FINKS PRIVACY POLICY

Version: 3.0

Effective Date: 2025-01-26

This Privacy Policy explains how Finks collects, uses, and protects your information. By using Finks, you agree to the practices described below.

Introduction

Finks ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, store, and protect your personal information, as well as your rights under applicable privacy regulations. By accessing or using Finks, you acknowledge and agree to the practices described herein.

1. Information We Collect

To provide and improve our services, we collect both personal and technical data either directly from you or automatically through your use of the platform.

A. Information You Provide

You may voluntarily submit information to us when registering, updating your profile, uploading content, or communicating with us. This includes:

  • Account registration details (e.g., name, email, password)
  • Portfolio or financial data submitted manually or via file upload (e.g., tickers, holdings, CSVs)
  • Prompts, questions, or insights entered into our platform during usage

B. Information We Collect Automatically

When you use Finks, we automatically collect:

  • Usage activity and interaction logs (e.g., searches, clicks, insights viewed)
  • Device and browser metadata (e.g., operating system, screen resolution)
  • IP address and inferred geographic location (e.g., city, region, country)

This data is used to maintain platform performance, personalize experiences, and ensure compliance with jurisdictional regulations.

2. How We Use Your Information

Finks uses your data to:

  • Operate and maintain core platform functionality
  • Provide the services you request and improve the quality of our services
  • Deliver insights and personalize content based on your usage
  • Communicate important product or policy updates
  • Monitor usage to detect fraud, misuse, or security threats

We do not sell your personal data. We may share data with service providers and partners solely to operate, support, and improve our services, in accordance with this Privacy Policy.

3. Third-Party Services

We rely on select third-party providers for infrastructure, analytics, and communication delivery. These providers are contractually bound to confidentiality and are only given access to data necessary for their function.

Financial Institution Data (Plaid)

If you use features that connect to your financial institutions, Finks uses Plaid Inc. (“Plaid”) to connect to your financial institutions and retrieve financial account information with your permission. When you use these features, your personal and financial data may be transferred to, stored by, and processed by Plaid in accordance with Plaid’s End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.

4. Data Security

We implement commercially reasonable technical and organizational safeguards to protect your data, including:

  • Encryption of data in transit and at rest
  • Access controls based on user roles
  • Periodic security reviews and vulnerability assessments

While no system is immune to threats, we are committed to mitigating risk and addressing incidents promptly.

5. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes described in this policy or to comply with applicable laws. Specifically:

  • Data is retained while your account remains active
  • Upon deletion of your account, your data will be deleted within 30 days, unless a longer retention period is required by law.

6. Your Rights and Choices

As a user of Finks, you may:

  • Access and update your personal information
  • Request deletion of your account and associated data
  • Opt out of marketing emails via unsubscribe links

To make a request, contact victor.lei@finks.ai.

7. International Transfers

Finks operates in Canada. If you access the platform from outside Canada, your data may be transferred to and processed in jurisdictions that may have different privacy laws.

8. Your Rights Under Local Laws

If you are a resident of California, you may have additional privacy rights, including:

  • The right to access, correct, or delete your personal data
  • The right to opt out of the sale or sharing of personal data (California)
  • The right to data portability

To exercise these rights, contact victor.lei@finks.ai. We will respond in accordance with applicable legal timelines.

9. Automated Decision-Making

Finks does not make legally binding decisions based solely on automated processing or profiling. Our AI tools generate research insights to support your decision-making, not to replace it.

10. Children’s Privacy

Finks is not intended for individuals under 18. We do not knowingly collect or process personal data from minors. If we learn such data has been collected, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy periodically. If material changes are made, we will notify users via email or in-app messages. Continued use of the platform after such updates constitutes acceptance of the revised policy.

12. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy, please contact:

Victor Lei

Privacy Officer – Finks

Email: victor.lei@finks.ai