Privacy Policy

Effective Date: August 2, 2024

This Privacy Policy (“Policy”) outlines how Fianellas collects, uses, and processes your personal data when you interact with our website https://fianellas.net (“Website”), web application (“Web App”), mobile application (“App”), and email communications (collectively, the “Services”).

If any specific part of this Policy applies only to certain Services or users in particular countries, we will clearly indicate this.

Applicable Regions:

Australia, Brazil, Canada, Hong Kong, India, Indonesia, Israel, Japan, Malaysia, Mexico, Philippines, Singapore, South Korea, Türkiye, UAE, and USA.

By using our Services, you confirm that you understand and agree to the collection, use, disclosure, and processing of your personal data as described in this Policy.

For U.S. Users

Personal information related to U.S. users collected in connection with our payment services is subject to our Consumer Privacy Notice.

If there is any conflict between this Privacy Policy and the Consumer Privacy Notice, the Consumer Privacy Notice will prevail.

Privacy Policy Summary

This summary provides an overview of how we handle your personal data.

1. Data Controller

The Data Controllers responsible for managing personal information are listed in the applicable section.

For questions, contact: privacy@fianellas.net

2. Data We Collect About You

What Personal Data Means

Personal data refers to information that identifies or could identify an individual. This excludes anonymous data.

2.1 Information You Provide

• Name
• Email address
• Contact information
• Financial and identity verification data

Brazil: CPF numbers may be collected for verification.

New Zealand: Additional data may be required for anti-money laundering compliance.

2.2 Information Collected Automatically

• IP address
• Device information
• Usage data
• Transaction information

2.3 Information from Third Parties

We may receive information from payment providers and financial institutions.

2.4 Information from Social Networks

If you sign in via Apple, Facebook, or Google, we may collect profile information for authentication.

2.5 Sensitive Data

We may collect biometric or identity verification data for compliance and fraud prevention.

2.6 Children’s Data

Our Services are not intended for children. If such data is collected unintentionally, it will be deleted.

3. How We Protect Your Information

We use encryption and security protocols to protect your data.

• Encrypted data storage
• Secure transmission
• Restricted access controls

4. How We Use Your Information

We use personal data for the following purposes:

• Providing and maintaining Services
• Fraud prevention
• Legal compliance
• Customer support
• Service improvement
• Marketing communications

5. Disclosure of Personal Data

We may share your data with:

• Affiliates and partners
• Payment providers
• Analytics providers
• Legal authorities when required
• Fraud prevention agencies

We do not share SMS opt-in data with third parties for marketing purposes.

6. EEA (European Economic Area)

If you are an EEA resident, we may disclose information to the National Bank of Belgium Central Point of Contact (CPC) as required by law.

This includes:

• Account information
• Account balances
• Contract information

This data may be retained for up to ten years.

7. Japan Disclosure

Personal data may be shared with Fianellas Payments Japan K.K. in accordance with legal requirements.

8. Data Storage and Transfers

Your data may be stored in the UK, EU, or other jurisdictions.

We use safeguards such as:

• Standard Contractual Clauses
• Secure data storage
• Restricted access

9. Automated Decision-Making

We may use automated systems for fraud detection and identity verification.

You may request human review of automated decisions.

10. Cookies

We use cookies to:

• Improve functionality
• Enhance security
• Improve user experience

See our Cookie Policy for details.

11. Data Retention

We retain data as required by law and business needs.

Some data may be retained after account closure.

12. Amazon Payment Provider Program

We may share limited data with Amazon when accounts are linked.

You may avoid this by not linking your account.

13. Your Rights

You may have rights including:

• Access to your data
• Correction of inaccurate data
• Deletion requests
• Withdrawal of consent
• Data portability

Contact: privacy@fianellas.net

14. California Privacy Rights

California residents have rights under the California Consumer Privacy Act (CCPA), including:

• Right to know
• Right to delete
• Right to correct
• Right to opt-out

15. Other Jurisdictions

Additional rights may apply based on your country of residence.

16. Third-Party Links

We are not responsible for third-party privacy policies.

17. Changes to This Policy

We may update this Privacy Policy at any time.

The latest version will always be available on our Website.