We at Finso Holding Limited (“Finso”, “we”, “us” or “our”) are constantly striving to provide excellent service to you, our clients and business partners while building a long-lasting relationship with them. To achieve these goals, we may need information about you when you visit our sites or use our software products.

This policy covers how Finso collects, uses and protects the information we gather through your use of Finso Websites and the Finso Software Products (both are defined below), and in connection with off-line communications.

Specifically, Finso may collect this information from transactions, orders, electronic analytics, offline and online registrations and forms, communications and interactions, and sales inquiries and other software-based actions.

No matter how Finso comes to have your information, we want you to know that we respect the privacy of your information and that you should be aware of how we handle it and protect it.

Being fully aware of our responsibility as Data Controller and Processor, we protect and process your personal data in accordance with the guidelines described below.

This policy covers the information practices of our websites and software products that link to this policy, which includes but not limited to: Finsopay.com and Finso.com.tr, as well as all international domains and sub-domains (collectively referred to as “Finso Websites” hereinafter), and Finso Mobile Apps and Finso Retailer Portals (collectively referred to as “Finso Software Products” hereinafter) which may show differences from country to country due to local laws and regulations. Our Finso Websites and Finso Mobile Apps may contain links to other company websites.

Please be aware that our privacy policy does not apply to these other websites.

Although Finso uses great care to select content for our Finso Websites, including links to websites of third parties, we disclaim any responsibility for content that is found on these other websites. We encourage you to review the privacy statements of the other websites to understand their information practices.

Clients, business partners, staff and candidate staff of Finso together with the site users are hereinafter collectively referred to as “parties.”

Finso does not

Finso does

Finso has always valued your privacy, and we reinforce this belief throughout our organization. Your information will be processed and protected as described here. Additionally, you may refer to sections “How Finso Uses and Shares This Information” and “Your Rights as Personal Data Holder” in this document to lean about processing of your personal data and legal rights. If you have further questions about our privacy policy, please Contact us.

Addressee: Visitors of Finso Websites 

Within our Finso Websites, you may be asked to give us personal or organizational contact information (like your name and surname, address of your organization and e-mail address) in order for you to receive information about our services or  business partnership opportunities. We may collect this information through either Contact or Newsletter Subscription communication components on our websites. Your e-mail address may be used to send you information about our company, product updates, special offers, and newsletters. To opt out of receiving communications from Finso, please Contact us.

Addressee: Finso Customers

Finso Mobile Apps are software applications on mobile platforms and designed to provide you fast, accurate and satisfactory financial services. In order to benefit from these services, Finso Mobile Apps require registering a membership profile which includes submission of your:

after your approval of the Privacy Policy of the relevant Finso Mobile App. You are not registered as a Finso Customer unless you provide your consent via OTP confirmation. Within Finso Mobile apps, you may  optionally provide information specific to your financial situation. Additionally, you may be required to give product delivery address, and optionally you may upload a profile photo.

Please note that persons under 18 are not eligible to register as Finso Customer or use Finso Mobile Apps.

Addressee: Finso-partnered Retailers

All Finso-partnered Retailers must provide their legal documents while registering to Finso, and Finso Retailer Portals are software applications on cloud platforms, designed to provide these Retailers to manage their sales and accounts.

Finso logs all transaction made and stores all information processed by the Retailer on the portal. Details of information collected by Finso in this context and its treatment are explicitly stated in the business agreement signed between Finso and the relevant Finso-partnered Retailers.

Addressee: Finso-partnered Banks

All Finso-partnered Banks must provide their legal documents while registering to Finso, and Finso integrates with the financial services of these Banks to verify Customer, get Customer banking information and execute transactions on behalf of the Customer as well as fetch current public information about the Banks.

Finso logs all transactions and stored information submitted,processed or derived in the context of financial integration. Details of information collected by Finso in this context and its treatment are explicitly stated in the business agreement signed between Finso and the relevant Finso-partnered Bank.

Addressee: Callers of Finso Call Centers 

When you contact our call centers, you may be required to provide your identity and other personal information depending on the issue. All such information are safely recorded by our certified operators in our data center to follow up and resolve the issue.

Addressee: All Parties

Finso may collect information by other means, including but not limited to:

Addressee: Visitors of Finso Websites and Finso-partnered Retailers

As you browse our Finso Websites or use our Finso Retailer Portals, our web servers collect information about your visit and transactions, not about you personally. Via Web server logs, we monitor statistics such as:

While we gather this type of information, none of it is associated with you as an individual. We use these statistics to improve our Finso Websites and Finso Retailer Portals, to monitor their performance, and to make it easier for you and other visitors to use the sites.

Our Finso Websites and Finso Retailer Portals also log Host Names (or IP addresses when the Host Name is not available) for systems administration and security purposes. These logs are monitored and analyzed to maintain systems and information security and allow us to constantly improve the value and the availability of the web content.

Cookies

A cookie is a small, encrypted data string our server writes to your hard drive that contains your unique User ID. Cookies on the Finso Websites may collect a unique identifier, user preferences and profile information and membership information. Finso’ server will query your browser to see if there are “cookies” previously set by the Finso Websites.

We use both session ID cookies and persistent cookies to deliver Web content specific to your interests and to control access to restricted content. Session ID cookies expire when you close your browser. Persistent cookies remain on your hard drive after you leave our Finso Websites or Finso Retailer Portals. The majority are set to expire within 90 – 365 days. We also use cookies to collect general usage and volume statistical information that does not include personally identifiable information.

A cookie cannot be used to access or otherwise compromise the data on your hard drive. On our Finso Websites, we offer an opt-out for cookies. However, in any case, browsers provide you information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. You can generally disable the cookie feature on your browser without affecting your ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion and might be required to complete certain functions.

Third Party Cookies

Finso may engage one or more third party service providers to track and analyze usage and volume statistical information from visitors to the Finso Websites. The service provider(s) set cookies on behalf of Finso.

Widgets

We may use widgets which are interactive mini-programs that run on our site to provide specific services from another company (e.g., links to bookmarked sites). Some information, such as your e-mail address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.

Embedded URLs

We also use a tracking technique that employs embedded URLs to allow use of the site without cookies. Embedded URLs allow limited information to follow you as you navigate the site, but is not associated with personal information and is not used beyond the session.

Embedded Pixels

We may use embedded pixel technologies on selected pages for the purposes of identifying unique user visits as opposed to aggregate hits. Moreover, embedded pixels or other technologies may be used in e-mails to provide information on when the e-mail was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient’s e-mail address.

Addressee: Finso Customers

Finso Mobile Apps need to be highly secure to safeguard your identity as well as all other information including your transactions and banking information. Your Finso Mobile account, device and application coupling approach is established to prevent fraud during your mobile operations. For this reason, your device information (brand, model, device identity etc.) is collected by your Finso Mobile App.

Additionally, your geo-location information may also be collected to give you better service, especially in guiding you to Finso-partnered Retailer or Bank locations. However, you always have the opportunity to cancel this feature via location settings of your mobile device.

Addressee: All Parties

As a result of its core business, Finso collects statistical information over Finso Websites and Finso Software Products to understand:

None of which is directly associated with you personally.

Addressee: All Parties

Information you provide us may be shared with our Partners who help to provide our services. Finso never sells your personal information to any other third party organization, except in selling our business. Your information may be used for the following purposes:

To Engage in Transactions We may use personal information such as name, e-mail address, and company to engage in transactions with you, including contacting you about your partnership requests or other issues.

To Provide Support or Other Services We may use your personal information to provide you support or other services or products you have ordered or you are interested in, as well as product updates and fixes and other similar communications.

To Communicate with You About a Conference or Event We may communicate with you about a conference or event hosted or co-sponsored by Finso or one of our partners. This may include information about the event’s content, event logistics, payment, updates, and any additional meetings, special demonstrations or other customer facilitation that we may provide related to an event for which you have registered. We may contact you after the event about the event and related products and services and may share information about your attendance with your company.

To Provide Online Forums and Social Networks Some services available on the Finso Websites and Finso Software Products may permit you to participate in interactive discussions, post comments, opportunities or other content to a bulletin board or exchange, or otherwise engage in networking activities. Some of these services are moderated; all may be accessed for technical reasons. Finso does not strictly control the content that users post to these forums or social networks. Content posted in these public areas, including advice and opinions, represent the views and is the responsibility of those who post the content. Finso does not necessarily endorse, support, verify or agree with the content posted. Any personal information that you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. You should carefully consider whether you wish to submit personal information to these forums or social networks and should tailor any content you submit appropriately and in accordance with the relevant terms of use.

To Tailor Marketing to Your Needs and Respond to Your Requests We may use your personal information to notify you about status of your transactions, needs for your approval, new product releases and service developments, or to respond directly to your requests for information.

To Post Testimonials We may post testimonials on our Finso Websites which may contain personal information. In such cases, prior to posting the testimonial, we obtain their consent to post their name or photo along with their testimonial.

To Comply with Legal Requirements Finso may be required to disclose your personal information in order to comply with legally mandated reporting, disclosure or other legal process requirements, including criminal or fraud investigations, and enforcement of our rights, your rights and others. We will use reasonable efforts to limit your personal information for these purposes.

Addressee: Finso Customers

Your personal information you provide in Finso Mobile Apps is only shared with the Finso-partnered Banks and Finso-partnered Retailers just in case you make a request such as forming a shopping cart or loan application through your account in you Finso Mobile App, and may be used for the following purposes:

To Process Transactions All information you knowingly give us in Finso Mobile Apps will be used upon your in-app process request for loan applications, opening bank accounts, reviewing your account balances, money transfers and purchasing in-app products, and for notifying you on various updates. Your process requests are executed only with your approval via security mechanisms which may vary depending on the mobile banking security policies of relevant Finso-partnered Banks. In this case, all of your information may be shared with the Finso-partnered Banks related to your process request in order to render quick, complete and accurate service to you.

In the same context, your name, surname and mobile phone number are shared with a Finso-partnered Retailer only if you explicitly intent to purchase an item or a set of items from that retailer at its store location or e-commerce site, and provide your mobile phone number to the retailer to form your shopping cart . Your product delivery address is also shared with the Finso-partnered Retailer to complete the purchasing.

Information Security

The security of your personal information is very important to Finso. You may refer to Processing of Personal Data Explanatory Statement to be informed on processing and protection of your personal data.

We have in place physical, administrative and technical safeguards designed to protect your personal information from unauthorized access. Additionally, Finso uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details. When you enter sensitive information such as your credit card number on our site, we encrypt it using Secure Socket Layer (SSL) technology.

In the event that your personal information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, we will notify you of the breach by e-mail, fax, or surface mail. We will give you notice promptly, consistent with the reasonable needs of law enforcement and/or Finso to determine the scope of the breach and to investigate and restore the integrity of the data system.

Commitment to Children’s Online Privacy

Finso Websites and Finso Software Products are not directed at children. Finso does not knowingly accept online personal information from children under the age of 18. If you are under 18 or otherwise would be required to have parent or guardian consent to share information with Finso, you should not send any information about yourself to us.

Data Storage and Cross Border Transfers

Finso operates worldwide, and have developed global data practices designed to assure your personal information is appropriately protected. Finso stores and processes information of all parties in secure data centers located within the borders of your country of residence. Please note that your personal information is never transferred, accessed and stored globally. However, information you provide via Finso Webservers or Call Centers may be stored in servers located worldwide. Therefore, by using Finso Websites or Call Centers, you consent to the transfer of information to Finso data centers located at countries outside of your country of residence.

Sensitive Information

We ask you not to send us or share any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership).

Update & Correction

If you have any privacy concerns or would like to correct and/or update your information, please Contact us.

While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within fifteen days.

Oversight

If you have comments or questions about our privacy policy, please Contact us. We will address any issue to the best of our abilities.

Changes to Policy

Finso keeps this privacy policy under regular review. When this privacy policy is updated, we will post a prominent notice in this section of this policy notifying users when it is updated. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you via e-mail, and you will have a choice as to whether or not we use your personal information in this different manner.

This privacy policy was last updated on January 06, 2020.