FI Connect Privacy Policy

Last updated and effective as of Aug 7th, 2023.

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date.

Our commitment to your privacy

Protecting your privacy is important to us. FI Connect maintains this Privacy Policy to help you understand our commitment to safeguard the privacy of your Personal Information. We want you to understand how we collect, use, disclose and protect your information received through our website, online services, third-party providers, or through applications submitted by our customers (collectively, “Information Channels”).

This Privacy Policy describes:

How we safeguard your information.
How, what, and why we collect certain information about you.
How we use your information and with whom we share it.
How you can access and update this information.
The choices you can make about how we collect, use, and share your information.

Contact us

If you have any questions regarding this Privacy Policy or our information collection and use practices, please contact us at [email protected] OR (866) 918-2898 OR by mail at 5680 Greenwood Plaza Blvd, Suite 400, Greenwood Village, CO 80111.

Safeguards

FI Connect maintains industry safeguards, in accordance with applicable federal and state laws and regulations, to keep your Personal Information safe and secure. When we provide Personal Information to financial entities, our affiliates, or third-party service providers, we require that those parties agree to process and keep the information in compliance with applicable privacy laws. The use of your information by our business partners may be subject to that party’s own privacy notice. Unless we are permitted by law, we will not disclose the information we collect about you from consumer or credit reporting agencies, without your consent. For certain online features or services, such as those that may include Personal Information, we require the use of username/password and/or encryption technologies for the protection of your Personal Information. You are responsible for protecting your username, password, and other user account information from disclosure to third parties, and you are restricted from circumventing the use of required encryption technologies. You agree to: (a) immediately notify us at [email protected] OR call us at 866-918-2898 of any unauthorized use of your username, password, and/or user account information, and/or any other breach of security; and (b) make sure that you log out from your user account at the end of each session. While we may provide certain safeguards to protect your confidential information, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.

Your consent to this privacy notice

You consent to the collection and use of your information by FI Connect in compliance with this Privacy Policy by submitting your Personal Information to FI Connect, or by using our services, unless you inform us otherwise, as allowable by law. Your available information choices are set forth below.

Browsing Information

Like most online services, we collect standard technical, information when you use our Services, including, but not limited to unique device identifiers, internet protocol (IP) addresses, browser types, internet service providers (ISPs), the number and duration of page visits and the number of clicks. We may use cookies, which are small pieces of data stored on your device which include an anonymous unique identifier, for session purposes. We may use tracking systems for certain systems, and we recognize Do Not Track requests from internet browsers or similar devices with regard to consumers, but not for Financial Institution employees acting within the scope of their employment.

Types of Information We Collect and Sources

We may collect certain information from you, and third parties we engage may also collect such information for the purpose of, administering and processing your transaction. We do not use your personal or sensitive information for additional purposes that are incompatible with the disclosed purpose for which the information was collected without providing you notice. We do not retain your personal information longer than is reasonably necessary to complete these services.

Information we may collect about you may be collected by from the following sources:

Applications or other forms we receive from you or your authorized representative (such as name, address, employment information)
Correspondence you or others send to us
Information such as account or loan numbers we receive through our Information Channels, i.e. financial institutions, third-party providers.
Information from consumer or other credit reporting agencies and public records maintained by government entities that we obtain directly from those entities, including your credit worthiness and credit history
Information we receive from other sources, as permitted by applicable, laws, and regulations

We do not share your Personal Information with third parties other than as set forth in this Privacy Policy.

Sensitive Information

We may collect certain sensitive information from you solely for the purpose of administering and processing your transaction, or to verify a request from you under the California Consumer Privacy Act We do not sell or share your sensitive personal information. The sensitive information we may collect from you may include:

Social Security Number
Driver’s License
State identification

FI Connect does not collect or process sensitive personal information with the purpose of inferring characteristics about a consumer, nor use or disclose sensitive personal information to service providers, contractors or third parties other than to perform the services for which it was obtained.

Use of Collected Information

The information we collect from you is used for one or more of the following business purposes:

To provide products and services to you or any financial entity or other third party who is obtaining services on your behalf, or in connection with a transaction involving you
To communicate with you regarding your transaction or our products and services
To improve our products and services
To personalize your user experience regarding our information channels
To verify your identity or determine your creditworthiness.
To respond to law enforcement requests, court orders, or governmental regulations

FI Connect has collected consumer Personal Information in these categories within the last 12 months.

When Information is Disclosed or Shared

We are permitted by law to disclose your Personal Information to various companies and individuals, without obtaining your permission. Certain laws do not allow you to restrict these disclosures. In the section below entitled, “Your Information Choices,” we share with you how to limit certain disclosures of your Personal Information.

We may disclose personal information to service providers, unaffiliated third parties for a business purpose, and to government agencies and regulatory authorities. FI Connect does not share or sell your Personal Information to any entity.

When we disclose personal information to a service provider or third party for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services required. We disclose personal information for business purposes to the following categories:

Our affiliates
Service providers, such as business process outsourcers
Governmental agencies and regulatory authorities
Third parties such as credit unions or other finance companies

FI Connect has disclosed Consumer Personal Information with these entities within the last 12 months for the business purposes noted herein.

Your Information Choices

FI Connect may use your Personal Information for the following purposes, which such use cannot be limited by you:

For our everyday business purposes – to process your transactions, respond to law enforcement or other government authorities regarding an investigation, and subpoenas or court orders
For our own marketing purposes
For our affiliates’ everyday business purposes, we may share information about your transaction and experiences

We do not disclose or use your Personal Information in the following circumstances:

For our affiliates’ everyday business purposes – information about your credit worthiness
For joint marketing with financial companies
For our affiliates and non-affiliates to market to you

Updates and Corrections

If you wish to correct or update your Personal Information in our possession, you may do so by using the methods provided under the “Contact Us” section as specified at the beginning of this Privacy Policy.

State Specific Privacy Laws:

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents certain rights to know what personal information we collect about them and how we collect, disclose and protect their personal information. This information is set forth above in “Types of Information we Collect” and “When Information is Disclosed or Shared.” The CCPA also provides individual California residents with a right to correct their information, opt-out of the sale of personal information, and a right to request that a business delete their personal information subject to certain exemptions under the CCPA. The consumer has the right to limit the use and disclosure of sensitive personal information collected about them and the right of data portability.

Right to Access

CA residents have the right to request that we disclose certain information to you about our collection, use, and disclosure your personal information. If FI Connect has verified the request is coming from you or an authorized party, and you have not made this request more than twice in a 12-month period, and we have confirmed the information collected is subject to the CCPA, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting, sharing, or selling your personal information.
The categories of third parties with whom we share your personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold your personal information, the categories of personal information sold and the categories of third parties to whom personal information was sold.
If we disclosed your personal information for a business purpose, the categories of personal information disclosed.

We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us, or the security of our systems or networks.

FI Connect does not sell or share your personal information as defined under the CCPA.

Right to Request Deletion

CA residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify a consumer request, we will erase your personal information from our records, unless an exception applies, or de-identify or aggregate the personal information. There may be instances where applicable law and regulatory requirements allow or require us to retain personal information. We may deny a deletion request if it is necessary for us or our service providers to maintain your personal information for any of the reasons set forth in the CCPA.

Most of the personal information FI Connect obtains is subject to the CCPA exemptions for personal information subject to the Gramm-Leach-Bliley Act (“GLBA”) and the Fair Credit Reporting Act (“FCRA”),

Exercising Access, Data Portability, Deletion and Correction Rights

To exercise these rights as described above, please submit a verifiable consumer request to us using our contact information at the top of this policy labeled “Contact Us”.

Right of Non-Discrimination

We will not discriminate against you for exercising any of your rights in this Privacy Policy and under applicable laws. Unless permitted by law, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price for goods or services or a different level or quality of goods or services.