Last updated February 06, 2023

Privacy Policy

Introduction.

This Privacy Policy ("Policy") is stating the details relating to personally identifiable information FinOctopus collects and uses or that the Users provide to FinOctopus through the Services, and to the User's rights hereunder.

The term "FinOctopus" in this Policy refers to FinOctopus Limited Liability Company, a Missouri limited liability company with registered office at 1617 Main St., Fl. 3, Kansas City, MO 64108, formed under the laws of the State of Missouri, USA, together with FinOctopus affiliated companies and subsidiaries, such as CREDEO FINANCE INC., a legal entity incorporated on June 28, 2016 under the laws of the Commonwealth of Virginia, USA (entity (file) number: C3928173), licensed as a California Finance Lender under the Department of Financial Protection and Innovation, license number 60DBO-61880, having its registered office at 8383 Wilshire Blvd, Suite 430, Beverly Hills, California, 90211, USA; and “User”/”Users” means you as a user of FinOctopus Services.

This Policy applies to all means of access to:

FinOctopus' website https://www.finoctopus.com/, including all subdomains (collectively - the "Website");
FinOctopus application, which shall refer to and consist of the following: (i) the mobile software application, including, without limitation, any software code, scripts, interfaces, graphics, displays, text, documentation and other components; (ii) the physical, electronic hardware device, including, without limitation, any firmware code, software code, scripts, cables, interfaces, connected and related vehicles, documentation and other components; (iii) any updates, modifications or enhancements to the items listed in subsection (i); (iv) any specific website the Application directs the User to via any browser located on a mobile device or any other computer device; (v) any add-ons and extensions to third-party websites; and (vi) any website usage and dashboard software (collectively - the “Application”);
FinOctopus' services or any other products, features, technologies or functionalities, websites, software and copyright assets and other services which FinOctopus have or have licensed to Users and/or which are offered by FinOctopus through the Website or any other means (collectively - the "Services").

This Policy should be considered an integral part of, and should be read together with FinOctopus Terms and Conditions located at https://www.finoctopus.com/terms_and_conditions (the "Terms").

By clicking an “agree” or “activate” or “sign up” or similar button or by installing and/or using the Website, Application(s) or any of the Services, the User accepts and agrees to abide by all of the terms and conditions stated or referenced herein and in the Terms.

Should the User have any questions about our processing of Personal Information or about this Policy, please refer to the last section of the document for information on how to get in touch with FinOctopus.

The term "Personal Information" in this Policy refers to personally identifiable information the User provides when using the Website, Application(s) and/or the Services and/or the and/or in any other contact with FinOctopus, its affiliates and their shareholders, members, directors, officers, employees, partners, agents, vendors, content providers, and representatives, except for any anonymized Personal Information. The term "Affiliated Parties" in this Policy refers to FinOctopus' partners, affiliated companies and third parties.

PLEASE READ THIS POLICY BEFORE USING FINOCTOPUS’ WEBSITE, APPLICATION AND/OR THE SERVICES. IF YOU DO NOT AGREE WITH THIS POLICY AND TERMS, PLEASE DO NOT USE THE WEBSITE AND/OR APPLOCATION(S) AND/OR THE SERVICES.

What Personal Information does FinOctopus collect?

FinOctopus collects and processes the following types of the User's Personal Information:

Identification Data, such as the User’s name (business name), truck owner first name and last name, driver’s first name and last name, shipper/carrier EIN number;
Contact Data, such as the Users’ phone number(s), business phone number(s), mailing address, garage address and e-mail address;
Services Data, including but not limited to US DOT number, drivers’ license number, current insurance certificates’ numbers and expiry date, date of current insurance certificates’ expiration, VIN numbers, Loss-Run report, VIN Numbers, CAB Report, IFTA Report;
Verification Data, including but not limited to phone number(s) and email address;
Financial Data, such as the Users’ payment card details and billing address, invoice details (invoice id and number, invoice completion date, invoice amount, invoice payment method and payment details, BOL digital data);
Transaction Data, such as the details about Users’ actions on or relating to the Website, Application and/or the Services and payments between the User and FinOctopus and any other details about actions relating to the Website, Application and/or the Services made by the User;
Technical Data, such as the Users’ login data, internet protocol addresses, browser types and versions, operating systems and platforms and other technologies on the devices Users use to access the Website, Application and/or the Services;
Profile Data, such as Users’ usernames and passwords, purchases and orders, Users’ interests, preferences, feedback;
Usage Data, such as the information about how User uses the Website, Application and/or the Services; and
Marketing and Communications Data, such as the User’s preferences in receiving marketing communications from FinOctopus and User’s communication preferences.

FinOctopus does not collect any sensitive data about Users that includes details about their religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Users’ health and genetic and biometric data.

FinOctopus only collects Personal Information that it deems to be reasonably necessary to fulfill Users’ requests and FinOctopus’ legitimate business objectives.

Personal Information does not include any publicly available information from government records and de-identified or aggregated consumer information.

How does FinOctopus collect Users’ Personal Information?

FinOctopus collects Users’ Personal Information by way of direct interactions, automated technologies and/or interactions, and third-party requests.

Direct interactions. A User may provide data by filling in forms on the Website and/or Application(s) and/or Services (or otherwise) or by communicating with FinOctopus by email, built-in chat module, phone or otherwise, including when the User:

Applies to, refers to and in any other manner interacts with the Website, Application and/or the Services;
Clicks on “agree” or “activate” or “sign up” or similar button and installs or uses the Website and/or the Application(s);
Clicks on the “agree” or “activate” or “sign up” or similar button being a link with the data sharing form leading to the Website and/or the Application(s) on the website and/or mobile application of Affiliated Parties, including, but not limited to Super Dispatch, Inc.;
Clicks on the CTA button in the e-mail containing marketing materials from Affiliated Parties, including, but not limited to Super Dispatch, Inc.;
Creates an account on the Website and/or the Application(s);
Subscribes to FinOctopus’ publications;
Requests resources or marketing information be sent to User; and
Gives FinOctopus feedback.

Automated technologies or interactions. As the User uses FinOctopus' Website, Application and/or the Services, FinOctopus may automatically collect technical data about Users’ equipment, browsing actions and usage patterns. FinOctopus collects this data by using cookies, server logs and Google Analytics.

Third-party requests. As the User uses FinOctopus' Website, Application and/or the Services, FinOctopus may, at User’s specific consent, request the User’s Personal Information from third parties, such as Department of Transportation, etc.

Correcting personal information. Users are required to review and update their personal information indicated in the Application(s) to ensure that it is correct. If any of the User's information is incorrect, please either correct it or contact FinOctopus with the correction at factoring@finoctopus.com.

How and why does FinOctopus use Users’ Personal Information?

Set out below is the description of the ways FinOctopus intends to use its Users’ Personal Information and the legal grounds on which FinOctopus will process such data. Where relevant, we also explain what our legitimate interests are.

The most common legal/lawful grounds for FinOctopus processing of Users’ Personal Information are:

Where FinOctopus needs to evaluate the User’s insurance application for the provision of the insurance quote;
Where FinOctopus needs to enter into and/or perform a contract with User;
Where it is necessary for our legitimate interests (or those of a third party), and the User's interests, provided, however, that these legitimate interests do not infringe on User’s fundamental rights;
Where FinOctopus needs to comply with a legal or regulatory obligation.

FinOctopus may process Users’ Personal Information on more than one lawful ground, depending on the specific purpose for which FinOctopus is using Users’ data. Please email FinOctopus at factoring@FinOctopus.com for details about the specific legal grounds FinOctopus is relying on to process Users’ Personal Information if more than one ground has been set out in the table below:

Purpose/Activity

Type of data

Lawful Basis for Processing

To register as a new User on the Website and/or Application(s)

Identification Data
Contact Data
Services Data
Verification Data

Evaluation of the User’s insurance application for the provision of the insurance quote
Performance of a contract with the User

To process the User’s activities on the Website, Application and/or the Services

Identification Data
Contact Data
Financial Data
Transaction Data
Verification Data

Evaluation of the User’s insurance application for the provision of the insurance quote
Performance of a contract with the User
Insurance application assessment and data verification

To manage our business relationship with the User, which will include:
- Notifying the User about changes to the FinOctopus' Terms or Policy or any other legal documents;
- Asking the User to leave a review or take a survey
- Provision of Services and FinOctopus updates to the User

Identification Data
Contact Data
Profile Data
Marketing and communications Data

Performance of a contract with the User
Necessary to comply with a legal obligation, i.e. due to product liability, data protection legislation, or accounting legislation
Necessary for our legitimate interests to keep our records updated and/or to study how Users use FinOctopus' products/services

To administer and protect FinOctopus business, Website, Services, intellectual property and any kind of licensed assets (including troubleshooting, testing, system maintenance, support, reporting and hosting of data)

Identification Data
Contact Data
Technical Data

Performance of a contract with the User

To use data analytics to improve or develop FinOctopus' business, Website, Services, intellectual property and any kind of licensed assets, marketing, User relationships and experiences

Technical Data
Usage Data

Necessary for FinOctopus’ legitimate interests to identify the types of Users for the purposes of fine-tuning FinOctopus’ experience and Services, to keep its Website updated and relevant, to develop its business, and to inform its marketing strategy

To make suggestions and recommendations to the User about different FinOctopus' Services that may be of interest to the User

Identification Data
Contact Data
Technical Data
Usage Data
Profile Data
Marketing and communications Data

Necessary for FinOctopus’ legitimate interests to develop its services and expand its business

Account registration. When a User signs up and creates an account on the Website, or browses and starts using the Application, FinOctopus collects their email address and asks the User to create a password. Once these steps are completed, FinOctopus assigns an Individual Account Number (IAN) to the User. FinOctopus uses this to maintain the User's account. When signing in for the first time, the Userы will be prompted to provide their Identification Data, Contact Data, Services Data and Verification Data.

Account history. For security and operations purposes FinOctopus may maintain records of the User's account activity when the User is logged into their account. Account activity includes the FinOctopus' Website browsing history, records of the User’s transactions, and other information related to the User’s activity on the Website and/or the Application(s).

Marketing communications. The User will receive marketing communications from FinOctopus if the User has:

Requested information from FinOctopus or obtained access to the Website, Application and/or the Services; or
provided FinOctopus with their Personal Information and has not unchecked the box when entering their Personal Information for FinOctopus to send the User marketing communications, e.g. when the User obtained access to the Website, Application and/or the Services, or
when the User signed up for a subscription; or
In each case, the User has not opted out of receiving FinOctopus' marketing communications.

FinOctopus will obtain the User’s express opt-in consent before FinOctopus shares the User’s Personal Information with any third party for such third party's marketing purposes. Generally, FinOctopus does not rely on consent as a legal ground for processing the User’s Personal Information, other than in relation to sending marketing communications to the User via email.

The User has the right to withdraw consent to marketing communications at any time. The User can ask FinOctopus to stop sending them marketing emails by following the opt-out or "unsubscribe" links on any marketing message sent to the User or by emailing at factoring@finoctopus.com.

Where the User opts-out of receiving our marketing communications, this will not affect Personal Information provided to FinOctopus in the course of accessing or using the Website, Application and/or the Services or any other experience referring to and/or applying to the Website, Application and/or the Services.

Change of purpose. FinOctopus will only use the User’s Personal Information for the purposes for which FinOctopus collected it, unless FinOctopus reasonably believes that FinOctopus needs to use it for some other reason and that reason is consistent with the original purpose. If the User wishes to find out more about how the processing for the new purpose is consistent with the original purpose, please email at factoring@FinOctopus.com.

If FinOctopus needs to use the User’s Personal Information for a purpose unrelated to the purpose for which FinOctopus collected such data, FinOctopus will notify the User and explain the legal grounds for processing.

FinOctopus may process the User’s Personal Information without the User’s knowledge or consent where this is required or permitted by law.

Cookies and logs. A cookie is small stream of information a website places on a user’s computer hard drive so that the website is able to remember the user’s preferences and/or the pages the user visited on the website in order to make the user’s visit more efficient and enjoyable.

FinOctopus may use cookies to determine the number of unique visitors to the Website over a given period, or to remember user account details, etc. so that the need for repeated log-ins is eliminated. FinOctopus may combine the information collected through cookies with any Personal Information submitted online when using the Website to help personalize the User’s access to and the use of the Website, Application and/or the Services. Users may decline the use of cookies by checking the appropriate option in the preferences or options menus in their browser.

FinOctopus may collect data in the form of logs. Log data collected on web servers supplies FinOctopus with aggregate information about the number of visits to different pages on the Website and other navigational data. The variety of technical data FinOctopus may log includes:

IP address;
Device information, including device name and ID, hardware model, operating system and version, and mobile network information;
Browser information;
Cookie information;
Date/time of access;
Requested page(s); and
Referring page(s).

Pixel Data. Depending on the User’s interaction with the Website, Application and/or the Services, FinOctopus may use (or have others use on our behalf) pixels, SDKs and other storage technologies, which operate similar to cookies, to collect or receive information from FinOctopus, the Website, Application and/or the Services and apps to provide metrics services and target ads.

Information from other sources. FinOctopus may transmit and receive Personal Information to the Department of Transportation and other third parties for the purposes of assessing the User’s fitness to use the Website, Application and/or the Services.

Users’ rights on the collection, use and distribution of Personal Information.

Opt-In/Opt-Out. FinOctopus allows Users to monitor the way in which FinOctopus uses their Personal Information obtained by FinOctopus. All promotional and marketing materials FinOctopus sends to Users (e.g. "newsletters" or "information bulletins") contain internal mechanisms that allow Users to block future mailings (Opt-out, or "unsubscribe").

Right to access, rectify, modify, erase and object. Users have the right to request access, rectification, or erasure of their data that FinOctopus has collected. Personal Information that was used or is being used for evaluation of the User’s application for the Services, for performance of a contract with the User, for application assessment and data verification purposes cannot be erased upon User’s demand, and it will be handled in accordance with the governing law.

The User also has the right to object or restrict, for legitimate purposes, the processing of the User’s Personal Information, as well as the right to data portability. If the User chooses to restrict FinOctopus' access to Personal Information, FinOctopus may be unable to provide certain Services to the User.

The User may also withdraw their consent to receive marketing communications and/or share their Personal Information with FinOctopus.

Users who wish to deactivate their account may do so in accordance with the Terms. Removed information may survive in backup copies for a reasonable period of time but will not be generally available to FinOctopus and/or other third parties via the Website, Application and/or the Services. The account deactivation and/or removal of the information and/or Personal Information that was used or is being used for evaluation of the User’s application for the Services, for performance of a contract with the User, for application assessment and data verification purposes cannot be accomplished upon the User’s demand, and such Personal Information will be handled in accordance with the governing law.

Removed information is retained for FinOctopus’ internal accounting purposes along with the User's history of actions and requests relating to the Website, Application and/or the Services.

The User will not have to pay a fee to access their Personal Information (or to exercise any of the other rights relating to their Personal Information on the Website, Application and/or the Services). However, FinOctopus may charge a reasonable fee if the User’s request is clearly unfounded, repetitive, or excessive. Alternatively, FinOctopus may refuse to comply with the User’s request in such circumstances.

FinOctopus may need to request specific information from the User to help FinOctopus confirm the User’s identity and ensure their right to access their Personal Information (or to exercise any of the User’s other rights). This is a security measure to ensure that Personal Information is not disclosed to any unauthorized person who is not the rightful account owner. FinOctopus may also contact the User to ask the User for further information in relation to the User’s request to speed up the response.

FinOctopus will try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if the User’s request is particularly complex or the User has made a number of requests. In this case, FinOctopus will notify the User and keep the User updated.

If the User wishes to exercise any of the rights set out above, please email at factoring@finoctopus.com

Data retention. FinOctopus will only retain the User’s Personal Information for as long as necessary to fulfil the purposes FinOctopus collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate Personal Information retention period, FinOctopus considers the volume, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the User’s Personal Information, the purposes for which FinOctopus processes the User’s Personal Information, whether these purposes could be achieved through any other means, and the applicable legal requirements.

By law, for accounting and tax purposes FinOctopus has to keep basic information about our Users (including Contact, Identity, Services, Financial and Transaction Data) for seven (7) years after they cease being Users.

In some circumstances FinOctopus may anonymize the User’s Personal Information (so that it can no longer be associated with the User) for research or statistical purposes, in which case FinOctopus may use this information indefinitely without further notice to User.

Sharing and disclosure of Personal Information. FinOctopus does not sell its Users’ data to any third party for marketing purposes. Generally, FinOctopus will not share Users’ Personal Information with third parties without its Users’ permission. However, since in provision of its Services FinOctopus collaborates with various partners, affiliated companies, and third parties, FinOctopus may have to share Users’ Personal Information with them.

FinOctopus may also disclose or share Users’ data with:

Service providers who provide IT and system administration services, data sourcing or verification services;
Subsidiaries or other group companies;
Affiliated parties;
Professional advisers, including lawyers, bankers, auditors, and insurers who provide consulting, banking, legal, insurance, and accounting services; and
State authorities.

FinOctopus only allows such third parties to process its Users’ Personal Information for specified purposes and in accordance with its instructions and applicable data protection laws.

FinOctopus works with trusted partners who perform certain key operational functions for it. The partners FinOctopus works with include website hosting, marketing and transactional communications, customer service, product analysis, business intelligence, and electronic payment and signature providers. FinOctopus may work with other service providers or third parties to undertake other functions such as account servicing. User information may be shared with these partners in order to maintain and develop the Website and/or provide Services. When FinOctopus shares its Users' personal information with vendors and service providers who perform functions on FinOctopus’ behalf, FinOctopus mandates such parties to maintain the security and confidentiality of its Users' information, as well as limit the use of the information to what's reasonable and necessary to carry out their collaboration with FinOctopus, and in doing so, to comply with all applicable laws and regulations.

Advertisers. FinOctopus may share its Users' personal information with third-party marketers who provide advertising services on our behalf. In order to deliver offers and advertisements that may be of interest to the User, FinOctopus displays targeted advertisements and FinOctopus' content on the Services and on other digital properties or applications, and such targeted advertisements and content are based on the information provided to FinOctopus by its Users and the information sourced by FinOctopus from third parties who have independently collected such information. These advertisers collect and use the information gathered through cookies and other technology, including personal information about User and their devices, in order to provide advertisements about goods and/or services (including our own) that may be of interest to the User. These companies typically use tracking technologies to collect this information, and their use of such technologies is subject to their own terms and privacy practices.

Legally mandated disclosures. FinOctopus may disclose its Users’ Personal Information if required to do so by law or if FinOctopus believes that such actions are necessary to:

Conform to the law, comply with a judicial or court order, or comply with the legal process served on FinOctopus or its affiliated parties;
Protect and defend FinOctopus’ rights and property, the services, the users of the services, and/or our affiliated parties;
Act under the circumstances to protect the safety and security of the Users of FinOctopus’ Website, Application and/or the Services.

When legally required by a law enforcement or government agency to do so, FinOctopus will share its Users’ information. FinOctopus may also share Personal Information when it believes that the disclosure is necessary to comply with a court order or judicial proceeding. Additionally, FinOctopus reserves the right to disclose any of the User's Personal Information that it believes is necessary to mitigate liability, comply with audit, regulatory or compliance requirements, defend against claims of third parties, assist government law enforcement agencies, protect the security of Website, Application and/or the Services, or protect the rights of FinOctopus' Users, FinOctopus and affiliated parties or other parties. Finally, Personal Information may be disclosed or transferred as part of, or during negotiations on, a merger, consolidation, sale of FinOctopus' assets, as well as equity financing, acquisition, strategic alliance, or in any other situation where Personal Information may be transferred as one of the business assets of FinOctopus.

International data transfers. FinOctopus is based in Missouri, USA, and its Users’ Personal Information is collected and processed in accordance with the US privacy laws and the EU General Data Protection Regulation.

FinOctopus may share, store, process or attempt to process all Users’ data worldwide. When Personal Information is shared or transferred, FinOctopus will ensure that the transfer will be subject to appropriate safeguards in accordance with applicable data protection legislation and that the level of protection is equivalent to that applicable in the USA and EU.

If the User is located outside the US, and the laws governing data collection and use in their jurisdiction are different from the US law, please note that the User is then transferring their personal information to the US, and in such context, they are consenting to such transfer by providing their personal information.

Security. FinOctopus has taken steps to ensure that the Personal Information collected by FinOctopus is secure. FinOctopus has also taken a range of technical and organizational measures to protect the confidentiality, security, and integrity of the Personal Information collected from Users, including protecting Users’ data from unauthorized access, loss, change, or deletion. Personal Information is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees, consultants and/or service providers.

FinOctopus also has security measures in place to protect the loss, misuse, and alteration of the information under our control. Such actions include but are not limited to, physical controls, encryption, eligibility restrictions, policies, etc.

FinOctopus has put in place procedures to deal with any suspected Personal Information breach and will notify Users and any applicable regulator of a breach where FinOctopus is legally required to do so.

Governing law. Any dispute, controversy, or claim arising out of or in connection with this Policy, or the breach, termination or invalidity thereof, shall be governed by the laws and venue as stated in the Terms.

California Notice.

The provisions in this section (the "California Notice") are intended to fulfill the requirements of the California Consumer Privacy Act ("CCPA") and shall apply to the Users of the Website and/or Application and/or Services who are residents of the State of California.

Personal information. The terms used in this Privacy Policy and the California Notice which are defined in the CCPA will have the definitions as provided in the CCPA. The term “Personal Information” or other similar uses implying private information belonging to the Users as used in this Privacy Policy and this California Notice include “Personal Information” as defined in the CCPA. All other capitalized terms have the meaning provided in the Privacy Policy.

Transparency and Opt-out. California Civil Code Section 1798.83 permits California residents to request certain information regarding and/or opt-out of our disclosure of their Personal Information to third parties for their direct marketing purposes. To make such a request, please e-mail at factoring@finoctopus.com.

Categories of Personal Information. The categories of Personal Information that FinOctopus may have collected in the last 12 months are described in “What Personal Information does FinOctopus collect?” of the Privacy Policy and, for the purposes of the CCPA, correspond to the following categories of Personal Information listed in the CCPA:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Processing Personal Information. FinOctopus will not process the Users’ personal information for purposes which are materially different, unrelated, or incompatible with the purposes set out in the Privacy Policy without providing the User a notice.

Disclosure of Personal Information to third parties. In the last 12 months, to the extent that FinOctopus has the Users’ personal information, FinOctopus has only disclosed this Personal Information to third parties for business purposes or with the User’s consent.

Sale and Disclosure of Personal Information to third parties. FinOctopus may share the User’s Personal Information by disclosing it to a third party for a business purpose. FinOctopus only makes these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, FinOctopus has not disclosed Personal Information for a business purpose, however, FinOctopus intends to disclose the following categories of Personal Information to the categories of third parties indicated in the chart below.

FinOctopus may also share Personal Information by selling it to third parties, subject to the User’s right to opt-out of those sales. FinOctopus Personal Information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, FinOctopus has not sold Personal Information, however, FinOctopus may sell the following categories of Personal Information to the categories of third parties indicated in the chart below.

Category	Category of Third-Party Recipients
Category	Business Purpose Disclosures	Sales
A. Identifiers.	Service providers; advertisers; affiliates, partners, parent or subsidiary companies; and internet cookie data recipients, like Google Analytics	Service providers, like insurance underwriters
B. Personal information categories listed in the California Customer Records statute	Service providers; advertisers; affiliates, partners, and parent or subsidiary organizations	Service providers, like insurance underwriters
C. Protected classification characteristics under California or federal law.	Service providers; advertisers; affiliates, partners, and parent or subsidiary companies	Service providers, like insurance underwriters
D. Commercial information.	Service providers; advertisers; affiliates, partners, and parent or subsidiary organizations	Service providers, like insurance underwriters
E. Biometric information.	None	None
F. Internet or other similar network activity.	Service providers; advertisers; affiliates, partners, parent or subsidiary organizations; and internet cookie data recipients, like Google Analytics	Service providers, like insurance underwriters
G. Geolocation data.	Service providers; advertisers; affiliates, partners, parent or subsidiary organizations; and internet cookie data recipients, like Google Analytics	Service providers, like insurance underwriters
H. Sensory data.	None	None
I. Professional or employment-related information.	None	None
J. Non-public education information	None	None
K. Inferences drawn from other Personal Information.	Service providers; advertisers; affiliates, partners, parent or subsidiary organizations; and internet cookie data recipients, like Google Analytics	Service providers, like insurance underwriters

Reselling Personal Information. The CCPA prohibits a third party from reselling Personal Information unless the User has received explicit notice and an opportunity to opt-out of further sales. FinOctopus has not sold any Personal Information to date. However, FinOctopus will update this section with the businesses that purchase Personal Information from FinOctopus and may resell that information in the future. To opt-out of those sales, the user will be able to visit that business's opt-out notice at the link to be provided.

Additional rights under the CCPA. California residents may have the following rights under the CCPA in addition to the rights set out in the Privacy Policy.

1. Access: Once FinOctopus receives and confirms the User’s verifiable consumer request, FinOctopus will disclose the following to the User:

the categories of the User’s Personal Information and the specific Personal Information that FinOctopus has collected;
the categories of sources from which the User’s Personal Information was collected;
FinOctopus business or commercial purpose for collecting the User’s Personal Information; and
the categories of third parties with whom we shares the User’s Personal Information, and where such third parties received the User’s Personal Information from FinOctopus for a business purpose, the categories of the User’s Personal Information that FinOctopus disclosed to such third parties.

Under the CCPA, the User is only entitled to exercise the Personal Information access right set out in the foregoing paragraph twice a year.

1. Deletion: Once FinOctopus receives and confirms the User’s verifiable consumer request, FinOctopus will (and will direct FinOctopus service providers to whom FinOctopus has disclosed the User’s Personal Information to) delete the User’s Personal Information unless an exception under the CCPA applies.

The rights set out in the foregoing paragraphs do not apply to Personal Information collected from FinOctopus employees as part of their employment with FinOctopus or Personal Information collected as part of a business-to-business transaction.

If the User would like to exercise any of the rights in this section, he shall contact FinOctopus in writing. The User must include the full name, mailing address, and policy number (if applicable), in addition to the rights the User is exercising and which information the User is exercising his rights on. The User shall also state that he is requesting access pursuant to the California Consumer Privacy Act. FinOctopus will respond promptly to any request.

Only the user, or someone legally authorized to act on behalf of the User, may make a verifiable consumer request related to the user’s Personal Information. FinOctopus may need to request specific information from the User to help FinOctopus confirm that the request is a verifiable consumer request.

Non-Discrimination. FinOctopus will not discriminate against the User for exercising any of the User’s rights under the CCPA. Specifically, unless permitted by the CCPA, FinOctopus will not:

deny the User’s access to Services provided by FinOctopus;
charge the User different prices or rates for the goods and/or Services provided by FinOctopus or impose penalties on the User;
provide the User with a different level or quality of goods and/or services than otherwise generally provided by FinOctopus; or
suggest that the User will receive a different price or rate for, or a different level or quality of, the goods and/or services generally provided by FinOctopus.

Changes to this section of Privacy Policy. FinOctopus is required by law to update this section of Policy at least once each year (last updated on January 04, 2023).

Changes of Privacy Policy. This Policy, may be subject to change from time to time. If substantial changes are made to the Policy, FinOctopus will notify the User of these material changes by posting them on the Website. Users are encouraged to check back and review this Policy from time to time so that they will always are informed of what information is being collected, how it is used, and to whom it is being disclosed. The User’s continued use of the Website, Application and/or the Services, the User content and/or intellectual property subject to this Policy will signify the User’s acceptance of the Policy changes.

Contact. Please contact FinOctopus at factoring@finoctopus.com for any questions related to this Privacy Policy.