Finvisage - Privacy Policy
Privacy Policy
Effective date: 21 April 2020
We are committed to our relationship with you and your privacy is very important to us. We want to be sure you
understand the steps we have taken to protect your information such as collection, use and disclosure of Personal
Information we receive from users of this Site. Please read this privacy policy carefully as it contains important
information on who we are and how and why we collect, store, use and share your personal information. It also
explains your rights in relation to your personal information and how to contact us or supervisory authorities in theevent you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject tothe General Data Protection Regulation (GDPR), which applies across the European Union (including in the United
Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. This
policy is intended to help you understand:

Quick Links:
Please read the full Privacy Policy to ensure that you are fully informed. However, if you wish to read only a particularsection of this Privacy notice, please click on the relevant section to navigate to that section❏Who we are We meaning - Apex Financial Technology Limited (“us”, “we”, “our” or “ Finvisage”) operates ourcloud-based SaaS solution called Finvisage. For more information about us, please see the “About” sectionof our Website at https://www.finvisage.com/about-finvisage/. We follow the EUs GDPR Data Privacy
Regulations in all respects to protect the privacy of our customers and users.

❏What Information we collect about you The information that we collect from you depends on what Services you use, how you use the Services,and what information you choose to provide or make available to us. We may also have to collectinformation about you when you input it into the Services or in cases when you have to provide it directly
to us.
● Account Information: We collect information about you when you create or register your account,
input information or data into any of our Services, or post or upload permitted content to ourServices, submit questions, requests, any other sort of communications to us via contact us forms,email, other communication media, contact us for any technical support, visit our website,
participate in any surveys, demonstrations, or other events if any.
● Customer Information: Customer Information here is the information collected upon the creationof accounts or that otherwise identifies you as a customer or end-user of our Services. It may
include personal information such as your name, email address, gender, location data, professional
online presence e.g. LinkedIn, postal address and phone number. It may also include payment
information, such as payment method, credit card information, and any other contact information(such as name and postal address) associated with payment billing information.

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Content you provide through our products: We collect and store content that you post, send,
receive and share while using our products. This content includes any information about you thatyou may choose to include such as any feedback that you may want to provide us.
Content you provide through our website: The Services also include our website owned or operated
by us. We collect other content that you submit to these websites, which includes social media orsocial networking websites operated by us. For example, you provide content to us when you
provide feedback or when you participate in any interactive features, surveys, contests, promotions,sweepstakes, activities or events.
Information provided through our support services: This includes our customer support services,where you may choose to share or submit information regarding a problem that you may be facingwith a Service. You may be asked to provide contact information, a summary of your problem you
are facing, and any other relevant information as deemed relevant by the Support Team that would
be helpful in resolving the issue. You also give your consent to us to record any calls made by You
seeking support services via telephone that may be further used by us for our internal quality
training and testing purposes and provide better services to you.
Payment Information: When you register for our paid Services we collect billing andpayment-related information. For example, we ask you to provide us with the name and contact
information of the billing representative upon registration. We also ask for payment information,such as payment card details, which we collect via secure payment processing services.
Information collected automatically when you use the Services: When you use our Services wecollect information about how you use the Services, your actions on the Services including IPaddresses, what software and hardware you use such as browser types, operating systems, internet
service providers(ISPs), URLs of referring/exit pages, platform type, device type, mobile device
identifiers, mobile carrier, features of Finvisage product used, and related dates and time stamps,
search items, search terms, links clicked, and other statistics related to your usage of Services. We
use your IP address and/or country preference in order to approximate your location to provide youwith a better Service experience. We also gather this information to learn how our users,
customers, and the public are consuming our content and using our Services. How much of thisinformation we collect depends on the type and settings of the device you use to access theServices. We may also use tools, including third-party tools, to collect analytics data. Some of thisinformation is collected through the use of "cookies". We may also work with third-party partners
to employ tracking technologies.
Information we receive from other sources: Information about you will also be gathered from otherService users, from third-party services, social media platforms, public databases, from our relatedcompanies and from our other business and channel partners. We may combine this information
with information we collect through other means described above. This helps us to update andimprove our records, identify new customers, create more personalised advertising and suggest
services that may be of interest to you.
Third party providers: Information about you may also be received from third party providers ofbusiness information and publicly available sources such as the social media platforms,
professional networking sites which may also include physical mail addresses, job titles, emailaddresses, phone numbers, intent data (or user behavior data), and social media profiles, for the
purposes of targeted advertising of products that may interest you, delivering personalisedcommunications, event promotion, and profiling.
Finvisage partners: We may also work with a global network of partners who provide consulting,
implementation, training and other services around our product. Some of these partners may also
assist us in marketing and promoting our services, generating leads for us, and resell our Service toa wide range of customers all over.
Other users of the Services: There may be instances when other users of our Services may provide
information about you when they submit content through Services. An example such as - you may
have been mentioned in an issue opened by someone else in your team, a team member mayupload content about you or assign to be discussed. In case any other Service user invites you tothe Services and here we may have to collect your email address and other information required.
Similarly, an administrator may provide your contact information when they designate you as thebilling or technical contact on your company's account or when they designate you as anadministrator.
❏How we use the information we collect from you We use the information we collect for a variety of purposes such as which Services or features of theServices you use, how you use them, if or any preferences have been communicated to us. Below are thepurposes for which we use the information we collect and we have tried our best to include all the points
that cover how we use the information collected from you and if any points that are missed out you canbe assured that they would be used only for the purpose of improving the quality of the Services.
● To provide technical assistance or customer support to you● To respond to your queries, requests or any other information requested by you● To contact you to update the product upgrades, information about products that you have signed
up and informing about other Finvisage products, services and features that may probably be ofinterest to you and to monitor the performance of our marketing efforts.
● Creating, training, and administering your information and account, including identifying you withyour account.
● Billing and other payment-related information for products purchased from us● To communicate with you about your account and informing you about any changes in the policy● To verify and maintain the quality of the Services used by you● We use your information to derive market insights, ways to improve our Services, business analysis,for other research and development purposes to make sure we provide you with smarter, faster,
secure and also to obtain collective learnings (including feedback) about how people use ourServices to troubleshoot, to identify trends, usage, activity patterns for better Services to users.
● To communicate with you about the Services or features in the product that may be newly addedby using your contact information to send transactional communications via email, including
confirming your sign-ups, purchases, reminding you of subscription expirations, responding to yourcomments, questions and requests, providing customer support, and sending you technical notices,
updates, security alerts, and administrative messages.
● To market, promote and drive engagement within the Services● Securing the Services and our systems, and protecting your information and data
● Customising existing and future product offerings and other aspects of the Services to you andother users● To verify your identity and prevent fraud● Enforcing our terms and policies● Detecting security incidents, protecting against any possible malicious, deceptive, fraudulent orillegal activity, including violations of Service policies● Developing new products and services● To ensure internal quality control to provide best services to you and users of our products.
● Auditing relating to interactions, transactions and other compliance activities● To share customised materials about our products, offers, and other services that may be ofinterest, value add to your business, including new content.
● Other purposes you consent to, are notified of, or are disclosed when you provide personal
information● To protect our legitimate business interests and legal rights where required by law or where weidentify it is necessary to protect our legal rights, interests and the interests of others, we use
information about you in connection with legal claims, compliance, regulatory, and audit functions,and disclosures in connection with the acquisition, merger or sale of a business.

●●❏How we may share your information we collect Except as provided below we do not share, disclose, sell or rent your personal information to any
advertisers or third parties without your permission, however, we may store your information or data on
servers provided by third party hosting vendors or service providers with whom we have contractualagreements. We will not share personal information about you to third parties for their independent use
unless otherwise you specifically authorise Finvisage to do so.
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❏We may use your information for any other business purpose that does not conflict with thestatements made in the privacy policy
We may use your information with your consent to do so for a specific purpose. Say for example,
To publish testimonials or featured customer stories to promote our products with your consent.

If it is required to do so to share any information about you by law, regulation or any legal processthat may be involved such as the court order etc.,
If disclosure is necessary to prevent physical, financial, or any other loss, injury or harm inconnection with an investigation of suspected or actual illegal activity
Any requests received from government agencies, such as law enforcements or other nationalsecurity agencies
The information that we collect is shared in accordance with our legitimate interests and businesspurposes.
We may share your contact information with our channel partners, subsidiaries, affiliates, forbusiness purposes
We may share your information we collect with service providers such as payment processing,website hosting, technical support and marketing or promotional services.
We also reserve the right to transfer personal information in the event it sells or transfers all or aportion of its business or assets, or merges with another entity, in such a case Finvisage will use
appropriate measures to direct the transferee to use the personal information in a manner that is
consistent with this policy. You will be notified via email and/or a prominent notice on the Services
if any such transaction takes place, as well as any choices you may have regarding yourinformation.
As necessary to comply with applicable law, including governmental requests, law enforcement
requests, and otherwise to protect the rights, privacy, business, safety, or property of you, us, orthe public.
In certain situations we may share information we collect with affiliated companies and, in somecases, with prospective affiliates. Affiliated companies are companies owned or operated by us.
The protections of this privacy policy apply to the information we share in these circumstances.

❏How long your personal information will be kept / Data Retention -●We retain the personal information that we collect from you as long as your account is active and areasonable period thereafter in case you decide to re-activate the Services. It may also be retained
as necessary to fulfill the purposes for which it was collected for providing our services, tocontinue to develop and improve our services, to resolve disputes if any, establish any legal
defense, enforce our agreements or to comply with any applicable laws, for legal audit purposes.
When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymise it or, if this is not possible (for example, because your personal data has
been stored in backup archives), then we will securely store your personal data and isolate it fromany further processing until deletion is possible.

How do we secure your information -●❏We are an ISO 27001 certified company, which means we follow top industry standards for
information security. We take every appropriate administrative, technical and organisational
security measures to safeguard your personal information from loss, theft, unauthorised accessand misuse. Nevertheless, no security measures are 100% fool proof and transmission via theinternet is not completely secure and we cannot guarantee the security of information about you.
Please feel free to write to us at privacy@apexft.com for any questions that you may have about
the security of your personal information.

Third party links ●Occasionally we may provide links to a variety of third party social media sites or professional
networking sites as a service to you or to provide additional information related to our services
that may be of interest to you. These third-party sites have separate and independent privacy
policies. We therefore have no responsibility or liability for the content and activities of theselinked sites. Nonetheless, we always seek measures to protect the integrity of our site andwelcome any feedback about these sites.

❏Transferring your personal information out of the EEA To deliver services to you, it is sometimes necessary for us to share your personal information outside
the European Economic Area (EEA), in cases when we have /may have our offices outside the EEA, withyour and our service providers located outside the EEA, if you are based outside the EEA, in cases
where there is an international dimension to the services we are providing to you
These data transfers are subject to special rules under European and UK data protection law.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We
will, however, ensure the transfer complies with data protection law and all personal information will
be secure. Our standard practice is to use standard data protection contract clauses that have been
approved by the European Commission.

❏Data Subject Rights You have the following rights, which you can exercise free of charge.

Access

The right to be provided with a copy of yourpersonal information (the right of access)Rectification

The right to require us to correct any mistakes
in your personal information

To be forgotten / Deletion

The right to require us to delete your personal
information—in certain situations

Restriction of processing

The right to require us to restrict processing of
yourpersonal
information—incertaincircumstances, e.g. if you contest the accuracyof the data

Data portability

The right to receive the personal information
you provided to us, in a structured, commonlyused and machine-readable format and/or

transmit that data to a third party—in certain
situations
To object

The right to object:—at any time to your personal informationbeing processed for direct marketing (includingprofiling);—in certain other situations to our continued
processing of your personal information, eg
processing carried out for the purpose of ourlegitimate interests.

Not to be subject to automated individual
decision-making

The right not to be subject to a decision based
solely on automated processing (includingprofiling)that
produces
legaleffects
concerning you or similarly significantly affectsyou

For further information on each of those rights, including the circumstances in which they apply, please contact us
or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General
Data Protection Regulation.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may
continue to retain and use information even after a data subject request for purposes of our legitimate interests,
including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce ouragreements.
If you have any issues with our compliance, you may contact our Data Protection Officer at privacy@apexft.com.
You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.
❏ Changes to our Privacy Policy ●❏We may change this privacy policy from time to time. We will post any privacy policy changes on
this page and/or update the Privacy Notice modification date at the top of this Notice. We
encourage you to review our privacy policy whenever you use the Services to stay informed about
our information practices and the ways you can help protect your privacy.

How to contact us ● If there are any questions regarding this Privacy Notice or your privacy rights you may contact us at
privacy@apexft.com● The Data Controller of your personal data is Apex Financial Technology Ltd, 128 City Road, London
EC1V 2NX, United Kingdom. For details regarding other Data Controllers in our group, please see
https://www.finvisage.com/contact-finvisage/