FinOpti Treasury, LLC
Privacy Policy

This Privacy Policy describes how FinOpti Treasury, LLC (“FinOpti,” “we,” “our,” or “us”) collects, uses, and shares information when you visit our website at finopti.co and when Program Partners and their authorized users access our technology platform, developer tools, APIs, and related services (collectively, the “Services”). This Privacy Policy is intended primarily for businesses evaluating or using the Services (“Program Partners”) and their representatives.

FinOpti is a financial technology company and is not a bank. Banking products and services are provided by one or more regulated financial institutions (each, a “Bank Partner”) and/or other licensed providers, as applicable, and may be subject to separate privacy notices and disclosures from those providers.

To the extent Program Partner has end customers (“End Users”), the End Users should refer to the privacy notice provided by the Program Partner and/or Bank Partner.

1. Information We Collect

We may collect the following categories of information, depending on how you interact with the Services:

Use of Services

• Identification information (e.g., name, title, company name, work email, phone number, mailing address).
• Know-your-customer data (e.g., your company legal name, title, employer identification number (“EIN”) or other information relating to your business or beneficial owners)
• Financial Account and platform information (e.g., login credentials, user roles, settings, support communications, audit logs).

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Browsing, Visiting, or interacting with our Website or Services

• Technical and usage information (e.g., IP address, device identifiers, browser type, operating system, pages viewed, API calls, timestamps, and performance data).
• Communications (e.g., emails, form submissions, meeting requests, and customer support interactions).

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FinOpti does not intentionally request or require consumer personal information through the public Website. If Program Partners integrate or offer FinOpti Services into an end-user experience, consumer personal information may be provided to or processed by FinOpti in accordance with the applicable Program Partner and/or Bank Partner program terms and disclosures.

2. How We Collect Information

We collect information in the following ways:

• Directly from you, such as when you request a demo, create an account, complete onboarding steps, or contact support.
• Automatically, such as through cookies and similar technologies when you visit the Website or use the Services.
• From third parties, such as Bank Partners, service providers, referral partners, or publicly available sources, to support onboarding, security, and compliance.

3. How We Use Information

We use information for the following business purposes:

• Provide and operate the Services, including authentication, account administration, and support.
• Evaluate, onboard, and manage Program Partners, including due diligence and risk management.
• Secure the Services, detect and prevent fraud, abuse, and security incidents.
• Improve and develop the Services, including debugging, analytics, and feature testing.
• Communicate with you about the Services, including service updates, security notices, and administrative messages.
• Market and advertise our Services to Program Partners and business prospects (see “Your Choices” below).
• Comply with legal and regulatory requirements and enforce our agreements.

4. How We Share Information

We may share information as follows:

• With Bank Partners and other regulated providers, as needed to support the delivery of regulated financial products and program operations.
• With service providers and contractors that perform services on our behalf (e.g., hosting, analytics, customer support, security monitoring, compliance tooling).
• With professional advisors (e.g., auditors, counsel) as needed for business operations.
• For legal, compliance, and safety purposes (e.g., to respond to lawful requests, protect rights, investigate fraud or misuse, and comply with applicable law).
• In connection with a business transaction (e.g., merger, acquisition, financing, or sale of assets).
• With your direction or consent.

We do not sell personal information in exchange for money. We also do not knowingly share personal information for cross-context behavioral advertising in a way that would require a “Do Not Sell/Share” link for typical B2B use cases; however, if we use third-party analytics or advertising tools, those providers may set cookies as described below.

5. Cookies and Similar Technologies

We use cookies and similar technologies (such as pixels and web beacons) to operate the Website and Services, understand usage, and improve performance. These technologies may include essential cookies (for functionality and security) and analytics cookies (to measure and improve user experience).

You can control cookies through your browser settings. If you disable cookies, some features may not function properly. We do not currently respond to “Do Not Track” signals because there is no uniform industry standard for them.

6. Your Choices

You may have the following choices:

• Marketing communications: You may opt out of marketing emails by using the unsubscribe link in those emails. Even if you opt out, we may still send non-marketing, service-related communications.
• Cookies: You can manage cookies through your browser settings and, where available, consent tools on our Website.
• Account information: Program Partner administrators may update certain account/profile information through the Platform.

7. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If you believe there has been a security incident involving the Services, please contact us at support@finopti.co.

8. Data Retention

We retain information for as long as reasonably necessary to provide the Services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and for legitimate business purposes. Retention periods may vary based on the type of information and the applicable program requirements.

9. International Use

The Services are intended for use in the United States. Information may be processed and stored in the United States and other jurisdictions where FinOpti or its service providers operate.

10. Children

The Services are not directed to children, and we do not knowingly collect personal information from children under 13.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on our Website and update the Effective Date. Your continued use of the Services after the update becomes effective indicates acceptance of the updated Privacy Policy.

12. Contact Us

FinOpti Treasury, LLC
Email: support@finopti.co
Address: 1515 Mockingbird Ln, Charlotte, NC 28209

13. California Privacy Notice (Business Contacts)

If you are a California resident acting in a business capacity (for example, as a representative of a Program Partner), you may have rights under the California Consumer Privacy Act (as amended). Where applicable and subject to legal exceptions (including information governed by the Gramm-Leach-Bliley Act), you may request access to or deletion of certain personal information, or request correction of inaccurate information. To submit a request, contact us at support@finopti.co. We may need to verify your identity and authority.

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