Effective Date 5/25/2025

FinCliq Inc. Privacy Policy

This Privacy Policy ("Policy") describes how FinCliq Inc. and its affiliates, including FinCliq Loan Services LLC ("FinCliq," "we," "us," or "our") collect, use, and disclose your information when you use our services. It also explains your rights and how you can exercise them.

1. Information We Collect

1.1 Information You Provide

When you interact with FinCliq, either directly or through a partner merchant, we may collect:

Identity Information: Full name, date of birth, address, email, and phone number
Financial Information: Linked bank account details, debit card information, transaction history
Authentication Data: Login credentials, SSN (for verification)
Customer Service Records: Call recordings, support messages, or email correspondence
Marketing Preferences: Your communication settings

1.2 Information We Collect Automatically

We may collect automatically:

Device & Usage Data: IP address, device ID, browser type, operating system, geolocation, click behavior, and browsing activity
Cookies & Tracking: Through cookies, beacons, and similar tools for analytics and personalization

1.3 Information from Third Parties

We may collect information from:

Bank data providers (e.g., Plaid) to verify account activity and deposits
Cookies & Tracking: Through cookies, beacons, and similar tools for analytics and personalization
Merchant partners to complete transactions and verify your purchase
Advertising partners for analytics and personalization

1.4 Additional Financial and Platform Activity Data

We may also collect and generate additional information related to your use of specific FinCliq features, including:

Payment Authorization Data: Autopay enrollment status, recurring payment schedules, payment retries, and authorization metadata.
Stored Value Data: FinCliq Balance amounts, transaction activity, credits, and adjustments.
Savings Circles Data: Contribution history, participation status, rotation position, and missed or failed contributions.
Gift Card Data: Gift card purchases, delivery confirmation, redemption status, and fraud-prevention signals.
Membership Data: Subscription status, benefit eligibility, and usage associated with FinCliq+.
Late Fee and Delinquency Data: Payment failures, late fee assessments, retry attempts, account delinquency status, and related servicing records.

2. How We Use Your Information

We use your information to:

Verify your identity and eligibility
Evaluate and offer payment plans and other platform features
Process one-time and recurring payments
Administer FinCliq Balance, Savings Circles, and membership programs
Fulfill gift card purchases and digital deliveries
Prevent fraud, misuse, and unauthorized activity
Power automated systems that assess eligibility, purchase power, and plan availability
Communicate with you about your account and services
Personalize features, offers, and user experience
Comply with legal and regulatory obligations

3. How We Share Your Information

Depending on the services you use, we may share your information with:

Payment processors and financial partners to process one-time and recurring payments
Gift card issuers and fulfillment partners to deliver digital products
Banking and data aggregation providers to verify account activity
Alternative credit and risk evaluation providers, including Consulytica
Analytics and fraud-prevention vendors to protect the Platform
If an account becomes delinquent, enters default, or otherwise remains unpaid, FinCliq may share certain personal, financial, and account information with third-party collection agencies or recovery partners for the purpose of servicing, collecting, or resolving outstanding obligations.

4. Your Choices & Rights

You may:

Access or update your information via your account
Opt out of marketing communications
Merchant partners to fulfill purchases and offer personalized services
Disable cookies via your browser
Withdraw consent to data collection (which may affect your access to Services)
Request deletion or restriction of your data, subject to legal exceptions

California and Oregon residents have additional rights outlined in our state-specific notices [available upon request].

5. Data Retention

Data Retention by Category
We retain personal information based on the type of data and purpose for which it was collected, including:

Account and identity data: retained while your account is active and as required by law
Payment and transaction records: retained for compliance, accounting, and dispute resolution
Stored value and balance data: retained while balances exist and for a reasonable period thereafter
Savings Circles participation data: retained to administer contributions and resolve disputes
Marketing and analytics data: retained until you opt out or as permitted by law

Retention periods may be extended where required by legal, regulatory, or risk management obligations.

6. Security Practices

We use:

Encryption and secure servers
Role-based access control
Monitoring and anomaly detection tools
Authentication and Security Data: We collect and process one-time passcodes, verification timestamps, device identifiers, and contact information (such as phone number or email) to enable multi-factor authentication, account security, fraud prevention, and access control.

However, no system is completely secure. We encourage you to protect your account credentials and report suspicious activity.
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7. Automated Decision-Making

FinCliq uses automated systems and algorithms to evaluate eligibility, purchase power, plan availability, and participation in certain platform features. These systems may consider financial, transactional, and behavioral data. You may contact us to request additional information or review of certain decisions, subject to applicable law.

8. Children’s Privacy

FinCliq does not knowingly collect data from individuals under 18. If we learn we’ve collected data from a minor, we will delete it promptly.

9. Updates to This Policy

We may update this Policy to reflect changes in our practices. Updates will be posted on our website with an effective date. Your continued use of the Platform after updates constitutes consent.

10. Contact Us

For privacy-related inquiries:

Email: info@fincliq.io

This Privacy Policy is designed to comply with applicable U.S. privacy laws including the Gramm-Leach-Bliley Act (GLBA), California Consumer Privacy Act (CCPA), and Oregon Consumer Privacy Act (OCPA).