Welcome to Finoo, the platform designed to help you fund your exchange program in an easy, practical, and intuitive way. Our platform offers a digital account specifically for exchange-related use, allowing you, the User, to have a multi-currency account and make international transfers quickly, simply, and securely. With it, you can start saving money in Brazilian reais, convert it to other currencies whenever you wish, and pay your educational institution through a transfer as easy as making a Pix to any bank account associated with universities, language schools, colleges, community colleges, among other institutions.
If you've come this far through our website, available at https://finoo.io/ , or through our app, available on both the Apple Store and Google Play (all together, 'Our Environments'), it's because you care about the protection of your Personal Data – and the purpose of this Privacy Notice (or 'Notice') is to make it clear to you, our User or not, and to the general public, how we also care about your privacy.
ATTENTION! Our Environments are intended for use by adults with full legal capacity. If you are under 18 years old or do not have full legal capacity, we kindly ask you not to register or use any features of Our Environments. We reserve the right to delete any registration or interaction that violates these conditions. Note to legal guardians: while we prohibit the registration and use of Our Environments by those not fully capable under the law, parents and/or legal guardians (as applicable) should supervise the online activities of their charges.
Before accessing and using the exclusive functionalities of Our Environments, we recommend that you read this Notice thoroughly and carefully. In it, we explain which of your Personal Data we collect, why we use them, with whom we share them, the security measures we adopt to protect them, and explain what your rights are regarding the activities we perform on them.
Having read and understood the terms of this Notice, you must express your awareness of its provisions, which can be done by ticking the checkbox in 'I have read and understood the Privacy Notice of the Finoo Platform'. Without your expression of awareness, the use of our Platform will not be possible.
For ease, we will use defined terms (which you will recognize as words beginning with capital letters, such as 'Privacy Notice') throughout the document. If you have any questions about them, you can consult their definitions at the end of this Notice, in our Glossary.
We understand that any and all interactions by Users result from their complete understanding and awareness of the terms of this Notice, and the use of Our Environments is a free and express manifestation of their agreement with the provisions here (including the collection of the Personal Data mentioned here and their use for the specified purposes below).
If you do not agree with the provisions of this Notice, you must discontinue access to or use of Our Environments.
The Finoo Platform is developed and maintained by us, Finoo Brazil Ltda., a private legal entity under Brazilian law, registered under CNPJ/ME No. 48.364.557/0001-38, with headquarters at Avenida Engenheiro Luiz Carlos Berrini, 1748 – suite 1710, in the Cidade Monções district of São Paulo/SP, ZIP code 04571-000.
As a rule, it is you who submits your Personal Data to us, such as when you register on our Platform, sign up for our newsletter to receive Finoo updates and other relevant information, or use the contact form on our website; however, in some cases, we may collect some information (which may include Personal Data) in an automated manner when you use Our Environments.
Collected data | For what porpuse we use | Registration data |
---|---|
Full Name | (i) To identify and authenticate you; (ii) To comply with our obligations to you arising from the use of our services; ((iii) To expand our relationship, informing you about news, features, content, news, and other events we consider relevant to you; (iv) To enrich your experience with us; (v) To promote our products and services. |
Email | |
Nationality | |
Date of Birth | |
CPF (Brazilian Individual Taxpayer Registry Number) | |
Phone | |
Complete Address | |
Profession | |
PEP (Politically Exposed Person) | |
HIO (Head of International Organization) | |
Student ID | |
Digital Identification Data | |
IP Address and Port | |
Origin Logic | DIGITAL IDENTIFICATION DATA |
IP Address and Logical Source Port | (i) To identify and authenticate you; (ii) To comply with our obligations to you, arising from the use of our services; (iii) To improve our Platform; (iv) To enhance our relationship and enrich your experience with us, by better understanding your interest in features and content of our Platform. |
Device (operating system version) | |
Geolocation | |
Date and time records of each action you perform | |
Which screens you accessed | |
Session ID | |
Cookies | PAYMENT DATA |
Credit card number and security code | (i) To comply with our obligations to you, arising from the use of our services; (ii) To fulfill our contract by sharing the Data with the third-party company responsible for processing the payment. |
Bank account details | SURVEY DATA |
Responses to optional questionnaires and surveys | (i) To enhance our relationship and enrich your experience with us, by better understanding your interest in the content of our Platform. |
3.1.1. We employ cookies in the functionalities of Our Environments, both for performance (collecting anonymous information about how Users use Our Environments – for example, Google Analytics) and for advertising (collecting information on browsing habits, aiming to make advertising more relevant to the User) and functionality (which allow the execution of certain features). If you wish, you can configure your internet browser to block cookies; however, if you do, some functionalities of the Platform may be compromised.
3.2.1. For the KYC process, a proof of life procedure will be conducted, through which our partner will request, in addition to the Personal Data listed above, (i) an identification document, which can be an identity card, passport, among other official documents, and (ii) a real-time interaction with facial biometrics analysis, whose results will be treated by hash (encrypted) and not stored.
3.3.1. Should there be a well-founded suspicion on our part that the processing of any Personal Data entered by the User may lead to a violation of the Law or, furthermore, that our Platform is being used for illicit purposes, we reserve the right to suspend the account in question until the suspicion is resolved.
5.1.1. These institutions, in accordance with the LGPD (General Data Protection Law), are independent Controllers of the Personal Data, and may integrate them into their own database, i.e., they may use your Personal Data in other ways or for different purposes than those provided here.
5.1.2. Finoo is not responsible for the Processing of your Personal Data that such institutions may carry out, which must be provided in their respective Notices (or Policies) of Privacy.
6.6.1. Protect your terminal (computer or mobile phone) against unauthorized access, and make sure to always click 'logout' at the end of your navigation on a shared terminal.
6.6.2. Be aware that we will never send electronic messages asking for data confirmation or with attachments that can be executed (extensions: .exe, .com, among others) or even links for possible downloads.
6.6.3. Understand that sharing passwords and access data violates the Platform's usage guidelines and can compromise the security of your Personal Data and Our Environments.
6.6.4. When accessing platforms or environments of third parties (including, but not only, when redirected from Our Environments), read the Privacy Policy of such platforms or environments, being your responsibility to accept or reject it – remember that we are not responsible for the content of any websites, contents, or services linked to environments other than ours.
DATA SUBJECT’S RIGHT | DEFINITION |
---|---|
Confirmation of the Existence of Processing | Request confirmation and clear information about the origin of the Data Subject’s Personal Data processed by Finoo, the criteria used, the purpose of the processing, and information regarding the (non-)existence of the record. |
Access | Access the Data Subject’s Personal Data that are in the database or being processed by Finoo. |
Rectification | Request the correction of incorrect or incomplete Personal Data of the Data Subject in Finoo’s database. |
Deletion | Request the deletion of the Data Subject’s Personal Data in Finoo’s database, or if not possible (due to the mandatory retention discussed in item 4), keep them for the period provided in an inactive database. |
Portability | Transmission of the Data Subject’s Personal Data for the use of third-party services. |
Review of Automated Decisions | Request a review of decisions made solely through automated processes. |
8.1. E-mail: hello@finoo.io;
8.2. "Help" channel on the Platform.
10.1.1 ANPD: stands for the National Data Protection Authority, a special nature autarchy of the Federal Government linked to the Ministry of Justice and Public Security, responsible for overseeing the protection of Personal Data and for guiding, regulating, and supervising compliance with legislation on the subject;
10.1.2 Notice (or Privacy Notice): this document, which provides transparency to our Users and the general public about which Personal Data we collect, why we use them, with whom we share them, the security measures we adopt to protect them, and explains the rights of such Data Subjects regarding the activities we perform on them;
10.1.3 Controller: is the natural or legal person, of public or private law, to whom decisions regarding the processing of Personal Data belong – in the case of the Finoo.io Platform, us, Finoo;
10.1.4 Personal Data: any information related to an identified or identifiable natural person, as defined in article 5, II of the LGPD;
10.1.5 Data Protection Officer: also known as Data Protection Officer, or DPO, is the person (natural or legal) appointed by us to act as a communication channel between us, the Data Subjects, and the ANPD, as per article 5, VIII of the LGPD;
10.1.6 HTTPS: is a secure version of the Hypertext Transfer Protocol (HTTP), a format for interoperability of internet communications, used to give the data traffic greater security and inviolability;
10.1.7 Session ID: is the record of the User's connection with our Platform;
10.1.8 LGPD: refers to Federal Law No. 13.709, of August 14, 2018, also known (and referred to as) General Data Protection Law, in its consolidated version (including all amendments);
10.1.9 Our Environments: means, jointly and indistinctly, our website, available at http://bestpass.travel, and our Platform, in its web and app versions;
10.1.10 Operator: is the natural or legal person, of public or private law, who processes Personal Data on behalf of and by order of the Controller, as per article 5, VII of the LGPD – in this case, hired by us to assist Finoo in its activities;
10.1.11 Platform: means the Finoo platform, in its web versions (accessible through our site, http://finoo.io ) and app version, available in app stores (Apple and Google), through which duly registered Users can use a specific digital account for everything about their exchange program;
10.1.12 Records: means the operational records (logs) we maintain regarding User interactions on our Platform;
110.1.13 TCP/IP: stands for Transmission Control Protocol and Internet Protocol, which has become the standard set of communication rules on the internet to allow information interoperability. IP can also refer to the IP address, which is the numerical sequence of 32 bits (IPv4) or 128 bits in hexadecimal (IPv6) used to identify a terminal in its internet connection – i.e., your online 'address';
10.1.14 TLS: stands for Transport Layer Security, a type of digital security that seeks to ensure secure communication between the Users' browsers and our website (which replaced SSL);
10.1.15 Data Subject: is the natural person to whom the Personal Data being processed refer, as per article 5, V of the LGPD;
10.1.16 Processing: is any operation performed with Personal Data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or information control, modification, communication, transfer, dissemination, or extraction, as per article 5, X of the LGPD;
10.1.17 User: is you, who registered at Finoo to facilitate your exchange program!