Version 01, May 25, 2023
FinHub is a part of SEPA Cyber Group, which has spent considerable resources developing a comprehensive financial technology hub. Our mission is to provide companies with scalable and customisable solutions that are easy to deploy into existing systems. FinHub is an easy-to-use product that enables businesses to add and remove practical modules with a single click. Our platform is flexible, meaning we can adjust it to the specific needs of our customers.
This Privacy Notice describes how we collect and use your personal information in relation to FinHub websites, applications, products, services, events, and experiences that reference this Privacy Notice (together, “ FinHub Offerings”).
This Privacy Notice does not apply to the “content” processed, stored, or hosted by our customers using FinHub Offerings in connection with an FinHub account. See the agreement governing your access to your FINHUB account and the FINHUB Data Privacy FAQ for more information about how we handle content and how our customers can control their content through FinHub Offerings. This Privacy Notice also does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy notice.
- Personal Information We Collect
- How We Use Personal Information
- How We Share Personal Information
- Location of Personal Information
- How We Secure Information
- Access and Choice
- Children’s Personal Information
- Third Party Sites and Services
- Retention of Personal Information
- Contacts, Notices, and Revisions
- Additional Information for Certain Jurisdictions
- Examples of Information Collected
Personal Information We Collect
We collect your personal information in the course of providing FINHUB Offerings to you.
Here are the types of information we gather:
- Information You Give Us: We collect any information you provide in relation to FINHUB Offerings. Click here to see examples of information you give us.
- Automatic Information: We automatically collect certain types of information when you interact with FINHUB Offerings. Click here to see examples of information we collect automatically.
- Information from Other Sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources. Click here to see examples of information we collect from other sources.
How We Use Personal Information
We use your personal information to operate, provide, and improve FINHUB Offerings. Our purposes for using personal information include:
- Provide FINHUB Offerings: We use your personal information to provide and deliver FINHUB Offerings and process transactions related to FINHUB Offerings, including registrations, subscriptions, purchases, and payments.
- Measure, Support, and Improve FINHUB Offerings: We use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop FINHUB Offerings.
- Recommendations and Personalization: We use your personal information to recommend FINHUB Offerings that might be of interest to you, identify your preferences, and personalize your experience with FINHUB Offerings.
- Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information. For example, we collect bank account information from FINHUB Marketplace sellers for identity verification.
- Communicate with You: We use your personal information to communicate with you in relation to FINHUB Offerings via different channels (e.g., by phone, email, chat) and to respond to your requests.
- Marketing: We use your personal information to market and promote FINHUB Offerings.
- Fraud and Abuse Prevention and Credit Risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, FINHUB, and others. We may also use scoring methods to assess and manage credit risks.
- Purposes for Which We Seek Your Consent: We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.
How We Share Personal Information
Information about our customers is an important part of our business and we are not in the business of selling our customers’ personal information to others. We share personal information only as described below.
- Transactions Involving Third Parties: We make available to you services, software, and content provided by third parties for use on or through FINHUB Offerings. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party. For example, you can order services, software, and content from sellers using the FINHUB Marketplace and we provide those sellers information to facilitate your subscription, purchases, or support.
- Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include: delivering FINHUB hardware, sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process that information in accordance with this Privacy Notice and as permitted by applicable data protection law.
- Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the individual consents otherwise). Also, in the unlikely event that FINHUB or substantially all of its assets are acquired, your information will of course be one of the transferred assets.
- Protection of Us and Others: We release account and other personal information when we believe release is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of FINHUB, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
- At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.
Location of Personal Information
SEPA Cyber Group is located in the Bulgaria, EU, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with FINHUB Offerings, your personal information may be stored in or accessed from multiple countries, including countries from EEA, UK and the United States. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by applicable data protection FINHUB.
How We Secure Information
At FINHUB, security is our highest priority. We design our systems with your security and privacy in mind.
- We maintain a wide variety of compliance programs that validate our security controls. Click here to learn more about our compliance programs.
- We protect the security of your information during transmission to or from FINHUB websites, applications, products, or services by using encryption protocols and software.
- We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.
- We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.
Access and Choice
You can view, update, and delete certain information about your account and your interactions with FINHUB Offerings. Click here for a list of examples of information that you can access. If you cannot access or update your information yourself, you can always contact us for assistance.
You have choices about the collection and use of your personal information. Many FINHUB Offerings include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of certain FINHUB Offerings.
- Account Information: If you want to add, update, or delete information related to your account, please go to the FINHUB Management Console. When you update or delete any information, we usually keep a copy of the prior version for our records.
- Communications: If you do not want to receive promotional messages from us, please unsubscribe or adjust your communication preferences in the FINHUB Management Console or the FINHUB Email Preference Center. If you do not want to receive in-app notifications from us, please adjust your notification settings in the app or your device.
- Cookies Preferences: You can change your cookie preferences on FINHUB sites at any time by clicking Cookie Preferences in the footer of the FINHUB site. You can also manage cookies through your browser settings. The “Help” feature on most browsers and devices will tell you how to remove cookies from your device, how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
- Sellers and SEPA Cyber Group Partners: Sellers and SEPA Cyber Group Partner Network members can add, update, or delete information in the FINHUB Marketplace
Children’s Personal Information
We don’t provide FINHUB Offerings for purchase by children. If you’re under 18, you can’t use FINHUB Offerings.
Third Party Sites and Services
FINHUB Offerings may embed content provided by others or include links to other websites and applications. These companies may collect information about you when you interact with their content or services. We are not responsible for the practices of these companies. Please consult their privacy policies to learn about their data practices .
Retention of Personal Information
We keep your personal information to enable your continued use of FINHUB Offerings, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.
Contacts, Notices, and Revisions
If you have any concerns about privacy at FINHUB, please contact us with a thorough description, and we will try to resolve the issue for you.
For any prospective or current customers of FINHUB, our mailing address is: email@example.com
Contact details for specific jurisdictions including the European Economic Area, the UK and Switzerland, can be found in “Additional Information for Certain Jurisdictions” below.
If you interact with FINHUB Offerings on behalf of or through your organization, then your personal information may also be subject to your organization’s privacy practices, and you should direct privacy inquiries to your organization.
Our business changes constantly, and our Privacy Notice may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Notice was posted. Unless stated otherwise, our current Privacy Notice applies to all personal information we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.
Additional Information for Certain Jurisdictions
We provide additional information about our controllers and data protection officers (as applicable), the privacy, collection, and use of personal information of prospective and current customers of FinHub Offerings located in certain jurisdictions.
European Economic Area, UK, Switzerland
Controller of Personal Information. When SEPA Cyber Group is the provider of an FinHub Offering, SEPA Cyber Group is the data controller of personal information collected or processed through the FinHub Offering.
SEPA Cyber Group is also the authorized representative of FinHub in the EEA.
Processing. We process your personal information on one or more of the following legal bases:
as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide FinHub Offerings, to respond to requests from you, or to provide customer support;
where we have a legitimate interest, as described in this Privacy Notice (see How We Use Personal Information above);
as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
with your consent.
Information We Retain After Your Account is Closed.
If you decide to terminate your agreement and close your FinHub account, we will retain your content for a period of up to 90 days after account closure, during which you may still access part of the FinHub Management Console in order to retrieve your billing documents and to contact customer support. During this period, you may also decide to reopen your FinHub account. At the end of this period, we will delete any content remaining in your account.
After account closure, we may need to keep certain information for an additional period of time for legal and legitimate business purposes. For example, we may retain personal information such as your contact information (e.g., name, email address, physical address) and any invoices that FinHub has sent to you (e.g., record of purchases, applicable discounts, and tax information) for tax and accounting purposes. If applicable, FinHub may also retain records of communications with you, as well as relevant logs (e.g., a log of your account closure) for dispute resolution purposes. We further may keep records for preventing fraud and ensuring security, for example in case of misuse of our services or violation of our terms.
Your Rights. Subject to applicable law, you have the right to:
ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
request that inaccurate personal information is corrected;
request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
request us to restrict the processing of personal information where the processing is inappropriate;
object to the processing of personal information; and
request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means.
Questions and Contacts. If you wish to do any of these things or have a data-protection related question, and you are an FinHub customer, please contact us here. If you are not an FinHub customer, please contact us here.
The data protection officer for SEPA Cyber Group can be contacted at firstname.lastname@example.org
You can also lodge a complaint with our principal supervisory authority, the Commission Nationale pour la Protection des Données in Luxembourg, or with a local authority.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Cookies. Please refer to our Cookie Notice.
Transfers outside of the EEA. When we transfer your personal information outside the EEA we do so in accordance with the terms of this Privacy Notice and applicable data protection law.
Examples of Information Collected
Information You Give Us
You provide information to us when you:
- search for, subscribe to, or purchase FINHUB Offerings;
- create or administer your FINHUB account (and you might have more than one account if you have used more than one email address when using FINHUB Offerings);
- configure your settings for, provide data access permissions for, or otherwise interact with FINHUB Offerings;
- register for or attend an FINHUB event;
- purchase or use content, products, or services from third-party providers through the FINHUB Marketplace (or other similar venues operated or provided by us);
- offer your content, products, or services on or through FINHUB Offerings or the FINHUB Marketplace (or other similar venues operated or provided by us);
- communicate with us by phone, email, or otherwise;
- complete a questionnaire, a support ticket, or other information request forms;
- post on FINHUB websites or participate in community features; and
- employ notification services.
Depending on your use of FINHUB Offerings, you might supply us with such information as:
- your name, email address, physical address, phone number, and other similar contact information;
- payment information, including credit card and bank account information;
- information about your location;
- information about your organization and your contacts, such as colleagues or people within your organization;
- usernames, aliases, roles, and other authentication and security credential information;
- content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us;
- your image (still, video, and in some cases 3-D), voice, and other identifiers that are personal to you when you attend an FINHUB event or use certain FINHUB Offerings;
- information regarding identity, including government-issued identification information;
- corporate and financial information; and
- VAT numbers and other tax identifiers.
We collect information automatically when you:
- visit, interact with, or use FINHUB Offerings (including when you use your computer or other device to interact with FINHUB Offerings);
- download content from us;
- open emails or click on links in emails from us; and
- interact or communicate with us (such as when you attend an FINHUB event or when you request customer support).
Examples of the information we automatically collect include:
- network and connection information, such as the Internet protocol (IP) address used to connect your computer or other device to the Internet and information about your Internet service provider;
- computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting;
- the location of your device or computer;
- authentication and security credential information;
- content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads;
- FINHUB Offerings metrics, such as offering usage, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs;
- the full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and FINHUB Offerings, content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs);
- email addresses and phone numbers used to contact us; and
- identifiers and information contained in cookies (see our Cookie Notice).
Information from Other Sources
Examples of information we receive from other sources include:
- marketing, sales generation, and recruitment information, including your name, email address, physical address, phone number, and other similar contact information;
- subscription, purchase, support, or other information about your interactions with products and services offered by us, our affiliates (such as FINHUB training courses), or third parties (such as products offered through the FINHUB Marketplace) in relation to FINHUB Offerings;
- search results and links, including paid listings (such as Sponsored Links); and
- credit history information from credit bureaus.
Information You Can Access
Examples of information you can access through FINHUB Offerings include:
- your name, email address, physical address, phone number, and other similar contact information;
- usernames, aliases, roles, and other authentication and security credential information;
- your subscription, purchase, usage, billing, and payment history;
- payment settings, such as payment instrument information and billing preferences;
- tax information;
- email communication and notification settings; and
- if you participate in the FINHUB Marketplace or SEPA Cyber Group Network (or other similar venues operated or provided by us), your account, your status, subscriptions, and other information.
Customers can access the information above through FINHUB Offerings, such as the FINHUB Management Console (including the My Account, Billing Dashboard, Bills, Payment Methods, Payment History, Preferences and Tax Settings pages), the FINHUB Email Preference Center and FINHUB Marketplace.