This Website Privacy Policy (“Privacy Policy”) covers the web sites (“Web Sites”) and services (“Services”) operated by FinTech Solutions Ltd (“Fintech Solutions” or “we” or “us” or “our”), including but not limited and the services provided by us through our products, the DeskRunner CRM Platform. This Privacy Policy describes the types of information that we collect, what we do with it, how we protect it, and if and when we disclose it to third parties. This Privacy Policy is a part of and subject to the Fintech Solutions Terms of Service (“TOS”). Accordingly, when you enter into the TOS, you agree that you have read, understand, and agree that we can collect, use, and disclose your information in accordance with this Privacy Policy. If you do not agree or are not comfortable with any part of this Privacy Policy, you should not agree to the TOS (including this Privacy Policy) and you may not use the Web Sites or our Services. Additional information about Fintech Solutions’ Data Privacy and Data Security practices, including Fintech Solutions’ commitments with regard to the General Data Protection Regulation (GDPR), can be found at the bottom of this page.

Information Gathering, Processing and Usage

In connection with operation of the Web Sites and providing the Services to you, we may collect the following types of user information (“Information”):

• Personal Information. We collect personal information (“Personal Information”) from you. This Personal Information is used for billing purposes, account management purposes and for you to utilize the features of the Web Sites to which you have purchased access. Examples of Personal Information we might collect include but are not limited to: first name, last name, email address, mailing address, etc. We also collect Personal Information provided to us via any contact forms you have completed (whether on the Web Sites or via social media), and any emails you send to us.

• Browsing Information. We collect information about your computer hardware and software and browsing activity.

• Customer Information. Through the use of the Services, you may enter and upload information relating to your customers and leads (“Customer Information”) which might include, but not be limited to, first name, last name, email address, mailing address, KYC information, financial information, etc.

We collect and process this Information to contact you, for billing purposes, to identify you when you use our Services and to enable you to use our Services. As a general rule, we never disclose Information to third parties. The only circumstance in which we may disclose Information would be to prevent an emergency, to protect or enforce our rights, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a subpoena or court order). The basis for the processing of your Personal Information is consent (when we contact you regarding our services or process Customer Information on your behalf in order to provide the Services) or legitimate interest (where we use your Personal Information in an emergency, to enforce our rights or as required under law). We will only access Customer Information when we are required to provide support services to you and for limited purpose only.

Cookies

To enhance your experience on our Web Sites, many of our web pages use “cookies”. Cookies are bits of electronic information that a web site can transfer to a visitor’s hard drive to help tailor and keep records of his or her visit. Cookies are required to use many Fintech Solutions’ Services. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access some of Fintech Solutions’ Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Web Sites. If you proceed with using our Web Sites without deactivating cookies through your browser, you are deemed to have accepted our use of cookies.

Analytics

We may use third-party service providers to monitor and analyze the use of our Web Sites. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Web Sites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Web Sites available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Web Beacons

Pages of our Web Sites or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). You are always free to block, delete, or disable these technologies if your browser.

Protecting Personal Information

We understand the importance of safeguarding your Information. We employ administrative, physical, and electronic measures designed to protect your Information from unauthorized access. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedom. Despite our efforts, we cannot guarantee the security of your Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Children’s Privacy

We are committed to protecting the privacy of children. Our solutions are not intended for anyone under the age of 18. If you are under 18, do not use or provide any information on or through our solutions. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 18, please contact us so that we can delete the child’s information. Our services will never knowingly accept, collect, maintain or use any information from a child under the age of 18. If a child whom we know to be under the age of 18 sends Information to us online, we will only use that information to respond directly to that child or notify parents.

Privacy Policy Updates

This Privacy Policy may be updated periodically and without prior notice to reflect changes in our online information practices. We will post a prominent notice on this Web Site to notify you of any significant changes to our Privacy Policy and indicate at the bottom of the policy when it was most recently updated.