Privacy Policy

This privacy policy (the “Privacy Policy”) governs the relations between Fineon Exchange S.àr.l., a Luxembourg private limited liability company, having its registered office at 14 rue Mathias Hardt, L-1717 Luxembourg, Grand Duchy of Luxembourg, registered with Luxembourg Business Registers under number B227406 (hereafter “Fineon”) and the individual user (the “User”) that uses the services provided by Fineon, as described in its terms of service (the “Terms”).
If necessary, this Privacy Policy is supplemented by the Terms or by special terms and conditions (the “Special Terms”) that prevail in case of conflict with the Privacy Policy.
This policy is drafted in English. If there is a conflict between a translated version and the English version of these terms then, to the extent permitted under applicable law, the English version shall prevail.
This policy sets out how we may collect personal data from you, when we may collect person data from you, the type of personal data and/or sensitive personal data we may collect from you or that you provide to us, and how such data may be controlled and/or processed once you use or access features on the Fineon website.


How we collect personal data

Personal data and sensitive personal data may be collected by us actively and passively. The specific types of personal data we may collect from you, and the manner in which such data may be collected, includes:
1. Necessary Data. This is data we must collect in order to activate, and provide you with access to, content found on our website, as well as to enable you to access and use that content across multiple devices, to enable you to delete personal data when you wish, and/or for us to deliver content or services that you request through the website. We may also use Necessary Data for the purpose of providing you with information about similar products and services we provide.
Necessary Data includes, but is not limited to, your name, email address, address.
Necessary data will be collected by us when you fill in and submit the relevant form through the website which contains that data.
2. Optional Data. This data includes information which is not necessary for us to collect but which you actively choose to provide to us (“Optional Data”).
Optional Data includes, but is not limited to, your age, your reasons for using the website or company information. We may also use Optional Data for the purpose of analysing your requirements as a consumer and providing you with information about other products and services we provide which may be of interest to you.
Optional Data will be collected by us when you submit a request for content through forms throughout the website which request that data.
You may be able to actively provide us, at any time in the future, with additional Optional Data if you choose to do so. We will collect and use that data in accordance with these terms.
3. Website Data. This data is passively collected by us in the course of you using and browsing the website.
Website Data includes, but is not limited to, your device’s Internet Protocol (IP) address, web cookies, browser type and version, the pages of our website you visit, the amount of time spent on each page of our website, time zone settings, the time and date of your visit and the operating system or platform you use, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), content you have viewed or searched for, page response times, download errors, length of visits to certain pages within the website, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Website Data is collected by us when it is transmitted to us during or after your use of the website. Such data may or may not be anonymised and will be used as further described below.


How we use your personal data

We may use Necessary Data for the purpose of providing content after you have requested it by filling in form, or for the purpose of creating your personal user account in order for you to gain full accessibility to the website and its content. For instance, when requesting content on our website you provide us with your phone number which will help our internal teams respond to your requests.
We may use website data for the purpose of understanding how our clients behave in order for us to develop or optimise:

  • How the website works for you;
  • The information and services provided to you through our website; and
  • The effectiveness of our online advertising and branding.

All personal data we collect and process is stored on our secure servers in accordance with reasonable security practices.
Where you have chosen (or where we have given you) a password which enables you to access certain parts of our website, or use our website in a particular way, you are responsible for keeping this password confidential. We ask you not to share this password with anyone and to change it if you suspect someone has gained access to it.



We will generally process your personal data with your express written consent, We may also process your personal data in accordance with this Privacy Policy if permitted under applicable Legislation For example, we may be able to legally control and process your personal data without your express consent for direct marketing purposes, if doing so is in the public interest, where it is necessary for performance of a contract, or if we must do so in order to comply with a local or national law.
We may also process your personal data without your express written consent if we have a legitimate interest in doing so, for example, for some internal administrative purposes, or for the purpose of ensuring electronic information security.
If we are controlling and processing your personal data on the sole basis of having your consent to do so, we must gain separate consents from you in respect of each distinct type of processing operation.
Where we are processing your personal data on the basis of you have given us your consent to do so, you do have the right to withdraw that consent at any time, but this will not affect the lawfulness of processing prior to the withdrawal of such consent. You can exercise your right to withdraw consent to processing at any time by contacting us.


Children’s privacy

The goods and services provided through our website are not marketed to, and should not be used by anybody under the age of 16.
We do not knowingly collect personal data from children under the age of 16. In the event that we discover that a child under the age of 16 has provided us with personal data, we will delete such data from our servers unless consent is given or authorised by the holder of parental responsibility over the child.


Use of Third Party Platforms

If you integrate your User Account with Third Party Services, Fineon may receive and use personal information in accordance with the privacy policies of such Third-Party Services.
Our Platforms use Google Analytics, a web analytics service offered by Google Inc. Google Analytics will make use of small pieces of data, known as cookies, which can be used to track and analyse the manner in which you use and operate our Platforms. Such data will be transferred to, and stored on a server in the USA operated by Google, Inc. Google, Inc. may i) transfer this data to third parties where required by law, or other third party processors used by Google, Inc. You may prevent cookies from being stored in relation to your visit to, and use of, our Platforms but do please be aware that this may negatively impact upon the way in which the Platforms work.
This website uses a HubSpot tracking code which uses cookies or similar technologies to track visitors. We use the information gathered to improve our website functionality, the user experience and content.
Log files
HubSpot uses log files. Log files may collect demographic information from you, for example, address, age, gender or interests. They may also collect information about your computer hardware and software. This can include your IP addresses, device and software identifiers, referring and exit URLs, on-site behaviour, feature use metrics and statistics. This information is used for the Subscription Service. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
Navigational Information
We may collect navigational information when you visit HubSpot hosted web pages on our website. The navigational information is used to improve your experience of using the website and to ease navigation around the site.
To find out more about HubSpot, please review their privacy policy and their security guidance.
The HubSpot Acceptable Use Policy applies to our website and prohibits the use of our website to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service to have an “opt-out” mechanism.
Some pages of our website are hosted in England and by HubSpot whose registered address is: 25 First Street, 2nd Floor, Cambridge, MA 02141, USA. Data captured and obtained within the UK, may be processed outside of the UK.
This website uses a LinkedIn tracking code which uses cookies or similar technologies to track visitors of this website and gathers information about them related to their LinkedIn profile. We use the information gathered to improve our website functionality, user experience and tailor content. This data is used to deliver customised content and promotions to users whose behaviour indicates that they are interested in a particular subject area.
For more information about LinkedIn’s privacy policy, click here.


Transfers outisde the EEA:

We may also transfer any personal data we hold to a country outside the European Economic Area (EEA), provided that one of the following conditions applies:

  • The country to which the personal data is transferred ensures an adequate level of protection for the data subjects’ rights and freedoms;
  • You have given your consent;
  • The transfer is necessary for one of the reasons set out in the Act and/or Regulation, including the protection of your vital interests;
  • The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
  • The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.

Personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. That staff may be engaged in, among other things, the provision of support services. We require that staff to comply with the requirements of this Privacy Policy.


Code of Conduct

The Service may be used for lawful purposes only. The Service shall not be used to post, transmit, communicate or otherwise distribute illegal material.
You further agree to not:
Defame abuse, harass, threaten or otherwise violate the legal rights of others or of any third-party including Fineon ;
In any manner publish or post any inappropriate, defamatory, infringing, obscene, pornographic, racist, terrorist, politically slanted, indecent or unlawful topic, name, material or information; or
Contribute to destructive activities such as dissemination of viruses, spam or any other activity that might harm the Service or Fineon in any way.



By accepting or using the Service, you consent to the provisions set out in this Policy and to Fineon’s use of your information as set out herein.
If you do not agree to any of the provisions of this Privacy Policy, you are not entitled to access or use the Service, and you shall refrain from doing so.
Please note that when using the Service, you may find links to other websites, applications and services (“Third Party Services”) or tools that allow you to share information from the Service with Third Party Services. Fineon is not liable for the content, privacy policies, or practices of such other Third-Party Services and you are recommended to review their privacy policy and other terms before sharing any information with or using such services.


The Information Fineon Exchange Collects

When you use the Service, Fineon or the entities which Fineon cooperates with in order to operate the Service (see section 7 below) may collect the following categories of your personal information:

Registration Information

Fineon will collect information necessary to create a User Account, including your email address, the Entity that you belong to and password (“Registration Information”).

Personal Information provided by you

Fineon may collect information that you voluntarily add to your profile, such as your name, position, industry, country of residence and city of residence.


User Information and Account

You are only allowed to register for one User Account and are responsible to ensure that any information that you provide during your use of the Service is accurate, complete and current at all times. Fineon takes no responsibility in regards to the validity of information provided by you or other Users.
You are responsible for your personal password and warrant to treat it as sensitive and confidential information, including not sharing your password with any third party. You acknowledge that your password is unique to you and that, although Fineon has the ability to reset your password, Fineon does not have access to your password.
Upon registration, you warrant that you have the legal capacity, or the legal consent, to register the User Account. You further agree that you and/or the Entity on whose behalf you use the Service, will be entirely responsible for any and all access, activities and use of the Service conducted under your designated User Account.
Fineon reserves the right to suspend or terminate your User Account if activities occur which, in Fineon’s sole discretion, constitutes or may constitute a violation of this Privacy Policy, the Terms, the Data Processing Agreement or any applicable local or international laws, rules or regulations.


How We Use Your Information

Fineon will store and use your personal information for the purposes of:

  • Operating and maintaining your User Account;
  • Providing information and the Service;
  • Analysing the user of the Service and its Users in order to personalize and improve it;
  • Communicating with you for purposes related to the Service;
  • Providing you with relevant information, which can include newsletters and tailored offers from Fineon’s partners;
  • Enforcing its Terms or this Privacy Policy; and
  • As otherwise stated in this Privacy Policy.


Who Can See Your Information

You control at all times who can see your personal information in the Service.
Pursuant to General Data Protection Regulation (EU) 2016/679 (“GDPR”), you have the right to request from Fineon acting as processor on behalf of the Exporter the access to and rectification or erasure of your personal data or restriction of processing and transfer concerning your data.
Personal information such as title, geography and industry are not visible to other Users of the Service.
Your full name and Entity is associated with any request submitted by you (the “requestor”) and become visible only to Fineon Exchange Relationship Managers, matched Funders and/or Insurers. Once an offer created by the Exporter is matched, all relevant requested information such as KYC, company profile, audited financials, obligor credit history and obligor information sheets will be visible to the matched Users. However, matched Users cannot see other matched Users’ names.
You choose, in complete independence and according to your objectives, the personal information and the relevant documents that you wish to upload on the Fineon Exchange Platform and that you wish to share with the Funders and/or any third-party.
The obligations borne by Fineon to assist you for the registration of your User Account and for the uploading of your relevant documents requested by Funders and/or any third party constitute obligations of means.
Your geography and industry may be used by Fineon for reporting aggregated data over multiple Users, industries and geographical areas.
Changes to the User and Privacy Policy
Fineon may from time to time and in its own discretion make changes to this Privacy Policy. The date of last modification is stated at the start of this document. It is your responsibility to check the current version of the Privacy Policy from time to time for updates.
If and when Fineon makes revisions to the Privacy Policy that Fineon consider material, Fineon will inform you through the Service. You will have no obligation to continue using the Service following any such notification, but if you continue to use the Service after said notification it will constitute your acceptance of the changes.