Finastra California Privacy Notice
Updated: December 31, 2022
This document gives notice how Finastra* (”we”, “our”, “us”, “Finastra”) handles Personal Information that is subject to the California Consumer Privacy Act of 2018 and corresponding regulations (the “CCPA”).
This Notice describes the practices we have adopted with respect to processing Personal Information as a “business” under the CCPA including the collection, use, storage or disclosure of Personal Information, without limitation, (i) on our websites that link to this Notice (collectively the "Sites"); or (ii) when you participate in our webinars, events, trade shows and demonstrations of our Services.
This Notice does not apply to information governed under regimes other than the CCPA such as information subject to the Gramm-Leach-Bliley Act or certain information subject to the Fair Credit Reporting Act.
If you are a California resident, you may request certain information from or certain action by us, such as exercising the access and deletion rights described below, or you may authorize an agent to make such a request on your behalf. We will seek to verify your identity and your agent’s authority when we receive an individual rights request from you or on your behalf to ensure the security of your Personal Information, and may need to collect additional Personal Information to do so.
Please direct any such rights requests (as further described below) or additional questions that you may have regarding this Notice to email@example.com or by post to Four Kingdom Street, Paddington, W2 6BD, United Kingdom.
California residents have the right to request the deletion of Personal Information, but we may not delete some or all Personal Information, as required or permitted by applicable law, such as if the requested information is necessary to fix our Services in the case of a bug; comply with a legal obligation; or make other internal and lawful uses of the information that are compatible with the context in which you provided it.
If you are a California resident, you may also request to receive details about how we collect, use, and share your Personal Information. You may also request to receive the specific pieces of Personal Information that we have collected about you.
Right to Correct Inaccurate Personal Information
You have the right to correct inaccurate Personal Information that we maintain about you.
Opt-out of Sale
If a business sells Personal Information, you have a right to opt-out of that sale. We do not, and do not intend to, sell the Personal Information of California residents and, furthermore, do not have actual knowledge that we sell the Personal Information of consumers under 16 years old.
Right to Limit Disclosure of Sensitive Personal Information
We do not use or disclose your sensitive Personal Information outside of the limited purposes set forth below, so you do not have the right to direct us to limit our use and disclosure of such sensitive Personal Information. For example, we may use your sensitive Personal Information for certain limited purposes, such as the following: (1) performing our service or providing goods, (2) detecting security incidents, (3) resisting malicious, deceptive, fraudulent, or illegal actions, (4) ensuring physical safety, (5) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and (6) to verify and maintain the quality or safety of a service or product to improve, upgrade, or enhance a service or product.
Businesses may not, and we do not, discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.
Sharing and Selling of Personal Information
We do not sell your Personal Information in exchange for monetary consideration without your consent.
We may allow certain third parties (such as online advertising services) to collect your Personal Information via automated technologies in exchange for non-monetary consideration. We share the categories of Personal Information listed below for the business and commercial purposes of online advertising and to provide third-party social network features and functionality. Those third parties may use your Personal Information for optimization, display cross-contextual advertising and manage their own platforms. You have the right to opt out of this disclosure of your information. You may opt out of the sale or sharing of your Personal Information by implementing the Global Privacy Control signal.
During the 12-month period prior to the effective date of this Privacy Notice, we may have sold or shared the following categories of Personal Information:
|Category of Personal Information||Category of Third Party|
|Identifiers||Advertising networks, data analytics providers, social networks|
|Commercial Information||Advertising networks, data analytics providers, social networks|
|Online Activity and Geolocation Data||Advertising networks, data analytics providers, social networks|
SERVICE PROVIDER DESIGNATION
When offering Services to our customers, we may act as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our customers in order for us to provide our Services. This Notice does not apply to the information, if any, that we collect pursuant to our role as a service provider.
ADDITIONAL CCPA DISCLOSURES
Categories of Personal Information Collected and Disclosed
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents:
- Identifiers, such as name and email address;
- Commercial information, such as transaction information and purchase history;
- Internet or network activity information, such as browsing history and interactions with the Sites;
- Geolocation data, such as device location and Internet Protocol (IP) location; and
- Professional or employment-related information, such as work history and employer.
Categories of Sources
The categories of sources from which we collected this Personal Information are:
- Directly from you or your agent, such as when you attend an event or webinar that we host or fill out a form that we provide;
- Passively through tracking technologies regarding your use of the Sites; and
- Our service providers and other third parties that provide online tracking and advertising services.
Categories of Recipients
The categories of third parties to whom we disclosed all of the categories of Personal Information that we disclose for our business purposes are:
- Vendors and service providers who provide services such as website hosting, data analysis, payment processing, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities; and
- Partners and third parties who provide services such as legal expertise, tax expertise, and auditors.
Purposes for Collection and Disclosure
We have collected and disclosed all the categories of Personal Information that we collect for the following purposes:
- To market our Services and provide other information about Finastra;
- Performing Services and making available other products or information related to our business, processing or fulfilling orders and transactions;
- Advertising or marketing Services and performing analytics;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
- Undertaking activities to verify or maintain the quality or safety of our business and Services; and
- Complying with laws and other legal process and law enforcement requirements.
*Turaz Global S.à r.l and its group companies