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Privacy Policy

1. User Consent

Frank Finly LLC ("Frank Finly," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes our practices regarding the personal data (as defined below) we collect from users of our website at frankfinly.com (the "Site") and related services (collectively, the "Services"). By submitting personal data through our Site and Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your personal data in accordance with this Privacy Policy.

2. A Note About Children

We do not intentionally gather personal data about visitors who are under the age of 13. Our Services are not intended for individuals under 18. If you are under 18, please do not use our Site or submit any personal data to us.

3. Cross-Border Data Transfer — Note to Users Outside the United States

Important: Frank Finly LLC is registered in Georgia. Your personal data may be processed in the country in which it was collected and in other countries, including the United States, where our servers and service providers are located. Laws regarding processing of personal data may differ from the laws in your country. BY USING OUR SITE OR SUBMITTING PERSONAL DATA THROUGH OUR SITE OR SERVICES, YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA ACCORDING TO THIS PRIVACY POLICY.

We take steps to protect your data when it is transferred, including contractual safeguards with service providers, technical measures (encryption, access controls), and compliance with applicable data protection requirements.

4. Types of Data We Collect

Personal Data You Provide to Us

We collect personal data from you when you provide it voluntarily on the Site. You may provide your name, phone number, email address, zip code, marital status, financial goals, household income, home ownership status, details about your family, and other details you may submit to us. You may also provide information in response to our surveys and questionnaires. We use this information to provide the Services, including matching you with financial advisors who participate in our platform.

Personal Data Collected via Technology

To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect personal data from you, including your IP address or HTTP referrer. We also use cookies and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Like most Internet services, we automatically gather this personal data and store it in log files each time you visit our website.

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. Persistent cookies can be removed by following your Internet browser help file directions. If you choose to disable cookies, some areas of our website may not work properly. We have also enabled Google Analytics and similar services to gather information about site usage. See our Cookie Policy for details.

We work with advertisers, ad networks, and analytics companies that collect information about your use of our services. You can opt out of interest-based advertising by visiting the Digital Advertising Alliance consumer choice page.

5. Use of Your Data

General Use

In general, personal data you submit to us is used either to respond to requests that you make or to aid us in serving you better. We use your personal data in the following ways:

  • Provide you with the Services and customer support
  • Match you with financial advisors who participate in our platform
  • Communicate with you about the Site and the Services
  • Improve the quality of the Site and the Services
  • Market our Services (and those of third parties) to you that we believe may be of interest to you — if you prefer that we do not send you these messages, please see the section below on Your Choices Regarding Your Personal Data
  • Verify your compliance with your obligations in our Terms of Use or other policies
  • Respond to your requests, resolve disputes, and/or troubleshoot problems

Compliance and Protection

We may use your personal information to:

  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft
  • Enforce the terms and conditions that govern the Site and the Services
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies
  • Protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims)
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities

Creation of Anonymous Data

We may create anonymous data records from personal data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve site navigation. We reserve the right to use and disclose anonymous data to third parties in our discretion.

Feedback

If you provide feedback on the Site or Services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your personal data. We will collect any information contained in such communication and will treat the personal data in such communication in accordance with this Privacy Policy.

6. Disclosure of Your Personal Data

Affiliates and Business Transfers

Although we currently do not have a parent company, subsidiaries, joint ventures, or other companies under a common control (collectively, "Affiliates"), we may in the future. We may share some or all of your personal data with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires us or our assets, that company will possess the personal data collected by it and us and will assume the rights and obligations regarding your personal data as described in this Privacy Policy.

Disclosure to Third-Party Service Providers

We may share your personal data with third-party service providers to facilitate creation of accounts or to provide services to us that enable us to make the Site or the Services available to you. These providers are contractually obligated to protect your data and use it only for the purposes we specify.

Disclosure to Financial Advisors

We may share your advisor matching form intake data with relevant financial advisor matches that meet participation criteria and actively participate in our matching platform. The terms and conditions permit those advisors to contact you with the information you have provided. By submitting your information, you consent to being contacted by matched advisors. See our Consent to Contact for more details.

Other Disclosures

Regardless of any choices you make regarding your personal data (as described below), we may disclose personal data if it believes in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) protect or defend the rights or property of Frank Finly or users of the Site or related services.

7. Third Parties

We may receive personal and/or anonymous data about you from other sources, such as from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website ("Third Party Companies"). We may add this information to the information we have already collected from you via our website in order to improve the Services we provide.

Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect personal data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

8. Notice to California Residents — Shine the Light

A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a "California Customer") may request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by emailing us at [email protected]. Please note that we are required to respond to one request per California Customer each year. For comprehensive California privacy rights, see our CCPA Notice.

9. Your Choices Regarding Your Personal Data

Choices

We offer you choices regarding the collection, use, and sharing of your personal data. We may periodically send you newsletters and emails that directly promote the use of our site or the purchase of our Services and may contain advertisements for third parties. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you notices of any updates to our Terms of Use or Privacy Policy.

Changes to Personal Data and Deletion

You may request access to, correction of, or deletion of your personal data by contacting us at [email protected]. Please note that we may be required (by law or otherwise) to keep this information and not delete it, or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from the active database, but may remain in our archives for a limited period as required for legal, compliance, or operational purposes.

10. Security of Your Personal Data

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. Despite these measures, you should know that we cannot fully eliminate security risks associated with personal data and mistakes may happen. No method of transmission over the Internet is 100% secure.

11. Data Retention

We retain your personal data for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need your personal data, we will securely delete or anonymize it. Data shared with financial advisors may be retained by those advisors in accordance with their own policies.

12. California Residents — CCPA

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA). Please see our CCPA Notice for details, including your right to know, delete, and opt out of the sale of personal information. We do not sell personal information.

13. Dispute Resolution

If you believe that we have not adhered to this Privacy Policy, please contact us by email at [email protected]. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

14. Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision. If we make any substantial changes in the way we use your personal data, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our website. Any material changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of notice of the changes on our site. These changes will be effective immediately for new users of our website or Services. Please note that at all times you are responsible for updating your personal data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your personal data, you must notify us prior to the effective date of the changes. Continued use of our website or Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

15. Contact Information

We welcome your comments or questions regarding this Privacy Policy. Please email us at [email protected] or contact us at the following address:

Frank Finly LLC
Attn: Privacy
Georgia, Kobuleti Municipality, Tsikhisdziri Village, 10th Street, No. 2
Email: [email protected]