Privacy Policy

Information you provide to us.

Personal information you may provide to us through the Service or otherwise includes:

• Contact data: such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

• Demographic Information: such as your city, state, country of residence, postal code, and age.

• Profile data: such as the username and password that you may set to establish an online account with us, preferences, and any other information that you add to your account profile.

• Communications: that we exchange with you, including when you contact us with questions or feedback, through the Service, social media, or otherwise.

• Marketing data: such as your preferences for receiving our marketing communications and details about your engagement with them.

• Financial and Payment information: needed to complete transactions, including payment card information or bank account number.

• Professional or employment-related information: if you submit your resume or other information relating to employment or potential employment.

• Other data: not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources.

We may combine personal information we receive from you with personal information we obtain from other sources where you have provided consent or as otherwise legally permitted or required under applicable law, such as:

• Public sources: such as government agencies, public records, social media platforms, and other publicly available sources.

• Data providers: such as information services and data licensors that provide demographic and other information.

• Marketing partners: such as joint marketing partners and event co-sponsors.

Automatic data collection.

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data: such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data: such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies.

Like many online services, we use the following technologies:

• Cookies: which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.

• Local storage technologies: like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons: also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

• Website analytics or tracking technologies: such as Google Analytics, to collect personally identifiable information about your activities over time and across different websites, which may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies.

Service delivery.

We may use your personal information to:

• provide, operate and improve the Service and our business;

• establish and maintain your user profile on the Service;

• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;

• understand your needs and interests, and personalize your experience with the Service and our communications; and

• provide support for the Service, and respond to your requests, questions and feedback.

Research and development.

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated or other non-personally identifiable data from personal information we collect to build predictive models that use anonymized data to improve the Service as well as future targeted promotions and advertising.

Direct marketing.

We may send you Functional FI-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection.

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

California residents' rights.

Subject to certain exceptions and limitations under the CCPA, California residents have the following rights:

• Right to Know: You have the right to request that we disclose to you: (1) the categories of personal information we have collected about you; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, or sharing personal information; (4) the categories of third parties to whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you.

• Right to Delete: You have the right to request deletion of your personal information that we have collected or maintain, subject to certain exceptions.

• Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you.

• Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your personal information. We do not "sell" or "share" (as defined by the CCPA) your personal information.

• Right to Limit Use of Sensitive Personal Information: You have the right to direct us to limit our use of your sensitive personal information to certain purposes set forth in the CCPA.

• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your CCPA rights.

How to exercise your California rights.

To exercise your rights described above, please submit a request by emailing us at hello@functionalfi.com. We will need to verify your identity before processing your request. In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Legal bases for processing.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include:

• Consent: where you have given us consent to process your personal data for a specific purpose.

• Contract: where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

• Legal obligation: where our use of your personal data is necessary for compliance with a legal obligation.

• Legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party. Our legitimate interests include improving and developing our services, preventing fraud, ensuring network and information security, and enabling us to provide our services.

Your EEA/UK rights.

Individuals in the EEA and UK have additional rights under applicable law, including the right to:

• access the personal data we hold about you;

• have us correct inaccurate personal data we hold about you;

• request deletion of your personal data;

• request that we restrict processing of your personal data;

• object to processing of your personal data on grounds relating to your particular situation;

• receive your personal data in a structured, commonly used, and machine-readable format, and to transfer your personal data to another controller (data portability); and

• withdraw any consent you have given, without affecting the lawfulness of processing before your withdrawal.

Data transfers.

The personal data we collect from you may be transferred to, and stored at or processed in, countries outside your country of residence, including the United States, which may have different data protection rules than those of your country.

We transfer personal data to countries outside the EEA and UK only when we have appropriate safeguards in place, such as standard contractual clauses approved by the European Commission, or where an exception applies.

How to exercise your EEA/UK rights.

To exercise your rights, please submit a request by emailing us at hello@functionalfi.com. We will respond to your request within the time period required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes and to complete any transactions that you began prior to your request.

If you have concerns about how we handle your personal data, you also have the right to lodge a complaint with the supervisory authority in your country of residence.