Privacy Policy

Effective Date: 30 Jan 2025
Last Updated: May 01, 2026

Welcome to the FintelConnect Technologies Inc. (dba Fintel Connect) (“Fintel”, “we”, “us” or “our”) privacy policy (the “Privacy Policy”). We handle Personal Information in accordance with the privacy regulations and procedures applicable to us, including the Personal Information Protection Act (British Columbia).

This Privacy Policy governs the access and use of our websites located at fintelconnect.com (the “Sites”), and our performance marketing and affiliate network management platform accessible thereon (the “Platform”, and collectively with the Sites, the “Services”) by any of the following individuals or entities (collectively, “user”, “you”, or “your”):

1. General visitors to the Sites;
2. Affiliate marketers and publishers authorized on the Platform (collectively, “Publishers”); and
3. Financial institutions, including banks, credit unions, and agencies, authorized on the Platform (collectively, “Merchants”).

BY ACCESSING OR USING ANY OF THE SERVICES, YOU AGREE, ON BEHALF OF YOURSELF AND ANY ENTITY YOU REPRESENT TO FINTEL’S HANDLING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE SERVICES.

1. Definitions and Interpretation

“Aggregated Information” means information that has been made anonymous or aggregated so that it can no longer be used to identify an individual, whether alone or in combination with other information.

“Contact Information” means information to enable an individual at a place of business to be contacted (e.g., name, position name or title, business telephone number, business address, business email or business fax number).

“Personal Information” means information about an identifiable individual (e.g., name, address, e-mail address, phone number). Personal Information does not include: (a) Aggregated Information; or (b) Contact Information, provided that it is processed solely for the purpose of communicating with that person in relation to their employment or profession.

“process” or “processing” means any action that a person can take with respect to Personal Information, such as collecting, using, sharing, storing and altering Personal Information.

As used in this Privacy Policy, all references to “including” herein will be interpreted as meaning “including without limitation”. Words importing the singular include the plural, and vice versa, and words importing a particular gender or neuter include both genders and neuter. Section headings used herein are for convenience of reference only.

2. Changes to Privacy Policy

Fintel may amend this Privacy Policy from time to time, so please review it periodically. Unless otherwise provided by Fintel in writing, any amendments to this Privacy Policy will be effective upon posting to our Sites. Your continued use of our Services after we post any amendments to the Privacy Policy will constitute your acceptance of the amendments and your consent to abide and be bound by the amended Privacy Policy.

3. Why We Process Personal Information

We may process Personal Information to fulfill the following purposes (collectively, the “Purposes”):

1. to provide our Services, including:
   1. to enable you to create and manage your user account on the Platform;
   2. to enable us to collect and send payments;
   3. to enable us to contact you about updates to the Services, and to respond to your communications with us; and
   4. to enable us to provide you with our newsletter to inform you about our promotions;
2. for marketing our Services and the products and services of our business partners, including:
   
   1. for email marketing and nurture campaigns;
   2. for webinars and event follow-up;
   3. for paid advertising and retargeting;
   4. for social media engagement and lead forms;
   5. for content downloads and content syndication;
   6. for audience segmentation, lead scoring/qualification;
   7. for campaign attribution and performance measurement; and
   8. for account-based or business development outreach;
3. for internal statistical and operational purposes to better understand how our Services are used;
4. to maintain and improve our Services;
5. to maintain and improve the security of our Services, including the detection, prevention, and response to security incidents or other malicious, deceptive, fraudulent, or illegal activity;
6. to effect changes to Fintel’s business, such as corporate mergers, acquisitions, and reorganizations;
7. to enforce our legal rights and comply with applicable law; and
8. to carry out any other purpose which is disclosed to you and for which you consent, or as is otherwise permitted by applicable law.

For each of the Purposes, we will only process Personal Information to the extent necessary to achieve that Purpose.

4. What Personal Information We Collect

Information that we collect may include the following, some or all of which may constitute Personal Information:

1. Identifiers. Your first and last name, address, phone number, email address, password for your user account, company name, job title, business contact details, CRM or marketing platform identifiers, and lead source or campaign source identifiers. We use this information to set up your user account on the Platform, maintain security on the Platform, and provide the features of the Platform.
2. Payment Information. Tax number (in Canada), and Form W-9 (in United States), payment information (for PayPal or wire transfer) and financial information relating to commissions earned and paid. We use this information to facilitate payments from Merchants to Publishers on the Platform.
3. Usage Information. Information on your use of the Services, such as usage analytics, web logs of user activity, IP addresses, device identification, geolocation information (such as approximate location based on your IP address, or information you provide to us such as city and state that you provide through a webform). We use this information to improve our Services by better understanding your preferences. We also use this information to keep a record of your acceptance of this Privacy Policy for compliance with applicable laws.
4. Recorded Information. Recordings of your interactions with our sales or support teams and messaging logs. We use this information to improve our Services through quality assurance and training protocols.
5. Marketing Information. Websites traffic analytics and performance information relating to promoted brands. We use this information to help market our Services and improve them.
6. Other Information. We may collect such other Personal Information to the extent necessary to fulfill the Purposes. Certain Personal Information may be used to fulfill multiple Purposes set forth in this Privacy Policy (even if not expressly set forth above).

For certainty, the categories of Personal Information above are not necessarily collected from all users. The types of Personal Information collected will depend on the extent of the Services accessed by the particular user (e.g., a general visitor to the Sites versus a Publisher or Merchant).

5. How We Collect Personal Information

There are three primary ways that we may collect Personal Information: (1) when you provide it to us through your access and use of our Services, and/or your communications with us; (2) when it is automatically collected from you through your access and use of the Services; and (3) when we receive it from a third-party source. We further describe these situations below:

1. Provided by You. You are requested to provide your Personal Information to us whenever we need it for the provision of our Services, or otherwise for accessing certain features of our Services, including:
   1. when you register for an account on the Platform;
   2. when you fill out a form on our Sites;
   3. when you subscribe to our newsletter; and
   4. when you otherwise communicate with us, such as when you utilize the “Contact Us” feature on our Sites.
2. Automatic Collection.
   1. Cookies. We may use cookies and similar technologies to track and analyze user activity in order to improve our Services and improve your experience. A cookie is a tiny element of data sent to your browser from a website. The cookie is stored on your hard drive so that your computer or other device may be recognized while you interact with the Sites.

      Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. Your computer provides you with the ability to clear all cookies that have been stored on your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the Sites and/or Services if you block or disable our cookies. For more information about cookies, please see: https://www.allaboutcookies.org/.

   2. Web Analytics. We may use web analytics services (e.g., Google Analytics) in order to better understand the user experience on our Sites, including:
      1. how you reached our Sites;
      2. the website you came from;
      3. how long you stayed on our Sites;
      4. what pages you looked at;
      5. how many pages you looked at;
      6. what buttons you clicked;
      7. what browser you are using; and
      8. what device you are using.

      Any use of such analytics services by us will be governed by the terms of service of the web analytics provider and any contract between us and such provider. The analytics providers may collect your Personal Information when you access and use our Services. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your device identifier, site usage information, and related information about you.
      
      If you do not wish to participate in web analytics, you may be able to download an opt-out browser add-on. Your web browser may also allow you to set a “Do Not Track” signal when you use online services. To learn more about “Do Not Track” signals, visit http://www.allaboutdnt.com/. You may also contact us at the “Contact Us” section below regarding any questions about web analytics services that we may use.

3. Third Parties. We may also obtain Personal Information from third parties. Such third parties may include: third-party service providers, advertising and analytics providers, event organizers, webinar hosts, sponsors, publishers, lead generation or content syndication partners, business partners with whom we market or offer services, data enrichment providers, and social media networks, including their plugins, embedded content, lead generation tools, and similar features. We protect such Personal Information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the Personal Information and applicable laws.

6. Consent for Processing Personal Information

We will not process your Personal Information without your consent, unless we are permitted or required to do so by applicable law. Consent may be express or implied, depending on the nature and sensitivity of the Personal Information. The type of consent we may rely on in processing your Personal Information will vary based on your reasonable expectations, the sensitivity of your Personal Information, and the circumstances surrounding the collection of your Personal Information. Express consent is when you willingly agree (e.g., orally, in writing, or electronic agreement) to the processing of your Personal Information for particular purposes. Implied consent is when: (a) you do not expressly give consent, but you rather volunteer Personal Information for obvious purposes that a reasonable person would consider appropriate in the circumstances; or (b) you are given notice and a reasonable opportunity to opt-out of your Personal Information being processed for specified purposes, and you do not opt-out. By accessing and using our Services, you consent to us handling your Personal Information in accordance with this Privacy Policy.

7. Disclosure of Personal Information

1. Service Providers. We may disclose your Personal Information to the extent required to fulfill the Purposes, including to our third-party service providers. For example, we may use third-party service providers to help us process payments, analyze usage of our Services, track the effectiveness of our marketing strategies and communications, assist with the prevention, detection and investigation of potentially illegal acts and security breaches, collect and process error and crash reports, and store data. If we provide your Personal Information to service providers, we limit the information to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality and security of such information.
2. Corporate Transactions. We may also disclose or transfer your Personal Information to affiliates or third parties in the event of a proposed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity, subject in each case to customary confidentiality agreements.
3. Legal Disclosure. We may disclose Personal Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Fintel will have no liability associated with any such disclosures made in good faith.
4. International Transfer and Storage. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage third-party service providers. By using our Services, and otherwise providing us your Personal Information, you consent to the transfer of your Personal Information to countries outside of your country of residence, which may have different data protection rules than your country. Personal Information is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such country, pursuant to the laws of such country. We implement appropriate safeguards to protect Personal Information transferred across borders, including contractual obligations requiring service providers to maintain standards of confidentiality and security comparable to those required under this Privacy Policy and applicable law. These safeguards include measures designed to protect Personal Information against unauthorized access, use, disclosure, or loss while in the custody of such service providers. We take reasonable steps to ensure that any third parties processing Personal Information on our behalf only use such information for the purposes for which it was disclosed and in accordance with our instructions and applicable law.

8. Retention of Personal Information

If we use Personal Information to make a decision that directly affects you, we will retain that Personal Information for at least one year, so that you have a reasonable opportunity to request access to it. In any event, we will retain your Personal Information only as long as necessary to: (a) fulfill the Purposes; (b) protect our legal rights; and (c) comply with applicable law. We will securely delete or anonymize the Personal Information once it is no longer necessary for us to hold it. We are not responsible for any liability or loss you experience as a result of any such disposal of Personal Information.

9. Security of Personal Information

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable and commercially acceptable security procedures and practices appropriate to the nature of the Personal Information we collect, use and store. We protect your Personal Information using appropriate technical and organizational measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Such measures may include:

1. Access controls to ensure that only those employees who need access to your Personal Information to fulfill their employment duties will have access to it;
2. Appropriate authentication mechanisms (including strong password practices and, where appropriate, multi-factor authentication);
3. Logging and monitoring of access to Personal Information;
4. Encryption, secure storage and handling practices designed to prevent unauthorized access, use or disclosure of Personal Information;
5. Secure deletion or destruction of Personal Information once it is no longer necessary for retention pursuant to this Privacy Policy;
6. Maintaining responses and remediation procedures for privacy incidents and data breaches; and
7. Regular security reviews of security systems and practices.

However, no method of transmission over the Internet is 100% secure. Therefore, we cannot guarantee absolute security. We encourage you to also take steps to protect Personal Information by, for example, closing all web browsers after using our Services.

10. Rights Relating to Personal Information

1. General. You may be able to exercise certain rights relating to your Personal Information, subject to applicable law in each instance:
   1. Right to be Informed. To know how your Personal Information is collected, how it is used, and how it is disclosed and stored. This further includes:
      1. Right to Withdraw Consent. To withdraw your consent to the processing of your Personal Information at any time. Please be advised that withdrawing your consent to the processing of Personal Information may impact on our provision of the Services. For further information on this, please contact our Privacy Officer as provided in the “Contact Us” section below.
      2. Right to Make a Complaint. To make a complaint about the processing of your Personal Information.
   2. Right to Access. To receive a copy of your Personal Information.
   3. Right to Rectification. To request correction of your Personal Information.
2. Exercising Your Rights. If you would like to exercise your rights listed above, please refer to our “Contact Us” section below. When doing so, please tell us which right you are exercising and provide us with contact information to direct our response. We will verify your identity in order to process requests to exercise any applicable rights. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for the purposes of verifying your identity will solely be used for the purpose of verification. We will respond to any request for exercise of rights within thirty (30) days of the request, or as otherwise required under applicable law.

11. Third-Party Materials

This Privacy Policy addresses the handling of Personal Information that we collect from you. If you disclose your Personal Information to third-parties, or if you engage any third-party sites or services, such third-party privacy notices and practices will apply. Occasionally, we may include or offer third-party products, services, links and/or applications through our Services (collectively, the “Third-Party Materials”). These Third-Party Materials are not owned, maintained, operated or controlled by Fintel. We cannot guarantee the privacy or security of your Personal Information once you provide it to a third-party and we encourage you to evaluate the privacy and security policies of each such third-party before any such engagement or disclosure. Fintel is not responsible for the content of such Third-Party Materials and does not make any representations, warranties or guarantees regarding the content or the privacy practices of such third parties. For certainty, Fintel disclaims any liability associated with your access to, use of, download of, or reliance on, such Third-Party Materials and their content. If you decide to access, use or download any such Third-Party Materials, you do so at your sole risk.

12. Opting Out of Communications

To opt-out from receiving our newsletters, or certain communications from us through your use of the Services (the “Communications”), you may either contact us as provided in the “Contact Us” section below, or, if applicable, click the “Unsubscribe” link in the relevant Communication. Please note that certain Communications may be necessary for the proper functioning and use of the Services, and opting out of those Communications may prevent the proper use of the Services.

13. Personal Information About Other Individuals

Before providing any Personal Information to us on behalf of another individual, you represent and warrant that you have received all necessary authorizations to do so. Do not provide us with any Personal Information on behalf of another individual if you do not hold all such authorizations to do so.

14. Contact Us

If you have any questions about this Privacy Policy or wish to exercise any applicable rights, you may contact our Privacy Officer at:

Email Address: Privacy@FintelConnect.com
Phone Number: +1 604-566-8020

To submit an identified security issue to Fintel Connect, please contact our Security Team at:

Email Address: Security@FintelConnect.com
Phone Number: +1 604-566-8020