Effective Date: May 1, 2017
To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
1. What Information Does the Site Collect?
(a) Information You Provide to Us
On the Site, we may ask you for limited information prior to the launch of the Finbooth Service relating to first and last name and email address, and thereafter, we may ask you to provide certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, phone number, government identification numbers, username and password, financial information, date of birth, citizenship, home address, photo and email address (“Personal Information”); and (2) business information, such as information about the company you work for, business contact information, your job title and company financial information (“Business Information”). We may collect this information from you at various times and places, such as when you:
- Create or update an account or otherwise save your information with us on our Site;
- Submit information about your accounting business (for accountants);
- Contact us regarding a question or concern such as when you make inquiries concerning our Site;
- Participate in any location-based services we offer (e.g. to provide you with information about accountants near you based on your location);
- Provide feedback, such as personal testimonials, reviews, ratings or compliments;
- Request to receive information from us; and/or
- Otherwise interact with the Company or the Site.
Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features.
(b) Information We Collect When You Use the Site
In addition to information that you choose to submit to us, we and/or our third-party service providers may use automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:
- your Internet Protocol (“IP”) address, UDID or other unique identifier (“Device Identifier”); A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- transaction details related to your use of our Site, including the type of services you requested or provided, date and time the service was provided, amount charged, and other related transaction details;
- the URL that referred you to our Site;
- the areas within our Site that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day you visit our Site, among other information.
We may use various methods and technologies to collect and/or store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
- Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some (but not all) instances can be blocked by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options. Please note that these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, visit www.adobe.com. Please understand that if you disable or remove any type of cookie, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.
- Web Beacons. A web beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages. Web beacons may be used by us for a number of purposes, including to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- ETag, or entity tag. An ETag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use the above Tracking Technologies (or ones we incorporate in the future) for a variety of purposes, including:
- To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of shopping cart functionality;
- To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
- To offer you enhanced functionality when accessing the Site, including identifying you when you sign‑in to our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
- To deliver content, including ads, relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements and/or content.
(c) Information We Collect From Third Parties
(d) Information We Collect When You Interact with Third-Party Sites
(e) Information You Provide About a Third Party
You may send someone else a communication from the Site, such as sending an invitation to a friend. If so, the information you provide (e.g., names, email addresses, phone number, etc.) will be used to facilitate the communication. You acknowledge that you have the recipient’s permission to use his or her information for this limited purpose. Please be aware that when you use any send-to-a-friend functionality on our Site, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.
2. How We Use the Information We Collect
We may use your Personal Information, Business Information or Usage Information for various purposes, including, but not limited to, the following:
- Operating our business, including providing services you request, such as enabling you to hire, engage, communicate and share information with one or more independent accountants;
- Sending you marketing information about Company and other third parties we work with, including through direct mail offerings;
- Sending you email communications such as electronic newsletters about our services and Promotions;
- Enabling you to participate in the Site’s features such as surveys and Promotions;
- Improving the effectiveness of our Site, marketing endeavors and service offerings;
- Offering you location-based services (e.g., to provide you with options for one or more independent accountants near you);
- Processing Site account registration;
- Processing or facilitating payments for services rendered;
- Enabling features that allow you to share information with other people, such as when you submit feedback or refer a friend to Finbooth;
- Providing customer service, including responding to your inquiries regarding our services;
- Sending you information about orders you have made on the Site;
- Identifying your service preferences, providing personalized content and ads and informing you of new or additional services and Promotions that may be of interest to you;
- Helping us address problems with and improve our Site and services;
- Protecting the safety, security and integrity of the Site;
- Investigating or addressing claims or disputes relating to your use of the Site, or as otherwise allowed by applicable law;
- For internal business purposes; and
3. Sharing of Information with Third Parties
(a) Sharing of Your Information with other Users. As a convenience to you and your accountant, we may share your information, your order, and/or your order history with your accountant. For example, if you are a business user (i.e. not an accountant), we may share your Personal Information, including your name, photo, financial information, among others, with your independent accountant that you select to provide you with accounting services. Based on your selection of access credentials to grant the accountant, we would share your Business Information to the accountant at your specific direction. If you are an accountant, we may share information with other users, including your profile, your certification and license credentials, your location, your average rating provided by other users, tasks performed and transaction details.
(b) When You Request We Share With Third Parties. You may be presented with an option to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their content on our Site. This may include using third-party tools such as Facebook, Twitter, LinkedIn or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(c) Sharing Information With the General Public. We love hearing from our users, including through publicly accessible blog and interactive forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You should use caution when deciding whether to disclose your Personal Information in these areas of the site.
(d) Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as: (i) to assist us in Site operations; (ii) to manage a database of customer information; (iii) hosting the Site; (iv) designing and/or operating the Site’s features; (v) tracking the Site’s activities and analytics; (vi) enabling us to perform other administrative services; (vii) providing services as independent accountants; and (viii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.
(f) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Business Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
4. Information You Disclose Publicly
(a) User Content and Public Information. The Site may permit you to submit ideas, photographs, videos, audio recordings, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), on blogs and message boards, product reviews and other public forums. We or others may store, display, publish, distribute or otherwise use User Content online or offline in any media or format and may or may not attribute the User Content to you. Others may have access to this User Content and may have the ability to share it with third parties. Please note that Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Site or what others do with information you share with them on the Site.
(b) Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit, please review our Terms & Conditions. By connecting with the Company brands through our social media pages or accounts, or by posting content using Company-created hashtags or other identifiers, you are providing your consent for Company to use any Personal Information or other content you submit or make available through such sites for marketing and promotional purposes, including, but not limited to, incorporation into our marketing materials, without further notice or compensation.
5. Ads and Information About You
This collection and ad targeting may take place both on our Site and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts.
6. Third-Party Content and Links to Third-Party Sites
The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site, you may be directed to other services that are operated and controlled by third parties. We are not responsible for the data collection and privacy practices employed by any of these third parties. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may independently collect data about you and may or may not have their own published privacy policies.
We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: email@example.com, with “California Privacy Rights” as the subject line. You must include your full name, email address, and postal address in your request.
8. Transfer of Information to and from the United States
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. We have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect. Credit card and other information are transmitted by secure servers (SSL). Further, access to your account information requires a username and password. You must keep your password confidential and you should always logout and close your browser when you finish your session.
Though no service is impenetrable, our service is built on top of Amazon Web Services (AWS). Amazon maintains ISO 27001 and SAS70 Type II certification for the AWS infrastructure, and has years of experience managing and securing large-scale data centers. More details about AWS security are available at http://aws.amazon.com/security/.
However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk. ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING THE SITE, APPLICATIONS, AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF OUR WEBSITE, APPLICATIONS, OR OTHER SERVICES PLEASE CONTACT US IMMEDIATELY AT INFO@FINBOOTH.PRO.
10. Updating and Modifying Your Communications Preferences
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to review, correct or update Personal Information you have provided through the Site’s forms, and you may provide updates and changes by contacting us via email at firstname.lastname@example.org. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.
We will give you, or anyone listed as an authorized contact for your account, information about your order/subscription information. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. You may grant or deny access to your order by setting the access credentials on your dashboard. We may send a confirmation email to your authorized contact(s), alerting them that they have been added as an authorized contact.
We encourage you to periodically review this policy for the latest information on our privacy practices.
13. Contacting Us