Privacy Policy

I. Introduction to Finstream Privacy Policy

This privacy policy (this "Privacy Policy") describes how Finstream Inc. and our affiliates ("Finstream", "we", "our" or "us") will collect, use, share and store your Personal Information that we collect in connection with your use of our website at https://www.finstreamptyltd.com/ and any of its related or subdomains (the "Website"); in connection with your use of our platform/dashboard mobile software application and any other software application that we license (the "Platform"); where we act as the controller of your Personal Information (as such term is used in applicable data protection laws); and in connection with other occasions where we collect and process your Personal Information, as further detailed in this Privacy Policy.

For purposes of this Privacy Policy, "Personal Information" is information relating to an identified or identifiable individual. For purposes of this Privacy Policy, Personal Information does not include de identified or aggregated information and, to the extent permitted by law, does not include publicly available information that is lawfully made available to the general public or information that is lawfully made available from government records.

This Privacy Policy does not apply to Personal Information collected from employees or candidates for employment with Finstream.

II. Personal Information Collected by Finstream

In order to provide you with the benefits of using our Website and Platform, Finstream collects certain information about you.

Personal Information about You

The following describes representative types of Personal Information that we may collect about you, the circumstances in which this Personal Information is collected, and our purposes for such collection.

Information Collected from Your Browser or Device

We automatically collect your IP address or other unique identifier ("Device Identifier") for the computer, mobile phone, tablet or other device ("Device") you use to access the Website. We use Device Identifiers to administer the Website, help diagnose problems with our servers, analyze trends, and track users' web page movements over time. We also automatically gather and store certain information about your visit from your browser or Device, such as your browser type, operating system type, length of time on the Website, and how you got to the Website.

Information Collected using Cookies or Other Tracking Technologies

We collect certain information through tracking technologies used on the Website such as cookies (data files placed on a Device when it is used to visit the Website), mobile analytics software and pixel tags. We do this to analyze trends, track user movement, gather demographic information, and to generally collect information that we may find insightful or helpful.

Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. However, some features of the Website may not function properly if you refuse cookies.

We use cookies provided by Google Analytics to collect statistical information about the use of the Website. You can learn more at www.google.com/policies/privacy/partners/ and opt out at https://tools.google.com/dlpage/gaoptout. The Website currently does not respond to Do Not Track Signals.

III. How We Use the Information We Collect

We may use the Personal Information we collect from you for a variety of purposes, such as to:

• Provide services through the Platform, authenticate your access, and provide analytics services;
• Respond to your inquiries, questions and requests;
• Communicate with you about your activities on the Website and changes to any Finstream policy or notice;
• Operate, improve, maintain, administer and provide the Website and the Platform;
• Manage our business, including performing accounting, auditing, and other internal functions;
• Evaluate and improve our services, conduct research, learn more about our users and customers, and enhance the customer experience;
• Comply with applicable laws and regulatory requirements;
• Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
• Protect and defend the rights or property of Finstream; and
• For purposes disclosed at the time you provide your Personal Information or otherwise with your consent.

Depending on the context, we may rely on one or more of the following legal bases when processing your Personal Information:

• To fulfill a contract with you or to take steps prior to entering into a contract;
• For our legitimate interests;
• To address our legal obligations; and
• With your consent.

IV. How We Share Information

We may share your Personal Information as disclosed at the time you provide your information and in the following circumstances:

V. Your Rights

You may be entitled to certain rights relating to your Personal Information. For example, you may be able to:

• Request, once per calendar year, certain information regarding our disclosure of your Personal Information to third parties for their own direct marketing purposes;
• Request to know the specific pieces and categories of Personal Information we have collected about you, the categories of sources, our business purpose, and the categories of third parties with whom we shared it;
• Request to delete the Personal Information we have collected about you;
• Request to correct inaccurate Personal Information we have collected about you;
• Receive your Personal Information in a structured, commonly used and machine readable format (data portability);
• Restrict or object to the processing of your Personal Information; and
• Lodge a complaint with a supervisory authority in the place of your residence.

We will not discriminate against you for exercising any of these rights. If you wish to make a request, please reach out to us using the information provided in the "Contact Us" section below.

VI. Opting Out of Communications

At any time, you may choose not to receive marketing and promotional communications from us by (i) selecting the unsubscribe link in the communication that we send you or (ii) contacting us using the information provided in the "Contact Us" section below. Please note that even if you opt out, we may still send you a response when you contact us for reasons related to your use of the Website or Platform.

VII. Children

The Website is not directed to children under the age of 18. Finstream does not knowingly collect, use or disclose Personal Information from anyone under 18 years of age. If we learn that we have collected Personal Information from a child under 18 years, we will use commercially reasonable efforts to delete that information. If you believe that we might have any such information, please contact us using the information provided in the "Contact Us" section below.

VIII. Security of Your Personal Information

We use administrative, physical and technical security safeguards to protect the Personal Information that we collect and process. Our security controls are designed to maintain the confidentiality, integrity and availability of your Personal Information and to protect against reasonably anticipated threats. If you believe that your data is no longer secure, please contact us using the information provided in the "Contact Us" section below.

IX. Retention of Your Personal Information

We will retain your Personal Information for such periods of time required or permitted by law or subject to our retention policies. We consider the following in determining such retention periods: the time required to retain Personal Information to fulfill business purposes; maintaining corresponding business records; improving the performance and quality of the Website and Platform; handling your inquiries; whether we reasonably believe this data will be needed for the handling of any litigation; and whether legal and contractual obligations pose any requirements for data retention.

X. Third Party Sites and Products

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a "Third Party Service"). We do not endorse and are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

XI. Transfers of Information

Given that we are an international business, our use of your Personal Information necessarily involves the transmission of data across borders. When we transfer data across borders, we do so in accordance with applicable data protection laws. For example, when we transfer data from the European Economic Area to jurisdictions that are not deemed to have an adequate level of data protection, we may use Standard Contractual Clauses. In the absence of an adequacy decision or Standard Contractual Clauses or any other right to transfer your data, we may rely on your consent as the basis for such transfer.

XII. Privacy Policy Updates

From time to time, we may update this Privacy Policy. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. By using the Website, the Platform, or by continuing to provide Personal Information to us after these changes are made, you acknowledge and agree to the revised version of the Privacy Policy.