Privacy and cookies policy

Hello, good morning!

If you are here, it is a reliable sign that you value your privacy. We understand this very well, which is why we are giving you a document in which you will find the rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the operation of the FINpl website and mobile application.

To begin with, the administrator of the service and the application is FIN-HUB Sp. Z o.o., Tysiaclecia Panstwa Polskiego Avenue 13, 24-110 Pulawy, NIP: 5252796739, REGON: 38396986200000, KRS: 0000796588, registration court: District Court for the Capital City of Warsaw in Warsaw, XII Economic Division of the National Court Register, share capital: PLN 6,000.00.

This privacy policy has been structured in the form of questions and answers. The choice of this form was dictated by the concern for clarity and legibility of the information presented to you. Below, you will find a table of contents of this policy corresponding to the questions we answer in turn.

  1. Who is the admin of personal data?
  2. Who can you contact about your personal data?
  3. What information do we have about you?
  4. Where do we have your personal data from?
  5. Is your data safe?
  6. What purposes do we process your personal data for?
  7. How long will we keep your personal data?
  8. Who are the recipients of your personal data?
  9. Do we transfer your data to third countries?
  10. Do we use profiling?
  11. What rights do you have in relation to data processing?
  12. Do we use cookies and what are they actually?
  13. On what basis do we use cookies?
  14. Can you deactivate cookies?
  15. What purposes do we use own cookies for?
  16. What third-party cookies are used?
  17. Do we track your behaviour undertaken within our website?
  18. Are we targeting you with targeted advertising?
  19. How can you manage your privacy?
  20. What are server logs?
  21. Is there anything else you should know?
  22. Can this privacy policy be subject to change?

If you have any concerns about the privacy policy, you can contact us at any time by sending an email to portal@finpl.co.uk.

# 1: Who is the administrator of your personal data?

The administrator of your personal data is FIN-HUB Sp. z o.o., Tysiaclecia Panstwa Polskiego Avenue 13, 24-110 Pulawy, NIP: 5252796739, REGON: 38396986200000, KRS: 0000796588, registration court: District Court for the Capital City of Warsaw in Warsaw, XII Economic Division of the National Court Register, share capital: PLN 6,000.00.

# 2: Who can you contact regarding the processing of your personal data?

As part of the implementation of data protection in our organisation, a decision has been made not to appoint a Data Protection Officer due to the fact that it is not mandatory in our situation. You can contact us on matters relating to data protection and privacy more broadly at the email address: portal@finpl.co.uk.

# 3: What information do we have about you?

Depending on the purpose, we may process the following information about you:

  • name and surname,
  • postal address,
  • e-mail address,
  • telephone number,
  • IP address,
  • financial data related to earnings, household, commitments,
  • data related to interests in credit opportunities,
  • data included in correspondence,
  • data included in the opinion about expert,
  • data included in the complaint,
  • statistics related to e-mails sent.

We have described the scope of the processing precisely for each processing purpose. Information in this regard can be found later in this policy.

Furthermore, we use tools that collect a range of information about you related to your use of our website or mobile application. This includes, in particular, the following information:

  • information about the operating system and web browser,
  • subpages viewed,
  • time spent on the site,
  • transitions between individual sub-pages,
  • clicks on individual links,
  • the source from which you go to the page,
  • the age range you are in,
  • Your gender,
  • Your approximate location limited to the Town or City,
  • our interests as determined by your online activity.

This information is referred in this privacy policy as "Anonymous Information".

Anonymous Information does not, in itself, in our view, have the character of personal data, as it does not allow us to identify you and we do not compare it with the typical personal data we collect about you. Nevertheless, given the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is attributed with the character of personal data, detailed explanations are also included in this privacy policy regarding the processing of this information.

As Anonymous Information is collected by the third party tools we use (the tools are detailed later in this privacy policy), Anonymous Information is also processed by the tool providers under the terms of their regulations of use and privacy policies.

Anonymous information is also used by the providers of individual tools to provide and improve services, manage services, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalise the content and advertising displayed on individual services, websites and applications.

# 4: Where do we get your personal data from?

In most cases, you are passing them on yourself. This happens when:

  • you register a user account,
  • you complete the credit comparison order form,
  • you fill in the expert search form,
  • you fill in the order form to contact an expert,
  • you submit a complaint,
  • you add an expert opinion,
  • correspond with us or an expert.

Some information about you is collected automatically by our ICT system:

  • IP address
  • approximate location,
  • statistics related to e-mails sent.

In certain situation, we come into possession of your personal data (e-mail address) even before you give it to us. This is the case when an expert, who has your data in his or her own database, invites you to use a service or application and you do not have a user account yet. In this case, we process your email address provided by the expert in order to send you an invitation to use the service or application. Acceptance of the invitation requires the registration of a user account, which already involves the self-submission of your data to us under the terms described in this privacy policy.

In addition, third-party tools that use cookies or other tracking technologies (the tools are described in detail later in this privacy policy) collect Anonymous Information related to your activities on the website or application.

# 5: Is your data safe?

We care about the security of your personal data. We analyse the risks involved in the various processes of processing your data and then implement appropriate security and personal data protection measures. We monitor the state of the technical infrastructure on an ongoing basis, train our staff, look at the procedures in place and make the necessary improvements. If you have any questions about your personal data, we are at your disposal at portal@finpl.co.uk.

# 6: What purposes do we process your personal data for?

There are more than one of these objectives. They are listed below, followed by a more detailed discussion. The respective legal bases for processing have also been assigned to the various purposes:

  • Supply of electronic services - Article 6(1)(b) RODO,
  • Handling of complaints - Article 6(1)(f) RODO,
  • Handling of processes related to the sending of emails - Article 6(1)(f) RODO,
  • the creation of an archive for the possible need to defend, establish or assert claims and to ensure that the proper fulfilment of data protection obligations can be demonstrated - Article 6(1)(f) RODO,
  • Creation of Facebook audience groups - Article 6(1)(f) RODO,
  • Analysis and statistics using Anonymous Information - Article 6(1)(f) RODO,
  • Marketing using Anonymous Information - Article 6(1)(f) RODO

Supply of services by electronic means - details

User account. When registering a user account, you have to provide the data necessary to set up the account specified in the registration form. The provision of data is voluntary, but necessary for the creation of the account.

The data provided by you in connection with the creation of your account is processed in order to provide you with an electronic service consisting of providing you with the possibility to use your user account. This service is provided on the basis of a contract concluded in accordance with the terms and conditions described in the Terms and Conditions, which means that, in this respect, the legal basis for the processing of your personal data is Article 6(1)(b) RODO.

Comparison of credit offers. If you fill in the order form for a comparison of credit offers, you must provide the data necessary for the expert to prepare such a comparison, which includes financial data related to your earnings, household, commitments and data related to your interest in credit opportunities. In addition, you have to provide in the form the data necessary for the expert to contact you. The provision of data is voluntary, but necessary in order to receive a credit comparison.

Enabling you to place an order to compare credit offers constitutes a service provided electronically. This service is provided on the basis of an agreement concluded in accordance with the terms and conditions described in the Terms and Conditions, which means that, in this respect, the legal basis for the processing of your personal data is Article 6(1)(b) RODO.

The comparison of credit offers is prepared by an expert. For this purpose, your data is made available to the expert preparing the comparison. The provision of data takes place in the context of the performance of a service provided electronically. This service is provided on the basis of an agreement concluded under the terms and conditions described in the terms and conditions, which means that, in this respect, the legal basis for sharing your personal data is Article 6(1)(b) RODO.

Once data is shared with the expert, the expert becomes an independent controller of personal data, independent of us.

Expert search. If you are completing an expert search form, you will need to provide the data necessary for expert selection, which includes financial data related to earnings, household, commitments and data related to interests in credit opportunities. The data you provide is voluntary, but necessary to find an expert.

Allowing you to search the expert database constitutes a service provided electronically. This service is provided on the basis of a contract concluded under the terms and conditions described in the Terms and Conditions, which means that, in this respect, the legal basis for the processing of your personal data is Article 6(1)(b) RODO.

Ordering an expert contact. If you fill in the expert contact order form, you have to provide the data necessary for the selection of the right expert, which includes financial data related to your earnings, household, commitments and data related to your interests in credit opportunities. In addition, you have to provide in the form the data necessary for the expert to contact you. The provision of data is voluntary, but necessary for the selected expert to contact you.

Enabling you to place an order to contact an expert constitutes a service provided electronically. This service is provided on the basis of a contract concluded under the terms and conditions described in the Terms and Conditions, which means that, in this respect, the legal basis for the processing of your personal data is Article 6(1)(b) RODO.

Based on the form you fill in, our ICT system searches the expert database and selects the expert best suited to your needs. Then, your data is made available to the selected expert. The provision of data takes place within the framework of the performance of a service provided electronically. This service is provided on the basis of a contract concluded in accordance with the principles described in the terms and conditions, which means that, in this respect, the legal basis for sharing your personal data is Article 6(1)(b) RODO.

Once data is shared with the expert, the expert becomes an independent controller of personal data, independent of us.

Contact an expert. You can correspond with experts via the service or the app. You then decide yourself what data you provide as part of your correspondence.

Enabling you to correspond with experts constitutes a service provided electronically. This service is provided on the basis of a contract concluded under the terms and conditions described in the Terms and Conditions, which means that, in this respect, the legal basis for the processing of your personal data is Article 6(1)(b) RODO.

When corresponding with an expert, your data is shared with the expert. The provision of data takes place in the framework of the performance of a service provided electronically. This service is provided on the basis of a contract concluded in accordance with the terms and conditions described in the terms and conditions, which means that, in this respect, the legal basis for sharing your personal data is Article 6(1)(b) RODO.

Once data is shared with the expert, the expert becomes an independent controller of personal data, independent of us.

Invitation by an expert. An Expert who has your data in their own database may use the service or application to contact you. For this purpose, the Expert provides us with your data in order to generate an invitation for you to use the service or application. If you receive such an invitation and you do not already have a user account, acceptance of the invitation requires registration of a user account.

Location. In connection with the provision of electronic services to you, our ICT system automatically determines your approximate location. This is done in order to facilitate the selection of experts.

IP address. In connection with the provision of electronic services to you, our ICT system automatically records your IP address. This is done for security purposes.

Data retention period. Data related to the services provided electronically are stored for the duration of the provision of these services, i.e. as long as you have a user account. Once your user account has been deleted, the data is kept for archival purposes, as referred to later in this privacy policy.

Complaints - details

If you make a complaint, you provide the personal data included in the body of the complaint. The provision of data is voluntary, but necessary to make a complaint.

The data provided in connection with submitting of a complaint is used for the complaint procedure and subsequently for archiving purposes, which is a legitimate interest pursued by the controller (Article 6(1)(f) RODO).

If the complaint relates to services provided by an expert, the content of the complaint and related correspondence is also made available to the expert to whom the complaint relates. The expert is in this situation an independent data controller, independent of us.

Sending e-mails - details

Our messages. If you consent to receive e-mails from us related to the opportunities offered by the service and the application, your data is processed for the purpose of handling the processes related to the sending of such messages, including the analysis of statistics on the effectiveness of the messages sent, which is our legitimate interest referred to in Article 6(1)(f) of the DPA. You can withdraw your consent at any time, which will cause us to stop sending you the said messages, but we will continue to store your data for the archiving purposes mentioned later in this privacy policy.

Expert messages. If you agree to receive emails directly from experts about offers, promotions, services or financial products, any expert with an active expert account may send you such emails. This means that your data is shared with each expert with an active expert account for this purpose, which is our legitimate interest as referred to in Article 6(1)(f) of the DPA.

You will find the data of all experts on the experts' business cards on the website. Each expert is a data controller in his own right, independent of us, as far as emailing is concerned.

You can withdraw your consent to receive e-mails directly from the experts about offers, promotions, services or financial products at any time, with the result that the expert is obliged to stop sending you the mentioned e-mails. Despite the withdrawal of your consent, your data will continue to be stored by us for archiving purposes as mentioned later in this privacy policy.

Statistics. Our ICT system allows you to view and analyse statistics related to the e-mails sent to you, including information such as opening the information, clicking on the link included in the message, etc.

Mail handling - details

When you contact us via the contact form, email or chat, you naturally provide your personal data included in the body of the correspondence, in particular your email address and your name. The provision of data is voluntary, but necessary in order to make contact.

Your data is processed in this case for the purpose of contacting you and the basis for processing is Article 6(1)(f) RODO, i.e. a legitimate interest. The legal basis for post-contact processing is also the legitimate interest of archiving correspondence for the purpose of ensuring that we can prove certain facts in the future (Article 6(1)(f) RODO).

The content of your correspondence may be subject to archiving and we are not in a position to make it clear when it will be deleted. You have the right to request the history of any correspondence you have had with us (if it is subject to archiving), as well as to request its deletion, unless its archiving is justified by overriding interests, such as defence against potential claims on your part.

Archive - details

We keep your personal data for archival purposes for the investigation, establishment or defence of claims and to ensure that we can demonstrate due compliance with our data protection obligations, which is our legitimate interest as referred to in Article 6(1)(f) of the RODO.

Personal data shall be stored until the expiry of the limitation period for claims relating to the electronically provided services and, if storage is further justified by the need to be able to demonstrate the proper fulfilment of data protection obligations, personal data shall be stored to the extent necessary for this purpose for as long as we may be subject to an audit of the proper fulfilment of mentioned obligations.

You can always ask us about the extent to which your personal data is stored in the archive and, if you consider this to be unjustified, object to such processing of your personal data. Your objection will be dealt with the general principles of the applicable data protection legislation.

Audience groups - details

Your e-mail address may be sent to Facebook in order to create a group of advertising recipients using that e-mail address.

When using this function, the email address is hashed before being sent to Facebook to create an audience.

The e-mail address will be used in the matching process conducted by Facebook.

Facebook does not share the email address with third parties or other advertisers and deletes the email address immediately after the matching process is completed.

Facebook has processes and procedures in place to ensure the confidentiality and security of the submitted email address and the set of Facebook user IDs that make up the group of recipients created using the email address, including through the use of technical and physical safeguards.

The creation of a Facebook ad audience using your email address constitutes a legitimate interest as referred to in Article 6(1)(f) of the DPA. You can object to the use of your e-mail address for this purpose at any time, simply by writing to us at portal@finpl.co.uk.

Analysis and statistics - details

We carry out analytical and statistical activities using the tools described in detail later in this privacy policy. As part of the analytical tools, we have only access to Anonymous Information.

As mentioned earlier, Anonymous Information in itself does not, in our view, have the character of personal data, as it does not allow us to identify you and we do not compare it with the typical personal data we collect about you. Nevertheless, taking into account the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is attributed with the character of personal data, detailed explanations on the processing of this information are also included in this privacy policy.

We base the processing of Anonymous Information on the legitimate interest referred to in Article 6(1)(f) RODO. The legitimate interest consists of creating, reviewing and analysing statistics related to user activity in order to draw conclusions for the subsequent optimisation of our activities.

We are not able to provide you with access to Anonymous Information about you, as we are not able to attribute any of the Anonymous Information to any specific user. From external tools, we only have access to a set of statistics and information not attributed to specific individuals.

You can, however, object to the processing of Anonymous Information about you by blocking the cookies of the external tools we use.

Self-marketing - details

We carry out marketing activities using third party tools as described in detail later in this privacy policy. As part of the marketing tools we have only access to Anonymous Information.

As mentioned earlier, Anonymous Information in itself does not, in our view, have the character of personal data, as it does not allow us to identify you and we do not compare it with the typical personal data we collect about you. Nevertheless, taking into account the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is attributed with the character of personal data, detailed explanations on the processing of this information are also included in this privacy policy.

We base the processing of Anonymous Information on the legitimate interest referred to in Article 6(1)(f) RODO. The legitimate interest is the creation of Custom Audience Groups based on Anonymous Information and the targeting of advertisements based on Anonymous Information, both of which fall within the marketing of our own products and services.

We are not able to provide you with access to Anonymous Information about you, as we are not able to attribute any of the Anonymous Information to any specific user. From external tools, we have only access to a set of statistics and information not attributed to specific individuals.

You can, however, object to the processing of Anonymous Information about you by blocking the cookies of the external tools we use.

# 7: How long will we keep your personal data?

Your personal data shall be stored for the duration of the supply of the electronic services to you, and thereafter for archiving purposes, until the expiry of the limitation period for claims relating to the electronically provided services, and if storage is further justified by the need to be able to demonstrate proper compliance with data protection obligations, personal data shall be stored to the extent necessary for this purpose for as long as we may be subject to an audit of proper compliance with mentioned obligations.

# 8: Who are the recipients of your personal data?

We would dare to say that modern business cannot do without services provided by third parties. We also make use of such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are:

  • hosting provider,
  • invoicing system provider,
  • provider of an online chat service,
  • accounting office,
  • a maintenance service provider who gains access to the data if the technical work carried out relates to areas where personal data are located,
  • other subcontractors who gain access to the data if the scope of their activities requires such access.

All the entities mentioned above process your data on the basis of personal data processing trust agreements and guarantee an adequate level of personal data protection.

If the need arises, your data may be shared with a legal advisor or lawyer bound by professional secrecy. The need may arise from a legal need requiring access to your personal data.

In addition, if necessary, your personal data may be made available to entities, authorities or institutions entitled to access the data under the law, such as: police, security services, courts, public prosecutors' offices.

Furthermore, when it comes to Anonymous Information, the providers of the tools or plug-ins that collect Anonymous Information have access to it. The providers of these tools are their own controllers of the data collected and may share this data according to the terms and conditions they set out in their own rules and privacy policies, over which we have no control.

Please, remember that your personal data is shared with Experts in connection with the supply of electronic services to you under the terms described in our terms and conditions. Details relating to the sharing of data are indicated within the discussion of the various purposes for which personal data is processed earlier in this privacy policy.

# 9: Do we transfer your data to third countries or international organisations?

If you contact us via the chat available on the website or app, your data is transferred to the USA due to the fact that the chat service provider (TIDIO LLC) uses a technical infrastructure located in the USA. However, TIDIO LLC ensures an adequate level of protection of personal data by using a compliance mechanism in the form of standard contractual clauses.

As for the rest, your personal data is not transferred to third countries or international organisations

# 10: Do we use profiling? Do we make automated decisions based on your personal data?

We do not make decisions towards you based solely on automated processing, including profiling, which would produce legal effects towards you or similarly affect you significantly.

Yes, we do use tools that may take certain actions depending on the information collected by the tracking mechanisms, but we believe that these actions do not have an impact on you, as they do not differentiate your situation as a customer, do not affect the terms of the contract you may enter into, etc.

We can use certain tools, for example, target you with personalised advertising based on your previous actions on the website, suggest products that may be of your interest or send you better tailored emails. This is known as behavioural advertising. We encourage you to learn more about behavioural advertising, particularly with regard to privacy issues. You will find detailed information, including the possibility of managing your settings with regard to behavioural advertising, here.

We emphasise that within the tools we use, we have only access to Anonymous Information. This information is stored on the servers of the providers of the individual tools, and these servers can most often be located around the world.

# 11: What rights do you have in relation to the processing of your personal data?

The RODO gives you the following potential rights in relation to the processing of your personal data:

  • The right to access your data and receive a copy of it,
  • The right to correct (amendment) your data,
  • The right to remove (if, in your opinion, there are no grounds for your data to be processed, you can request removal),
  • The right to restrict processing (you can request that processing which is restricted to storing only your data or carrying out activities agreed with you, if in your opinion, we have inaccurate data or are processing it improperly),
  • The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which you think justifies stopping the processing covered by the objection; we will stop processing your data for these purposes unless we can demonstrate that the grounds for processing override your rights),
  • The right to data portability (you have the right to receive in a structured, commonly used machine-readable format the personal data you have provided under the contract or your consent; you can have this data sent directly to another entity),
  • the right to submit a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may submit a complaint to the President of the Office for Personal Data Protection or any other competent supervisory authority).

The rules related to the exercise of the rights indicated above are described in detail in Articles 16 - 21 of the RODO. We encourage you to familiarise yourself with these provisions. For our part, we consider it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data.

We emphasise that one of the rights indicated above is always available to you - if you consider that there has been a violation of data protection regulations in the processing of your personal data, you have the possibility to submit a complaint with the supervisory authority (President of the Office for Personal Data Protection).

You can also always request access to information about what data we hold about you and what purposes we process it for. Simply send an email to portal@finpl.co.uk. However, we have made every effort to ensure that the information of your interest is comprehensively set out in this privacy policy. You can also use the e-mail address given above if you have any questions about the processing of your personal data.

# 12: Do we use cookies and what are they?

Our website, like almost all other websites, uses cookies.

Cookies are small textual information stored on your terminal device (e.g. computer, tablet, smart phone) that can be read by our ICT system (our own cookies) or by third-party ICT systems (third-party cookies). Specific information can be recorded and stored in cookies, which can then be accessed by ICT systems for specific purposes.

Some cookies used are deleted when your browser session ends, i.e. when you close your browser (so-called session cookies). Other cookies are stored on your terminal device and allow your browser to be recognised the next time you visit the website (persistent cookies).

If you would like to find out more about cookies as such, you can read, for example, this material.

# 13: On what basis do we use cookies?

We use cookies on the basis of your consent, except where cookies are necessary for the proper supply of an electronic service to you.

Cookies that are not necessary for the correct supply of the electronic service remain blocked until you have given your consent to the use of cookies. When you visit the website for the first time, we display a message asking for your consent together with the possibility to manage cookies, i.e. to decide which cookies you agree to and which you want to block.

Please, remember that deactivating or restricting cookies may prevent you from using some of the features available on the website and may cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on the website may not be available to you.

# 14: Czy możesz wyłączyć pliki cookies?

Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also block cookies of specific sites. You can also delete previously saved cookies and other site and plug-in data at any time.

Web browsers also offer the option of incognito mode. You can use this if you do not want information about pages visited and files downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows in this mode.

Browser plug-ins are also available to control cookies, such as Ghostery. The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

In addition, there are tools available on the internet to control certain types of cookies, in particular to collectively manage behavioural advertising settings.

We also give you the possibility to control your cookies directly from our website. We have implemented a special mechanism for managing cookies that allows you to block those cookies that you do not want.

Please, remember that deactivating or restricting cookies may prevent you from using some of the features available on the website and may cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on our website may not be available to you.

# 15: What purposes do we use our own cookies for?

Cookies are used to ensure the correct functioning of the various mechanisms of the website, such as remembering the session after logging in and the correct submission of forms.

Own cookies also store information about the cookie settings you have defined via the cookie management mechanism.

# 16: What third-party cookies are used?

The following third-party cookies operate within the website:

  • Google Analytics,
  • Google Ads,
  • HotJar,
  • Tidio,
  • Facebook Custom Audiences,
  • Facebook Connect and other social plug-ins.

Details of individual third-party cookies are described below.

Google Analytics - details

We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We carry out these activities based on our legitimate interest in generating statistics and analysing them in order to optimise the website.

In order to use Google Analytics, a special Google Analytics tracking code is implemented in the code of the website. The tracking code uses cookies from Google LLC concerning the Google Analytics service. You can block the Google Analytics tracking code at any time by installing a browser add-on provided by Google.

Google Analytics automatically collects information about your use of the website. The information collected in this way is usually transmitted to Google servers, which may be located around the world, and stored there.

Due to the activated IP anonymisation, your IP address is shortened before being passed on. Only in exceptional cases is the full IP address transmitted to Google's servers and only shortened there. The anonymised IP address transmitted by your browser within the scope of Google Analytics is generally not combined with other Google data.

We emphasise that within Google Analytics we have only access to Anonymous Information.

Google Analytics and Google Analytics 360 services have been certified to the independent security standard ISO 27001. ISO 27001 is one of the most widely recognised standards in the world and certifies that the systems operating Google Analytics and Google Analytics 360 meet the relevant requirements.

If you are interested in details related to Google's use of data from sites and applications that use Google services, we encourage you to read this information.

Google Ads - details

We use remarketing functions available within the Google AdWords system operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We perform these activities based on our legitimate interest in marketing our own products or services.

When you visit the website, a remarketing cookie from Google is automatically left on your device, which collects information about your activity on the website. Thanks to the information collected in this way, we are able to display advertisements to you within the Google network depending on your behaviour on the website. For example, if you view a sub-page, this information will be recorded by the remarketing cookie so that we can target you with an advertisement that we consider appropriate. This advertising will be displayed to you within the Google network when you use the Internet, browse other websites, etc.

We emphasise that when using Google Ads, we use only Anonymous Information.

Using Google AdWords, we are only able to define the audience groups we would like our adverts to reach. On this basis, Google decides when and how it will present you with an ad.

Further processing of the information takes place only if you have consented to Google linking your browsing history to your account and using information from your Google account to personalise the advertisements that are displayed on the websites. In this case, Google will use your data to create and define target group lists for remarketing purposes on different devices. For this purpose, Google will temporarily combine the information collected with other data it has in order to create targeting groups.

If you do not want to receive personalised adverts, you can manage your ad settings directly on the Google website: https://adssettings.google.com/.

If you are interested in the details related to Google's use of data from sites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Hotjar - details

We use the Hotjar tool to understand your needs better and to optimise the website for your experience, which is a legitimate interest. The tool is provided by an external entity, i.e. Hotjar Limited, Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta.

Hotjar records every visitor to the website and allows us to play a video recording of their movement around the site, as well as to generate so-called heat maps. Within the Hotjar tool, we do not have access to information that allows us to identify you, as Hotjar does not record the process of filling in forms. The information we have access to within Hotjar is, in particular:

  • information about the operating system and the web browser you are using,
  • the sub-pages you view within the website,
  • time spent on the site and its sub-sites,
  • transitions between different sub-pages within the website,
  • the source from which you go to the service,
  • places where you click the mouse.

In order to use Hotjar, a special Hotjar tracking code is implemented in the code of the website. The tracking code uses cookies from Hotjar Limited. The information collected as part of the cookies is stored by Hotjar as part of a pseudonymous user profile. Neither Hotjar nor we use this information to identify you.

You can object to Hotjar creating your user profile, Hotjar storing information about your use of our website and Hotjar's use of cookies here: https://www.hotjar.com/legal/compliance/opt-out.

If you are interested in the details related to Hotjar's data processing, we encourage you to read Hotjar's privacy policy: https://www.hotjar.com/legal/policies/privacy.

Tidio - details

We use Tidio chat, which allows you to contact us and the experts directly. The chat service is provided by an external entity - TIDIO LLC, 60 Spear Street, #1000 San Francisco, California 94105, United States of America.

Cookies of a third party, TIDIO LLC, are used in connection with the chat function. TIDIO LLC have access to the information collected through these files. This information is used to analyse and improve the functioning of the chat service, to understand better how users use the chat and to adapt the service to users' preferences. In addition, TIDIO LLC cookies are used to remember choices you make when using the chat service, such as language preferences.

The information collected via TIDIO LLC cookies is in the nature of Anonymous Information. We do not have access to this information at all. The use of cookies is only relevant in this regard in that it allows the chat service to function properly.

Facebook Custom Audiences - details

As part of the Facebook Ads system provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, we use the Custom Audience Groups function to target specific user groups with targeted advertising messages. We carry out activities in this respect based on our legitimate interest in marketing our own products or services.

In order to target you with advertisements personalised to your behaviour on the website, a Facebook Pixel is implemented within the website, which automatically collects information about your use of the website. The information collected in this way is usually transmitted to Facebook servers, which may be located anywhere in the world, particularly in the United States of America (USA).

The information collected within Facebook Pixel is anonymous, i.e. it does not allow us to identify you. Depending on your activity on the site, you may be targeted to a specific audience, but we do not identify individuals belonging to these groups in any way.

The Facebook Pixel may track and remember, among other things, the following behaviours of yours:

  • display the content of a specific page,
  • moving to the checkout within the shop,
  • finalising the purchase within the shop,
  • filling in a specific form, e.g. subscribing to a newsletter.

However, we would like to inform you that Facebook may combine the information collected with other information collected about you through your use of Facebook and use it for its own purposes, including marketing. Such activities of Facebook are no longer dependent on us, and you can look for information about them directly in Facebook's privacy policy. From your Facebook account, you can also manage your privacy settings. You will find useful information in this regard here.

Facebook Connect and other social plug-ins - details

Our website uses plug-ins, buttons and other social media tools, collectively referred to as "plug-ins", provided by social networks such as Facebook, Instagram, LinkedIN, Twitter.

When displaying a web page containing a plug-in of a particular social network, your browser sends information to the administrator of that social network about the visit. As the plug-in is a piece of the social network embedded in the page, the browser sends a request to download the content of the respective social network to the page.

The plug-ins collect certain information about you, such as your user ID, the website visited, the date and time and other browser information.

The social network administrators use some of this information to personalise the viewing conditions of our site. For example, when you visit a page with a "Like" button, the social network administrator needs information about who you are in order to show you which of your friends also like our page.

The information collected by the plug-ins may also be used by the social network administrators for their own purposes, such as, for example, improving their own products, creating user profiles, analysing and optimising their own activities, targeting advertisements. We have no real influence on how the information collected by the plug-ins is subsequently used by the social network administrators. You can look for details in this regard in the rules and privacy policies of the individual social networks.

Social network plug-ins collect and transmit information to the administrators of these social networks even when you browse the website without being logged in to your social network account. However, the browser then sends a more limited set of information.

If you have logged in to one of the social networks, the site administrator will be able to directly attribute your visit to our site to your profile on the respective social network.

If you do not want social media sites to attribute the data collected during your visit to our website directly to your profile on the respective site, you must log out of the site before visiting the site. You can also completely prevent plug-ins from loading on the website by using the appropriate extensions for your browser, such as script blocking.

In addition, the use of certain plug-ins may involve the publication of certain information within your social profiles. For example, information about clicks on the 'Like' button may be available on your Facebook timeline. Of course, if you share any content on your social media using plug-ins embedded on our website, this sharing will naturally be visible on your profile.

With regard to the details relating to the processing by the social network administrators of the information collected by the plug-ins, in particular the purpose and scope of the data collection and its further processing and use by the administrators, as well as the possibility of contacting you and your rights in this respect and the possibility of making settings to ensure the protection of your privacy, you will find everything in the privacy policies of the respective service providers:

# 17: Do we track your behaviour undertaken on our website?

Yes, we use Google Analytics, Google Ads, HotJar and Facebook Custom Audiences tools which involve collecting information about your activities on our website. These tools are described in detail under the question on third-party cookies, so we will not repeat this information here.

# 18: Are we targeting you with targeted advertising?

Yes, we use Facebook Ads and Google Ads, whereby we can target adverts to specific target groups defined on the basis of various criteria such as: age, gender, interests, profession, job, activities previously undertaken on our website. These tools are described in detail in the question on third-party cookies, so we do not repeat this information here.

# 19: How can you manage your privacy?

The answer to this question can be found in many places in this privacy policy when describing individual tools, behavioural advertising, consent to cookies, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.

  • the cookie settings within your internet browser,
  • Browser plug-ins supporting cookie management, e.g. Ghostery,
  • additional cookie management software,
  • incognito mode in the web browser,
  • behavioural advertising settings, e.g. youronlinechoices.com,
  • Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout,
  • Google Ads Settings: https://adssettings.google.com,
  • HotJar Opt-out: https://www.hotjar.com/policies/do-not-track/,
  • Facebook Ads Settings: https://www.facebook.com/ads/settings,
  • mechanism for managing cookies from our website.

# 20: What are server logs?

The use of the website involves sending requests to the server where the website is stored. Each request made to the server is recorded in the server logs.

The logs include, among other things, your IP address, the date and time of the server, information about the web browser and the operating system you are using. The logs are saved and stored on the server.

The data stored in the server logs are not associated with specific users of the website and are not used to identify you.

The server logs are only ancillary material for the administration of the site, and their contents are not disclosed to anyone other than those authorised to administer the server.

# 21: Is there anything else you should know?

As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge on the issues that are important to you. If anything is unclear to you, you would like to find out more or simply discuss your privacy, please email portal@finpl.co.uk.

# 22: Is this privacy policy subject to change?

Yes, we may modify this privacy policy, in particular due to technological changes and changes in legislation. If you are a registered user, you will receive a message about any change to the privacy policy. In addition, all archived versions of the privacy policy are linked below.

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