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    • Finn of America, Inc.
    Mobile App and Website Privacy Policy

    ‍This Privacy Policy was last updated on August 31, 2023.


    This Privacy Policy (the “Privacy Policy”) describes how Finn of America, Inc. and affiliates (“Finn of America”, “us”, “our”, or “we”) uses the Personal Information (defined below) that we collect, receive, maintain, store about you. This Privacy Policy applies to the website (the “Website”), Program’s mobile application available through the Apple App Store, the Google Play Store  any other location to download (directly from our Website or other platform) (“Mobile App”), websites, webpages, social media pages, and electronic communications from which it is linked or on which it appears (collectively, the “Services”). 

    Please note that different or additional terms – including, but not limited to, the subscription agreement that governs your use of our vehicle service (the “Program”) – may apply to specific services or features offered on the Service or specific uses of the Service (“Specific Agreements”).  This Privacy Policy applies to all users and visitors of our Services, including the individuals who have been approved by Finn of America to participant in the Program and have accepted this Agreement by clicking “Accept” on the “Accept terms and conditions” page of the Mobile App or Website (“Subscribers”).


    1. What Personal Information We Collect About You

    We may collect a range of Personal Information about you.  “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to an individual.  When we combine Personal Information with other information (i.e. information that does not, on its own, identify you), we treat the combined information as Personal Information.  Examples of the types of Personal Information we may collect include:

    • Contact Information – If you submit an inquiry or apply to become a Subscriber, we may collect your contact, mailing and other information.  This may include your name, email address, phone number, date of birth. 
    • Financial Information – Certain components of our Services may require you to provide us with your payment or financial information including your credit card number, expiration date, security code, shipping address and billing address, which constitutes Personal Information. We, with support from our authorized service providers (see Section 4 of this Privacy Policy below), will only use your payment information to process your payments to provide you with the products or items you ordered through our Services.
    • Driver License numbers, Driving Records & Credit Scores.  We may collect Personal Information from you to ensure your insurability as a Subscriber of our Program and your suitability for using our Services.  Such Personal Information may include, your driver license numbers, driving records or motor vehicle reports, FICO Scores and/or Vantage Scores
    • Usage Information – We may also collect usage and device information when you visit our Services.  This may include information about the browser, operating system, and/or device identifier for the device you are using, your internet service provider (“ISP”) and internet protocol (“IP”) information, your navigation activity on the Services, as well as the websites that you came from and the Services you visit when you leave. 


    2. How We Collect Personal Information

    We may collect Personal Information in a variety of ways.  We may collect Personal Information directly from you; for example, when you register to be a Subscriber of our Program, send us an inquiry on our Website or Mobile App, or otherwise interact with us through the Services. 

    We may also collect Personal Information from third parties.  For example, we work with business partners, subcontractors, advertising networks, analytics providers, and search information providers in order to provide and operate our Services and Program.  These may include identity verification services, consumer reporting agencies or government databases.

    We may also collect Personal Information from you passively.  Our Services uses tracking tools like cookies, pixels, and web beacons.  We may use these tools both on our Services and in emails that we send to you.  Through these tools, we collect Personal Information about users over time.  This collection includes usage and browser information.  For more information about the trackers that we use, please see Section 5 of this Privacy Policy.  Additionally, if you enable location data on your device, this data will be collected passively based on the location settings on your device.


    3. How We Use Your Personal Information

    Our primary purpose in collecting your Personal Information is to provide you with a secure, safe, efficient and customized experience. We will use your Personal Information to provide you with our Services, manage your Subscriptions, respond to your requests and inquiries, send you communications, and otherwise enable your interactions with our Services.  Please see a table below for some example of how we plan to use Subscribers’ Personal Information.


    Category of Personal Information
    		Purposes of Collection
    Identifiers
    		For account registration, ID verification, check creditworthiness of customer, and to follow up unfinished checkouts via email where necessary.
    Mailing address and phone number
    		To fulfill product orders for delivery of cars and/or to confirm/assess whether you fall within our serviceable delivery range.
    Credit scores and driving records
    		To assess creditworthiness and driving risk of customer to evaluate whether to extend a subscription offer and on which terms.



    We may also use your Personal Information:

    • to provide and operate our Services and Program;
    • to comply with our legal obligations, including detecting and preventing fraud, spam, abuse, security incidents and other illegal or harmful activity, and to conduct risk and security assessments;
    • to process your applications and transactions, and to verify information you provide to us, including background and other checks as permitted by applicable law;
    • to ensure compliance with this Privacy Policy, our Mobile App and Website Terms of Service, the Specific Agreement, and other agreements we have with you;
    • to communicate with you for transactional purposes (for example, we might contact you about your Subscription or this Privacy Policy);
    • to process your employment application and assess your employment candidacy, as well as communicate with you for hiring purposes;
    • to improve our Services, for example, by using your Personal Information to customize your experience with us;
    • for the security of the Services and our company, our customers, and other third parties;
    • for our marketing purposes, to send you information about new features on the Services, new services we offer and special investment opportunities, to serve you ads, and to tell you about investments available through us or information we think you might find interesting;
    • to resolve any disputes and enforce our agreements with third parties; and
    • for other purposes, as permitted by applicable law.  


    4. Sharing Personal Information

    We may share your Personal Information in the following circumstances:

    • With our Affiliates – We may share your Personal Information with our affiliates, including but not limited to FINN Titling Trust, and across our organization.
    • Service providers – When we hire a service provider to help operate the Services or our business, we may give access to Personal Information as necessary to perform the service for us.  Such tasks include hosting our Site (Netlify), processing payments (Stripe), analyzing websites usage data (google Analytics), hosting our data about our cars invoices and subscriptions (Airtable), customer service.  We take commercially reasonable steps to require our service providers provide at least the same level of protection for Personal Information as we do.
    • Business Partners – We may share Personal Information with our trusted business partners whose products or services we think may be of interest to you.  For example, we may share your Personal Information with a company when we co-sponsor a promotion.  These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.
    • Third party websites – We may provide links to websites that are owned or operated by other companies, for example identification verification (or know your customer) services.  If you use a link to visit a third party website, you will subject to that website’s privacy notice and terms of use, which may be different from ours.  You should read the privacy policy and terms of use before providing any information to a third party website.
    • Legal obligation or protection from harm – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Equilibrium, its users, or the public against harm.
    • Merger or sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
    • Purposes described to you – We may share your Personal Information for other purposes, as we describe to you.

    Statement of Non-Sharing for Mobile Numbers, Message Frequency, and Data Rates Disclosure:

    This statement outlines our practices regarding the collection, usage, and disclosure of mobile numbers, message frequency, and the associated costs related to messaging services. Please read this statement carefully to understand how we handle this information.

    Collection and Usage of Mobile Numbers:

    When you provide us with your mobile number, either through our website, mobile application, or any other means, we will only use it for the specific purposes outlined in this privacy policy. We collect mobile numbers solely to facilitate communication with you, such as sending important updates, notifications, promotional offers, and other relevant information related to our products or services.

    Sharing of Mobile Numbers:

    We do not share your mobile number with any third parties without your explicit consent, except in the following circumstances:

    • If required by law, legal process, or government request, we may be obligated to disclose your mobile number.
    • In case of a merger, acquisition, or any other change in ownership, your mobile number may be transferred to the new entity, but we will notify you beforehand and provide options to opt out if desired.

    Message Frequency:

    By providing your mobile number and opting in to receive messages from us, you consent to receive periodic communications via text messages or other messaging platforms. The frequency of these messages will vary depending on the nature of the information being sent, such as transactional messages, promotional offers, or service updates. While we strive to maintain a reasonable message frequency, please note that it may vary and you can always opt out of receiving messages by following the instructions provided in the messages or by contacting us directly.

    Message and Data Rates:

    Standard message and data rates may apply when you receive text messages or other communications from us. These rates are determined by your mobile service provider and are beyond our control. We are not responsible for any charges or fees incurred as a result of receiving messages from us. We recommend checking with your mobile service provider for details on any applicable charges.


    5. Cookies and Similar Technologies

    We collect Personal Information about users over time on the Services by using several common types of cookies and other tracking technologies including web beacons, pixels, and flash cookies (“Usage Information”).  We also have third parties that collect Personal Information in this way on our behalf and for their own purposes.  Cookies are small files that download when you access certain websites.  For more information about cookies visit: www.allaboutcookies.org/. Web beacons, pixels, and other tracking technologies operate independent of cookies. 

    To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics.  For more information on Google Analytics’ processing of your Personal Information, please see “How Google uses data when you use our partners' Servicess or apps.”  You can opt out of Google Analytics by installing Google’s opt-out browser add-on.

    These cookies may be ones placed by us (first-party) or by a third party.  These cookies may also be Flash Cookies.  To learn how to manage privacy and storage settings for Flash cookies click here.  We may use cookies that are session-based or persistent.  Session cookies expire when you close your browser or turn off your device. Persistent cookies remain on your device after you close your browser or turn off device. 

    We may use a variety of cookies:

    Type of Cookies
    		Description
    Required
    		Required cookies are essential for the Services to function properly and for you to navigate our Services and use its features, such as accessing secure areas of the Services and using our services.
    Performance
    		These cookies collect information about how you use the Services, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Services functions and performs.
    Functionality
    		Functionality cookies allow the Services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Services after logging-in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
    Targeting or Advertising
    		From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Services. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Services. The information provided to third parties does not include Personal Information, but this information may be re-associated with Personal Information after we receive it.
    By way of example, as you visit the Services, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Services.
    We also contract with third-party advertising networks and similar partners that collect IP addresses and other information on our Services, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts.
    Third parties, with whom we partner to provide certain features on the Services or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.


    You can control cookies and tracking tools.  Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings.  Our Services does not currently respond to these signals.  If you choose to block cookies and other trackers, certain features of the Services may not work.  Blocking or rejecting cookies will not stop all of the tracking described in this Privacy Policy.  These features and options are browser and device specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:


    To find out more on how to manage and delete cookies, visit www.allaboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:


    On a mobile device, you may also be to adjust your settings to limit ad tracking.


    6. Your Choices and Opting Out of Receiving Electronic Communications

    You have certain choices about how we use your Personal Information. We may send notifications or other information to you, for example, via email and SMS ("Communications"). To opt out of marketing communication use the respective function within marketing communication of us or contact us using the information in Section 11 below. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. To delete your personal data please use our contact form here and select the option "Delete User Account and Personal Data".

     

    7. Storage, Security, and Retention of Information

    We use reasonable physical, technical, and operational safeguards to protect Personal Information.  Please note, however, that no transmission of information via the Internet can be entirely secure, so we recommend that you do not use unsecure channels to send us sensitive or confidential information (for example, your social security number).  


    8. International Use of the Services

    We are located, and the Services are operated and hosted, in the United States.  Our Services are intended for a US audience.  If you are located outside the United States, please note that your Personal Information will be treated in accordance with US federal and state laws, which may be different from those in your country.


    9. Children Under the Age of 16

    We do not knowingly collect or solicit any Personal Information from children under the age of 16.  In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.  If you are a parent or legal guardian and think your child has given us their Personal Information you can email us at help@finn.auto and include “COPPA Inquiry” in your inquiry.


    10. Links to Third-Party and their Websites

    As described above, our Services may include third party content and links to third party websites and services that collect Personal Information.  We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them.  We encourage you to read the third parties’ privacy policies carefully.


    11. Contact Us

    ‍If you have any questions about our practices or this Privacy Policy, please contact us at +1 (619) 439-0735 or help@finn.auto. You may also send us mail at the following address: Finn of America, Inc., 206 East Huron Street Suite 120, Ann Arbor, MI 48104.