Last updated: October 2020
WHY THIS MATTERS
We want to build an indispensable platform to aid our users in making smart comparisons and to afford us the information required to give sound recommendations. Knowing certain things will help us do that better.
Please be sure to read this entire Policy before using or submitting information through the web-app. By using or submitting information through the use of the web-app, you are indicating that you agree to the collection, transfer, manipulation, storage, disclosure and other uses of your Personal Data as described in this Policy and to be bound by the terms of this Policy.
CHANGES TO THE POLICY
We may change this Policy from time to time, so please review this page periodically for changes. If we make any material changes to this Policy, we will notify you either by placing a notice on our web-app, or by contacting you through the email address you have provided to us upon sign up. The “Effective Date” provided at the top of this page will indicate when the Policy was most recently updated.
We collect Personal Data from you when you voluntarily provide such information, such as; when you access the web-app, access, complete and/or use our online forms/questionnaires, calculators, tools or content items or contact us with queries.
To effectively use the web-app you may be required to complete online forms/questionnaires and calculators and therefore may be required to provide Personal Data in order to receive the most accurate outcome.
If we have registration and/or log-on experience, this would include the information we collect when you create an account such as name, email address, password and/or other information to provide account related functionalities to our users.
Demographic Data/ Personal Information
This information may include your name, address, email address, phone number, age, sex, marital status, nationality.
Medical history, health, property and life insurance information, income, ownership or rental history, employment status, expenses, investment information and other information.
Feedback and Support
If you provide us feedback or contact us for support, we may collect your name, email address and phone number, as well as any other content that you send to us. We collect and use this data based upon our business need to receive and act upon your feedback or issues.
If you voluntarily submit certain information to our web-app, such as filling out a survey about your user experience, we may collect the information you have provided. We may collect this information to understand your opinions, better market our services and to collect relevant information about our business.
Information we may collect which is not specifically listed here, is described in this Policy or is otherwise disclosed at time of collection. FinWise collects Personal Data from you to, in part, provide you with personalised content and results related to your financial position, but TBSL is not a lender, credit card issuer, banking institution, investment institution or other similarly situated financial institution. Any investment, loan or related product to which you may become a party is solely transacted between you and the applicable provider and is not a part of our services.
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Policy. You represent that the Personal Data you provide is true, accurate, current and complete, and that you have the authorisation to provide it to us.
INFORMATION AUTOMATICALLY COLLECTED
Whenever you interact with the web-app, we may automatically receive and record information from your computer, browser and/or mobile device, which may include the following:
The requests you make to FinWise may contain your IP address (the Internet address of your computer. We may use visitors’ IP addresses for various purposes, including to display customised content and analyse and report upon usage of the web-app; to diagnose and prevent service or technology problems affect the web-app; and to monitor and prevent fraud and abuse.
We may collect information on the type of device you are using, operating system, settings, browser and OS information, unique device identifiers, network information and other device-specific information. The information collected may depend on the type of device you use and its settings.
We may collect location data based on your IP address and the geolocation of your device. We collect this data to better tailor our services to you and to help provide service offerings available to you in your geographic area.
We collect information about how you use our services, such as the categories of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities on the web-app.
OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION
TBSL and FinWisE uses the Personal Data you provide in a manner that is consistent with this Policy. Generally, we may use information we collect in the following ways:
• To identify and personalise the outcomes and recommendations when you visit our web-app.
• To provide products and services.
• For fraud and information security.
• To improve the information provided on the web-app.
• To conduct analytics such as usage trends.
• To respond to inquiries related to support or other requests.
• To send marketing and promotional materials about the web-app.
• To manage our relationships.
• To build aggregated user profiles and segments.
If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it is provided. For instance, if you contact us by email or provide feedback in any way such as to ask a question or report an issue with the web-app, we will use the Personal Data you provide to answer your question or resolve your problem.
TBSL and our affiliate, Global Financial Brokers Limited may also use your Personal Data and other personally non-identifiable information collected through the web-app to help us improve the content and functionality of the web-app, to better understand our users and to improve the services.
OUR DISCLOSURE OF YOUR PERSONAL DATA
TBSL is not in the business of selling your information to third parties. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Certain Business Partners
When we partner with other businesses to provide information or services to you or to such business partners, we may share relevant Personal Data in connection with such content or services. For example, we will share your name or contact information with an investor and/or insurer if the information you provide in one of our online questionnaires or tools matches certain product criteria or is requested by you.
In the event of a corporate sale, merger, dissolution, acquisition or similar event, Personal Data may be part of the transferred assets. Your Personal Data could also be shared with professional advisors and counterparties during such events.
We may also share your Personal Data with TBSL’s subsidiary companies for purposes consistent with this Policy.
Agents, Consultants and Related Third Parties
TBSL, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include maintaining databases and providing marketing assistance. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
TBSL may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (1) comply with a legal obligation, (2) to protect and defend the rights or property of TBSL, (3) act in urgent circumstances to protect the safety of users of FinWisE or the public, or (4) protect against legal liability.
OTHER IMPORTANT INFORMATION
This Policy does not apply to any Personal Data collected by TBSL other than Personal Data collected through FinWisE. This Policy shall not apply to any unsolicited information you provide to TBSL through the web-app or through any other means. All unsolicited information shall be deemed to be non-confidential and TBSL shall be free to reproduce, use, disclose and distribute such unsolicited information to others without limitation or attribution.
Children’s Privacy Online
TBSL does not knowingly collect Personal Data from children under the age of sixteen (16). If you are under the age of 16, please do not submit any Personal Data through the web-app. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Policy by instructing their children never to provide Personal Data on the web-app without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to TBSL through the web-app, please contact us, and we will endeavour to delete that information from our databases.
TBSL takes reasonable steps to protect the Personal Data provided via the web-app from loss, misuse and unauthorised access, disclosure, alteration and destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, emails sent to and from the web-app may not be secure. Therefore, you should take special care in deciding what information you send to us via email. By using the web-app or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the web-app. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the web-app or by sending an email to you.