit card issuing bank login credentials) will not be retained by us, but will be retained in the Very Good Security vault to comply with fraud reporting requirements.

• Device location settings: The collection of location data is required by the mobile application stores. Through your mobile phone settings you can limit the collection of data to occur only when the Mobile App is active.

• Push notifications: If you have enabled push notifications on the Fyncr Mobile App, you may disable these at any time by updating your mobile device settings.

4. RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) grants certain rights to California residents. If our processing of your personal information is subject to the CCPA, you are entitled to the following rights:

• Right to access. You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding 12 months. You may only make a request for access twice within a 12-month period.

• Right to deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. Please refer to Section 3, “MOBILE APP CHOICES” for certain types of personal information exempt from deletion.

• Right to opt-out. You have the right to opt-out of the sale of your personal information to third parties. Fyncr does not have actual knowledge that it sells personal information of minors under the age of 16 years.

• Right to non-discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.

To exercise your right to access or delete your personal information, you may submit a request by calling us at +1 833 908 3339 or emailing us at support@fyncr.com. For requests submitted via telephone and email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

5. NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. Fyncr does not currently sell any of your personal information under Nevada law, nor does Fyncr plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting Fyncr at support@fyncr.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

6. MARKETING EMAILS

You may opt-out of receiving marketing emails from Fyncr by clicking the “unsubscribe” link provided with each email. Alternatively, for Apple products with iOS version 15, enable Mail Privacy Protection (MPP). Please note that Fyncr will continue to send you emails necessary to the Services, your account, your purchase, or any assistance you request.

7. DO NOT TRACK

We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

8. INFORMATION SECURITY

Fyncr implements and maintains reasonable security measures, including access controls and encryption, to protect the personal information that Fyncr collects and maintains.

9. AGE RESTRICTION

The Website are not intended for individuals under the age of eighteen (18).

10. CHANGES TO THIS PRIVACY POLICY

Fyncr may change this Privacy Policy from time to time. We will post the changes to this page and indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If Fyncr make changes that materially affect your privacy rights, we will notify you with a prominent post on the Services and obtain your consent, if required.

11. CONTACT

If you have any questions about this Privacy Policy, please contact us at support@fyncr.com.