Applicability

This disclosure explains how FinSyte.com LLC d/b/a Finsyte (Finsyte or the Company)  collects, uses and discloses personal information relating to applicable U.S. state privacy regulations, including California residents covered by the California Consumer Privacy Act of 2018 (CCPA) and Consumer Rights Privacy Act of 2020 (CPRA), Colorado residents covered by the Colorado Privacy Act (CPA), Connecticut residents covered by the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (CTDPA), Delaware residents covered by the Delaware Personal Data Privacy Act (DPDPA), Florida residents covered by the Florida Digital Bill of Rights (FDBR), Iowa residents covered by the Iowa Consumer Data Protection Act (ICDPA), Montana residents covered by the Montana Consumer Data Privacy Act (MTCDPA), Nebraska residents covered by the Nebraska Data Privacy Act (NEDPA), New Hampshire residents covered by the New Hampshire Data Privacy Act (NHDPA), New Jersey residents covered by the New Jersey Privacy Act (NJDPA), Virginia residents covered by the Virginia Consumer Data Protection Act (CDPA), Texas residents covered by the Texas Data Privacy and Security Act (TDPSA), Oregon residents covered by the Oregon Consumer Privacy Act (OCPA) and Utah residents covered by the Consumer Privacy Act (UCPA).  We are providing this specific privacy notice to supplement the information and disclosures already contained in our Finsyte Privacy Notice.

Introduction                                                                                

Under the state regulations, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular resident. The specific Personal Information that we collect, use, and disclose relating to a resident covered by the applicable regulations will vary based on our relationship or interaction with that individual.

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or by application service providers that we use to support our business.

Collection or Disclosure of Personal Information

The chart below outlines the categories (as defined by the California regulations) of Personal Information and the actual Personal Information we have collected in the preceding twelve months. The examples of Personal Information provided for each category are taken from the California regulations and are included to help you understand what the categories mean. Other applicable states listed above may have different requirements, but the disclosure requirements are similar. THE PERSONAL INFORMATION THAT WE ACTUALLY COLLECT OR DISCLOSE IS LISTED IN THE SECOND COLUMN OF THE TABLE BELOW.

Category Examples	ACTUAL INFORMATION COLLECTED BY FINSYTE
A. Identifiers Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Name, title, business name, business email address, business physical address, business telephone number.
B. Categories of Personal Information in Cal. Civ. Code 1798.80(e) Examples: 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, medical information, or health insurance information.	Name, title, business name, business email address, business physical address, business telephone number.
C. Characteristics of Protected Classifications under State or Federal Law Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	None
D. Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Records of products or services purchased
E. Biometric Information Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information..	None
F. Internet or Other Electronic Network Activity Information Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.	Information regarding a contact’s interaction with the Finsyte website.
G. Geolocation Data Examples: Information that can be used to identify a precise physical location such as an IP address location of an internet-connected terminal or a GPS-enabled mobile phone	IP address location only
H. Sensory Information Examples: Audio, electronic, visual, thermal, olfactory, or similar information.	None
I. Professional or employment-related information Examples: Job application or resume information, past and current job history, and job performance information.	None
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.	None
K. Inferences Drawn from Personal Information Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	None

Categories of Sources of the Collection of Personal Information

In the preceding 12 months, we have collected Personal Information from general sources including you, your use of our services, your devices, our product vendors, and the media companies we use for promotions and campaigns. The categories of sources from whom we collected this Personal Information are:

• Directly from a resident or the individual’s representatives
• The FinSyte website

• Commercial sources

Categories of Third Parties to Whom We Disclosed Personal Information and Business Purpose

The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:

• Service providers who provide services such as website hosting, data analysis, web traffic analysis, information technology and related infrastructure, customer service, text messaging or email delivery, auditing, marketing and marketing research activities, communication infrastructure and storage.
• Media companies and social media providers who promote the Company and products to customers and other prospective buyers.
• Third parties who provide services such as payment processing, banking, legal expertise, tax expertise, notaries and auditors.
• Other third parties if we have obtained your permission to disclose your Personal Information.

 

Use of Personal Information

In the past 12 months, we have used Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services.
• Protecting against security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
• Undertaking internal research for technological development and demonstration.
• Complying with laws and regulations and complying with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)

We may send Finsyte marketing information or newsletters to you.  You may opt-out from the receipt of additional marketing or newsletter materials from the company at any time.

Sale of Personal Information

We do not sell or share your Personal Information as defined by applicable law. For purposes of this notice “sell or share” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.

Your State Privacy Rights

If you are a resident of an applicable state, you have the right to:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
  • the categories of Personal Information about you that we collected;
  • the categories of sources from which the Personal Information was collected;
  • the purpose for collecting Personal Information about you;
  • the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
  • the specific pieces of Personal Information we collected about you.
• Request we delete Personal Information we collected from you, unless the applicable state privacy requirements recognizes an exception; and
• Be free from unlawful discrimination for exercising your rights.
  
  

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information may require additional information to verify your identity.

If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to applicable state privacy access or deletion rights.

We will advise you in our response if we are not able to honor your request. We will not provide any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

If you reside in California, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm the authorized agent has permission to submit the request.  If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please contact us as set forth below.

We will work to process all verified requests within 45 days or within the time frames specified by the applicable state privacy regulations. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

How to Exercise Your Rights

If you are a resident of an applicable state listed above, you may submit a request or contact us with questions or concerns about this Disclosure and our practices to:

Finsyte.com LLC
5299 DTC Blvd, Suite 700
Greenwood Village, CO 80111
info@Finsyte.com

Appeals.  If we deny your request, you may appeal our decision by notifying us at the address above. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Changes to US State Privacy Act Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.