FundTek Capital Group. Privacy Policy – Because your privacy is important to FundTek Capital Group. and its subsidiaries (collectively referred to as “FundTek”), we created a Privacy Policy that discloses to you the information we collect, how it is used and shared, and to help you to make informed choices when you visit the FundTek website, FundTekCapitalGroup.com (the “Site”). The Site is owned and operated by FundTek. References to “we”, “us” and “our” mean FundTek, including any company we control. This Site may use cookies, web beacons, and similar technologies to facilitate administration and navigation, to better understand and improve our products and services (“Products and Services”), to determine and improve the user experience here or elsewhere, and to provide you with a customized online experience. By accessing or using this Site, and/or accepting our Terms of Service, you agree to this Privacy Policy. We may change this Privacy Policy from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. If you have any inquiries about this Privacy Policy or how we use your information, please contact us.
1. What Information We Collect and How We Collect It. The type of information we collect depends on how you use the Site and how you interact with us. “Personal Information” means any data which can be associated with you as an individual, either directly or indirectly, and is collected on either a voluntary or involuntary basis. The Personal Information we collect via the Site may include:
The Site is not intended to store or transmit “special categories” or “protected classifications” of Personal Information, such as details about your race, color, ancestry, national origin, citizenship, religion, creed, medical condition, physical or mental disability, sex life, sexual orientation, gender identity, gender expression, political opinions, veteran or military status, genetic information, marital status, criminal convictions and offenses.
2. How We Collect Personal Information
We collect information from you in three different ways.
a) Personal Information you provide to us.
If you provide information on our “Get Approved” “Get in Touch” or “Apply Now” page through the Site, you will provide us with your identity, contact information, IP address and any other information contained within any attachments you submit (e.g. CV’s, resumes and cover letters, sale inquiries, etc.). This data is collected through direct solicitation and your voluntary submissions. You will also provide us with Personal Information when you correspond with us. We will track basic analytics (for example, open rates and click throughs) and may embed tracking codes in our regular daily email correspondence.
b) Personal Information we collect automatically as you navigate the Site.
The Site uses a third-party traffic measurement service to analyze how visitors use the Site, and may use cookies, web beacons, embedded scripts (described below) or other similar mechanisms to automatically collect web site usage information, to, among other purposes, deliver advertisements, in which you might be interested, prevent you from seeing the same advertisements too many times, and to conduct research. Cookies, web beacons and embedded scripts and other similar mechanisms used to collect web site usage information from third-party traffic measurement services are governed by their respective privacy policies and not this Privacy Policy.
In addition, as you use the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Google Analytics to help us analyze user habits while visiting our Site. The data gathered from cookies may be transmitted to Google servers in the United States. We employ IP address anonymization to ensure that there is no direct reporting of individual user IPs as part of this process. The information will be used by Google only for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on behalf of FundTek. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.
We may use any of the following, or other, cookies individually or in combination:
Cookie name What it is used for
Google Analytics: website analytics and visitor tracking
YouTube: user viewing preferences
You can remove cookies from your computer through the browser settings. Please note however that doing so may affect, limit or degrade your ability to use of some features on the Site and other websites. Management of cookie settings varies from one browser to another, and the “Help” menu of your web browser should provide instructions how to manage cookies.
3. How and Why We Use Personal Information
a) You have given us permission to do so.
If you subscribe to our mailing list, we will send you updates and marketing information that you have consented to receive. Similarly, if you contact us with a question or comment, we may need your contact, identity, technical and/or usage information to respond.
b) To Respond to You.
When you contact us, we may collect information that identifies you (such as your name, address and a phone number) along with additional information we need to help us respond to the reason you contacted us and/or to answer your question or respond to your comment. We retain this information to assist you in the future and to improve our customer service, products, Services, and promotions.
c) To Contact You.
We may contact you with offers and information about our Products and Services and our affiliates, including to inform you about our promotions and special offers that may be tailored to your interests. You may opt out of receiving commercial messages (excluding transactional messages) from us by following the instructions contained in our electronic messages or by contacting us as set out below.
e) To Better Understand Our Customers and to Improve Our Services.
In the course of providing our Products and Services, we may collect information on our users’ demographics, interests and behavior and analyze that data. We do this to better understand and serve our users, and to improve our Products and Services.
f) We have a legitimate interest (reasonable business purpose) for doing so.
We will use your information for our legitimate business reasons where doing so will not unduly affect your rights, including the use of cookies and personal data we collect through account registration (email, phone number, address) to improve the website and for marketing and advertising services. This includes but may not be limited to email, text, SMS, social media, and programmatic advertising.
We will use your technical information to:
Make the Site available, to improve it, to conduct system maintenance, support, troubleshooting, reporting and to host data; Ensure that the Site is secure; Analyze how users interact with the Site; andAddress technical issues you may experience with the Site. We may also use any or all of the information above to administer and manage our business in general, which include engaging in “Know Your Customer” and anti-money laundering checks as required by law, regulation, or best business practices. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should, therefore, stop processing your data, please let us know)
We need to comply with legal or regulatory obligations.
In certain circumstances, we may need to retain or use your data to comply with laws or regulations.
4. Privacy and Access Choices Available to YouChoices with Respect to Cookies and Similar Technologies.
You may block cookies and similar technologies in your browser or device settings, as and if permitted by such device.
Choices with Respect to Interest – Based Advertising.
ou may opt out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative, Digital Advertising Alliance and Digital Advertising Alliance of Canada.
Data Access. Subject to applicable law, you may also have a right to access, update, and correct inaccuracies in other personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in the personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Email Promotions. You may opt out of receiving commercial email, text message, and other electronic messages from us (excluding transactional messages) by following the instructions contained in those messages.
5. Other Important Information Children Under the Age of 13.
Our Site is not intended for children under 13 years of age. No one under age 13 may use or direct any information to the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Site, use any of its features, subscribe to our mailing list, use any of the interactive links or post anything on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verified parental consent, we will delete that information.
International transfers. This Site is hosted on servers located in the United States. We will endeavor to meet those data protection laws and regulations (including the General Data Protection Regulation, or “GDPR,” when and as applicable) to which we may be subject.
General Data Protection Regulation. General Data Protection Regulation (“GDPR”) was passed by the European Parliament and establishes a standard for data privacy for all member states of the European Economic Area (“EEA”) (“EU”). Its purpose is to give EEA residents (described as “data subjects” by the GDPR) certain rights over their Personal Information, including, the: Right of access: Individuals can ask for a copy of the Personal Information retained about them and an explanation of how it is being used. Right to rectification: Individuals have the right to correct, revise or remove any of the Personal Information retained about them at any time. Right to be forgotten: Individuals can ask to delete their Personal Information. At your request, we will remove your contact information from the system, and we will not contact you again. Right to restrict processing: If an individual believes, for example, that their Personal Information is inaccurate or collected unlawfully, the individual may request limited use of their Personal Information. Right of portability: Individuals have the right to receive their Personal Information in a structured, commonly used and machine-readable format. Right to object: Where an individual decides that they no longer wish to allow their Personal Information to be included in analytics or to receive direct marketing emails or other personalized (targeted) marketing content at any time, the individual may opt out of use of their data for these purposes. If you are a data subject falling under the scope of the GDPR, you can exercise the above rights. Please note that these rights are not absolute, and limitations/exceptions may apply in some cases. In respect of transfers outside of the Company, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your Personal Information; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield. You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.
Data Security.
The safety of your Personal Information is important to us, and we use various technical and organizational measures to secure it. However, the transmission of information via the Internet is not completely secure, and unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Although we take commercially reasonable measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You acknowledge and agree that you are solely responsible for maintaining the security and confidentiality of your account username and password.
How Long We Keep Personal Information.
We will retain your Personal Information only for as long as it necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we processed the data and whether we those purposes may be achieved by another means, and the applicable legal requirements.
Changes to this Privacy Policy or your data.
From time to time, we may amend this Privacy Policy. We will post any update to this Privacy Policy on the Site. We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by means of a notice on the Sites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.
Information We Collect
The FundTek Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“), but does not include in particular: Publicly available information from government records; Deidentified or aggregated consumer information; Information excluded from the CCPA’s scope, like: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the California Financial Information Privacy Act (FIPA); and Driver’s Privacy Protection Act of 1994. The Site has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and email address. YESB. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, physical characteristics or description, address, telephone number, and payment card information. Some personal information included in this category may overlap with other categories. YESC. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).NOD. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YESE. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NOF. Internet or other similar Platform activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YESG. Geolocation data. Physical location or movements. YESH. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NOI. Professional or employment-related information. Current or past job history or performance evaluations. NOJ. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NOK. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES Personal information does not include: Publicly available information from government records; Deidentified or aggregated consumer information; Digital images or photographs not used for identification; Information excluded from the CCPA’s scope, for example: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. FundTek obtains the categories of personal information listed above from the following categories of sources: Directly from you. For example, from forms you complete, products you purchase, or information you choose to post or share. Indirectly from you. For example, from observing your actions on the FundTek Platform.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following purposes: To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Products or Services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a Product or Service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns; To provide, support, personalize, and develop our Platform, Products, and Services; To create, maintain, customize, and secure your account with us; To process your requests; To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses; To personalize your FundTek Platform experience and to deliver content and Product and Service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law);To help maintain the safety, security, and integrity of our Platform, Products and Services, databases and other technology assets, and business; For testing, research, analysis, and product development, including to develop and improve our Platform, Products, and Services; To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; As described to you when collecting your personal information or as otherwise set forth in the CCPA; and To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FundTek’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by FundTek about FundTek users is among the assets transferred. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Deletion Request Rights You have the right to request that FundTek delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights) we will delete and direct our service providers to delete your personal information from our records, unless an exception applies. Even if verifiable, we may nonetheless deny your deletion request if retaining the information is necessary for us or our service provider(s) to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; Debug products to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; Comply with a legal obligation; or Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
EXERCISE PERSONAL INFORMATION PORTABILITY To exercise the right to delete your personal information stored by FundTek, you may submit a request to us by visiting:
DO NOT SELL MY PERSONAL INFORMATION
As noted above we do not sell your information to third parties. We will retain your opt-out request in the event our practices change in the future. Should your email address change, please submit a new request with your new email address.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-In data and consent; this information will not be shared with any third parties
Verification Requirement for Requests
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access, data portability, or deletion twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will acknowledge receipt of your request within 10 days and will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will notify and inform you of the reason and extension period in writing. If we receive a verifiable request to opt-out or Do Not Sell My Personal Information from you, we will act upon that request within 15 days from the date we receive that request. If you have an account with us, we will deliver our written response to that account electronically. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance (e.g., an excel spreadsheet that has been converted into a changed-locked pdf).We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to Our Privacy Notice
FundTek reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the FundTek Platform and update the notice’s effective date.
General Data Protection Regulation (“GDPR”)
For those persons located in the United Kingdom and within the European Union and/or for data subject to the GDPR or UK data protection laws the following policy applies:
Technical information when you use our website. When you consent to our use of cookies, we collect information about how you use our website. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our cookie policy.
Where is my data stored?
Where we store your data will vary depending on the location of the group company you are interacting with. Whenever we transfer your personal information outside of the UK and the EU including between our group companies, we ensure it receives additional protection as required by law. To keep this privacy policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.
