Last updated: April 23, 2020

Privacy Policy

Finalis is committed to respecting the privacy rights of its Users. We created this Privacy Policy (“Privacy Policy”) to give you confidence as you use the Service, and to demonstrate our commitment to fair information practices and the protection of privacy.

PERSONALLY IDENTIFIABLE INFORMATION

In using the Service, you may be requested to provide certain information such as your name, address (postal and email) and telephone number. This information is stored in our database.

We do not sell or license personally identifiable information to third parties. We may use personally identifiable information to administer and improve the Service, customer support, to send you information about Finalis or the Service, to contact you when necessary and for such other purposes as you may consent. We also share personal information with our business partners who assist us by performing core services (such as hosting, billing, fulfillment or data storage and security) related to the Service. Those business partners have all agreed to uphold similar standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use such information to carry outtheir specific business obligations to Finalis.

COOKIES

We use “cookies” to collect information and to provide you with a better service. We may customize content specific to yourinterests, store your password so you do not have to re-enter it each time you use the Service, and promote the Service to you. You can instruct your computer to not accept cookies; however, if you do so, you may not be able to use all aspects of the Service.

SECURITY

We follow generally accepted industry standards to protect personal information submitted to us. Finalis uses reasonable measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained, and follows applicable laws regarding safeguarding any such information under our control. Finalis uses certain trusted third party companies to provide and improve the Service, including data storage and hosting operations. These third parties may have access to your information only for the purposes of performing tasks on our behalf and under obligations similar to those in this Privacy Policy. While we believe that we have taken reasonable steps to secure data collected from our customers, no security system is impenetrable. Each user is responsible for protecting his, her or its own username, password and other authenticating information and processes from third party access, and for selecting passwords that are secure. Each user must promptly notify us if their username or password is lost, stolen or used without permission. In such an event, we will remove that user name orpassword from your account and update our records accordingly. The Servicemay contain links to third party websites. We are not responsible for the privacy practices or the content of such websites.

CONFIDENTIALITY

Except as otherwise provided in this Privacy Policy, we will use commercially reasonable efforts to protect and safeguard all personal information against unauthorized use, publication or disclosure, and will not share it with third parties, unless such disclosure is necessary to:(a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Use, take precautions against liability, toinvestigate and defend ourselves against third-party claims or allegations, to assist government enforcement agencies in connection with an investigation or to protect the security or integrity of the Service and website. Information that you store or exchange on the Service will immediately become availableto those whom you have authorized to view such information, and Finalis is not responsible for the privacy or disclosure practices of such recipients. We restrict access by our personnel to such information except as necessary to maintain and provide the Service or if the customer requests our assistance. If Finalis is involved in a business divestiture, change of control, sale, merger or acquisition of all or a part of its business, we reserve the right to transfer your information. We will notify you of any change in control of your personally identifiable information and any choices you may have regarding the information.

RIGHTS TO ACCESS, LIMIT USE OF, AND LIMIT DISCLOSURE OF PERSONAL DATA

We collect a variety of information via the use of the Service and at the direction of customers, and may not have a direct relationship to the individual whose personal data those customers process. As an individual, if you have concerns about your personal information being processed or if you seek access or want to correct, amend or delete inaccurate data, please email us at email@finalis.com and we will work with you and the organization responsible for processing your personal data to respond to your request within a reasonable timeframe.

REQUIRED DISCLOSURES

In certain situations, Finalis may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

INQUIRIES OR COMPLAINTS

If you believe Finalis processes your personal data and have inquiries and concerns that you would like to discuss with us, please contact us at email@finalis.com.

USE OF THIRD-PARTIES

Finalis engages a limited number of third-party service providers to assist in providing the Service, including for management of some aspects of the Services and related support functionality.

YOUR CHOICES

We will share your personal information with third parties only in the ways that are described in this privacy statement. From time to time, we may disclose your personally identifiable information to certain third party vendors used by Finalis to assist us in providing the Service, to the extent necessary to enable such vendors to provide such assistance. These third parties are prohibited from using your personally identifiable information for any other purposes. If you do not want us to share your personal information with these vendors, email us directly at email@finalis.com. Such restrictions may limit our ability to continue to provide you with some or all of the Services.

CHANGES IN YOUR INFORMATION

You may update or correct your personal information and email preferences at any time by emailing us directly at email@finalis.com.

UPDATES AND CHANGES TO PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page. Such changes are effective when posted onthis page. By continuing to use the Service after the changes are made, you agree to be bound by the updated Privacy Policy. If you have any questions about this Privacy Policy, please contact us at email@finalis.com.

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This site is operated by Finalis, Inc. (“Finalis”), which is not a registered broker-dealer. Finalis does not give investment advice, endorsement, analysis or recommendations with respect to any securities. Neither Finalis nor any of its officers, directors, agents and employees makes any warranty, express or implied, of any kind related to the adequacy, accuracy or completeness of any information on this site or the use of information on this site. By accessing this site and any pages thereof, you agree to be bound by the Terms of Service and Privacy Policy.

Certain services so designated are offered by Finalis Securities LLC, Member FINRA / SIPC and an affiliate of Finalis, located at Sausalito, CA. Finalis Securities does not make investment recommendations and no communication, through this website or in any other medium should be construed as a recommendation for any security.

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