PRIVACY POLICY


This Privacy Policy (the “Policy”) describes how FINGLOBAL LLC, a New York domestic limited liability company, with its registered office at 418 Broadway, Ste N, Albany, NY 12207, USA (the “Company”, “we”, “us”), acting as a data controller, collects, processes, stores, and protects personal data of individuals who access our Website, purchase or use our subscription-based digital service delivering AI-generated trading ideas, signal-style indications, market commentary and related informational features (the “Service”), or interact with any related communication channels (such as WhatsApp, Telegram or similar).

By accessing the Website, submitting forms, or otherwise engaging with our Services, you acknowledge this Policy.

If you do not agree to the terms of this Policy, please refrain from using the Services or submitting any personal data.

1. DEFINITIONS
For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:
1.1. “Site” means the official website of the Company available at https://finglobal.ai/ including any subdomains, language versions, and digital environments directly controlled by the Company through which Users may access the Services.
1.2. “Company”, “we”, “us” refers to FINGLOBAL LLC, a New York domestic limited liability company, acting as the provider of a digital, subscription-based Service delivering AI-generated trade ideas, signal-style indications, market commentary and related informational features, as described in the Terms of Service.
1.3. “Participant”, “User”, or “you” means a natural person of legal age and full legal capacity who accesses or uses the Services, in accordance with the Terms and Conditions.
1.4. “Personal Data” means any information relating to an identified or identifiable natural person, as defined under applicable data protection laws, including but not limited to:
  • information provided by the User during registration or in the course of using the Services;
  • automatically collected technical data such as IP address, cookie identifiers, browser type, device specifications, timestamps, and navigation paths;
  • any other information voluntarily submitted by the User or generated in connection with the use of the Services.
1.5. “Service” or “Services” refers to the digital, subscription-based service delivering AI-generated trade ideas, signal-style indications, market commentary, risk-management frameworks, community-based discussions and other non-personalised informational features made available by the Company from time to time, including delivery via designated communication channels (such as WhatsApp, Telegram or similar), as further described in the Terms of Service.
1.6. “IP address” means a unique numerical identifier assigned to each device connected to a computer network that uses the Internet Protocol for communication.
1.7. “Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, alignment, restriction, erasure, or destruction.
1.8. “Confidentiality” means the obligation not to disclose Personal Data to unauthorized third parties without a legal basis or the explicit consent of the data subject.
1.9. “Controller” means the legal entity (in this case, the Company) that determines the purposes and means of processing Personal Data.
1.10. “Consent” means any freely given, specific, informed, and unambiguous indication of the User’s wishes by which they, through a statement or clear affirmative action, signify agreement to the processing of their Personal Data.
Unless otherwise required by context:
  • words denoting the singular include the plural and vice versa;
  • words denoting gender include all genders;
  • references to terms such as “including”, “in particular”, or similar shall be construed as illustrative, not limiting;
  • section headings are for convenience only and do not affect interpretation.

2. GENERAL PROVISIONS
2.1. This Privacy Policy applies to all Personal Data collected through the Website, the Service and any related communication channels, including but not limited to online platforms, mobile or desktop applications, community spaces, chat groups, and messaging tools (such as WhatsApp or Telegram) used to deliver the Service, or otherwise in connection with your use of or participation in the Service. We collect and process your Personal Data for the purpose of delivering, administering and supporting the Service, managing Subscriptions and billing, providing user support and Service-related communications, ensuring technical and information security, analysing Service usage, complying with legal obligations, and enforcing our rights under the Terms of Service.
2.2. The Company is committed to protecting the privacy and integrity of all Personal Data processed in connection with the Services. We uphold high standards of data confidentiality and transparency and aim to create a secure and respectful environment for all Users.
2.3. This Policy explains how we collect, use, disclose, and protect your Personal Data when you access the Site or participate in the Services. This Policy does not apply to the practices of third-party websites, platforms, or entities not owned or controlled by the Company, even if linked to from our Site.
2.4. As the data controller, FINGLOBAL LLC determines the purposes and means of processing your Personal Data in accordance with applicable data protection laws, including, where relevant, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable U.S. privacy requirements.
2.5. By registering on the Site, using the Services, or otherwise affirmatively consenting through available mechanisms (e.g., checkbox, submission form, platform registration), you provide your informed and voluntary consent to the collection, use, storage, transfer (including to authorized service providers), and other forms of Processing of your Personal Data as described in this Policy.

3. DATA WE COLLECT ABOUT YOU
3.1. Depending on your interaction with the Site and participation in the Service, we may collect, process, store, and use different types of Personal Data, including the following categories:
3.1.1. Basic Customer Information. This includes, in particular:
  • your first and last name;
  • postal address and country of residence;
  • telephone number and messaging identifiers used to deliver the Service (such as your WhatsApp or Telegram number/account, where applicable);
  • email address;
  • account credentials (such as username and password, if an account is used to access the Service).
3.1.2. Financial and Transaction Information. We may process limited financial and transaction-related information in connection with your payments for the Service, including:
  • the type of payment method used (e.g. card, bank transfer, digital wallet);
  • partial payment card or account details made available by our payment processors (for example, card type, the last four digits of the card number, expiry month and year, or an anonymised payment token);
  • billing address and country;
  • records of payments made to us, including the date, amount, currency, status (successful, failed, refunded, chargeback) and related internal transaction identifiers. 
  • We do not collect or store full payment card numbers or full bank account numbers ourselves; such data is processed directly by our authorised payment service providers in accordance with their own security and compliance obligations.
3.1.3. Preferences and Settings. This includes information about your preferences and settings when using the Service, such as:
  • your chosen language, time zone and display settings;
  • your communication and notification preferences (for example, whether and how you wish to receive updates, alerts or marketing communications);
  • your selected Service configuration or Access Option, where applicable.
3.1.4. Transaction and Usage Data. This includes information about how you use the Service and interact with us, for example:
  • which Service features, AI-generated trade ideas, signal feeds or materials you access;
  • how frequently you log in, receive or open Service-related messages;
  • your interactions with our communication channels and community spaces (such as message activity, participation in discussions or reactions to content);
  • technical logs relating to your use of the Service (such as access timestamps, session identifiers, IP address, device and browser information, and general location data at city level).
3.1.5. Additional Information You Provide to Us Directly. We also collect information that you choose to provide to us directly, including when:
  • you place orders, subscribe to the Service or manage your Subscription;
  • you contact us with questions, support requests or other communications (including emails, chat messages or tickets);
  • you upload files, submit forms or share content in connection with the Service;
  • you participate in surveys, feedback requests or user research initiatives;
  • you take part in our community spaces, post comments, reviews or other contributions that may be visible to other Users;
  • you share information about your experience, goals, risk tolerance or knowledge in areas covered by the Service, to the extent you decide to disclose such information.  
  • Where permitted by applicable law and clearly communicated to you in advance, we may also keep records or transcripts of support calls and other interactions with our team for quality assurance, training and dispute resolution purposes.
3.1.6. Technical Data, collected automatically through your use of the Site or Services, including:
  • device and browser information (e.g., type, version, plugins);
  • operating system and interface settings;
  • time zone, language preferences, and screen resolution;
  • IP address and general location data (city-level);
  • interaction logs such as clicks, scrolls, hover actions, and navigation paths;
  • diagnostics and performance data (e.g., loading errors or session duration);
  • usage of cookies, pixel tags, or similar technologies.

  • 3.1.7. Anonymous or Pseudonymized Data, which may be generated by removing identifiers from collected Personal Data. We may use such data to analyze trends, improve user experience, and enhance the functionality of the Services. Anonymous data may be shared with third parties at our discretion, provided it cannot be used to identify an individual.
  • 3.2. We may also process aggregated data, such as statistical summaries or generalized demographic indicators. While such data may be derived from Personal Data, it is not considered Personal Data under applicable law unless it is combined in a manner that directly or indirectly identifies an individual. If we do link aggregated data to your identity, it will be treated as Personal Data and processed accordingly.
  • 3.3. We do not collect or process any special categories of Personal Data as defined by Article 9 of the GDPR. This includes, but is not limited to, information relating to your race, ethnicity, religion, political opinions, trade union membership, sexual orientation, health status, or biometric identifiers.

4. PERSONAL DATA COLLECTION
4.1. We collect Personal Data from Users through various sources and by the following means:
(a) Direct Interactions. You may provide Personal Data to us directly when you:
  • visit or browse our Site;
  • register an account or submit a form;
  • subscribe to the Services or any communications;
  • contact our support team;
  • respond to surveys, participate in promotions, or provide feedback.

(b) Automated Technologies. When you use the Site, we may automatically collect certain technical and usage-related Personal Data. This may include:
  • browser and device identifiers;
  • IP address and general location;
  • session data and clickstream behavior;
  • cookies, logs, and other tracking technologies.
This data helps us enhance the performance, security, and personalization of your experience.

(c) Third-Party Sources. We may receive Personal Data from:
  • social media platforms, when you connect or communicate with us via such services;
  • payment service providers, when processing your subscription or purchase;
  • analytics or advertising networks;
  • hosting and infrastructure providers;
  • communications platforms.
Such data is subject to the privacy policies of the respective third parties.

(d) Public Sources. We may access publicly available information, such as content published online or in official registers, when relevant for fraud prevention, identity verification, or legal compliance.
4.2. We only collect Personal Data that you knowingly and voluntarily provide or that is obtained in accordance with applicable legal grounds. Providing Personal Data for the purpose of using the Services and Site constitutes your consent to its processing in accordance with this Privacy Policy, unless another legal basis under Article 6(1) of the GDPR applies.

5. PURPOSES OF PERSONAL DATA USAGE
5.1. We process your Personal Data only when there is a valid legal basis under applicable data protection laws, including:
  • to perform our contractual obligations under the Terms of Service;
  • to comply with legal and regulatory obligations;
  • to pursue our legitimate interests (provided that such interests are not overridden by your fundamental rights and freedoms);
  • where you have provided your explicit consent (e.g., for marketing communications).
  • Certain categories of Personal Data are necessary for us to enter into and perform the Terms of Service with you and to provide you with access to the Service. If you choose not to provide such information, or if you later request its deletion or object to its processing in a way that prevents us from performing the contract, we may be unable to create or maintain your account or to continue providing you with the Service, and we may be required to deactivate or close your account.
5.2. Specifically, we use and may disclose your Personal Data for the following purposes:
  • to register you as a Participant and provide access to theServices;
  • to process payments and manage transactional records;
  • to deliver support, resolve inquiries, and maintain communication with you;
  • to notify you of updates to the Site, Services, Terms of Service, or this Policy;
  • to collect insights on how Participants interact with the Services, for product improvement and experience optimization;
  • to analyze market behavior and participant preferences, in support of business development and communication strategies;
  • to administer, monitor, troubleshoot, and improve the technical performance and security of the Site and Services;
  • to maintain secure backups and data recovery systems;
  • to share data with trusted service providers or contractors, bound by confidentiality and data protection agreements;
  • to ensure compliance with the Terms of Service and enforce our rights;
  • to protect the safety and rights of Participants, third parties, and the Company;
  • to comply with legal requests, court orders, and government requirements;
  • to obtain legal, accounting, and professional advice;
  • to exercise or defend legal claims;
  • to respond to legitimate law enforcement or national security requests;
  • for any additional purpose where you have expressly consented.
5.3. With your consent, we may use your identity, contact details, technical and usage data to inform you about services, offers, or updates that may be relevant to your interests (“marketing communications”). You may receive such communications if:
  • you have previously requested information or subscribed to the Services; and
  • you have not opted out of receiving such messages.
5.4. You may withdraw your consent to receive marketing communications at any time by:
  • clicking the “unsubscribe” link in our emails;
  • adjusting your preferences in your account settings (if available); or
  • contacting us at: info@finglobal.ai.

6. PERSONAL DATA DISCLOSURE
6.1. We treat all Personal Data as confidential and do not disclose it to third parties except as permitted under this Privacy Policy, required by law, or authorized by your explicit consent. We do not sell, rent, or trade your Personal Data to any other party. Disclosure may occur solely for the purposes of providing and improving the Services, complying with legal obligations, protecting our legitimate interests, or where necessary to perform a contract with you.
6.2. We may disclose your Personal Data to trusted service providers, agents, subcontractors, or affiliated companies who assist us in delivering the Services. These third parties may include, in particular: technical infrastructure, hosting and cloud storage providers; customer support platforms and communication tools; payment processors and billing service providers; sales enablement, marketing and advertising partners;  analytics and product experience providers; service providers assisting with content delivery and product features;  security, fraud detection and prevention service providers;  research and user feedback tools;  legal, tax, compliance and other professional advisors. All such parties are bound by strict contractual obligations to process your data in accordance with applicable data protection laws and solely for the purposes specified by the Company.
6.3. We may also disclose your Personal Data if required by law, judicial process, or governmental authority, or if necessary to enforce our Terms of Service, investigate fraud or security incidents, protect our rights or those of other Users, or ensure compliance with legal and regulatory requirements. In the event of a corporate restructuring, including merger, acquisition, asset sale, or insolvency, your data may be transferred to a successor entity, subject to continued protection under this Policy and applicable law.
6.4. The Site may contain links to third-party websites or services. Please be aware that such sites operate independently and have their own privacy practices. We are not responsible for the content, terms, or data handling of these external services and encourage you to review their policies before interacting with them or submitting any Personal Data.

7. SAFETY
7.1. We are committed to maintaining the security and confidentiality of your Personal Data and have implemented appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, destruction, or other forms of unlawful processing in accordance with applicable data protection laws. Access to your Personal Data is strictly limited to authorized employees, contractors, or service providers who are bound by confidentiality and data protection obligations and who require such access in order to perform their designated functions.
7.2. All Personal Data exchanged between you and the Site is transmitted via secure SSL (Secure Socket Layer) technology and is encrypted to prevent interception. In the case of online payments, transaction data is encrypted during transmission and processing. If you are provided with (or choose) a password to access certain sections of the Site or Services, you are solely responsible for maintaining the confidentiality of such credentials and must not share them with third parties.
7.3. While we implement industry-standard safeguards to protect your information, you acknowledge that no method of transmission over the Internet or method of digital storage can be completely secure. We therefore cannot guarantee absolute security of your data, although we make every reasonable effort to prevent security breaches.
7.4. Depending on the specific risks associated with the processing of your Personal Data, we may implement additional protective measures, including but not limited to: staff training and internal privacy protocols, physical access controls, encryption and pseudonymization techniques, data availability and recovery mechanisms, and regular system audits.
7.5. We also maintain procedures for detecting and responding to potential Personal Data breaches. In the event of a confirmed breach that may pose a risk to your rights and freedoms, we will promptly notify you and the relevant supervisory authority in accordance with applicable law.

8. PERSONAL DATA RETENTION
8.1. We retain your Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, tax, accounting, or reporting obligations. In certain circumstances, we may retain your data for a longer period, particularly where it is necessary for the establishment, exercise, or defense of legal claims, enforcement of our agreements, fraud prevention, or internal auditing purposes.
8.2. When determining the appropriate retention period, we consider the nature, volume, and sensitivity of the Personal Data, the risk of potential harm from unauthorized use or disclosure, the purposes for which we process the data and whether those purposes can be achieved through alternative means, as well as the legal requirements applicable in the United States, the European Union and any other relevant jurisdictions.
8.3. Once your Personal Data is no longer required for the stated purposes, or when the retention period expires, we will securely delete, anonymize, or destroy such data in accordance with industry best practices and applicable data protection laws.

9. SAFETY OF MINORS
9.1. The Services and Site are not intended for use by individuals under the age of majority or those lacking full legal capacity under applicable law. We do not knowingly collect or process Personal Data from minors. By using the Site or participating in the Services, you confirm that you are of legal age and possess full legal capacity to enter into binding agreements.
9.2. We take the protection of minors seriously and urge parents and legal guardians to educate their children about responsible online behavior and the risks associated with sharing personal information over the Internet.
9.3. If a parent or legal guardian becomes aware that a minor has provided us with Personal Data in violation of this Policy, they should contact us without delay at info@finglobal.ai . Upon receiving such a request and verifying the status of the data subject, we will promptly take all reasonable steps to delete the information from our systems and prevent further processing.

10. INTERNATIONAL DATA TRANSFERS
As the Company operates internationally, your Personal Data may be transferred to and processed in countries outside of your jurisdiction, including countries outside the European Economic Area (EEA), such as the United States and other jurisdictions where our affiliates, partners, or service providers operate. These countries may have data protection laws that differ from those in your country and may not provide the same level of protection. Nevertheless, we take appropriate legal, technical, and organizational measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected in accordance with the principles outlined in this Privacy Policy. Where required by law, such transfers are based on safeguards such as adequacy decisions of the European Commission, Standard Contractual Clauses, or your explicit consent. We are committed to ensuring a high standard of data protection and privacy regardless of where your information is processed.

11. DATA SUBJECT RIGHTS – EUROPEAN UNION AND UNITED STATES RESIDENTS
If you are a resident of the European Union, you have the right under applicable data protection laws, including the General Data Protection Regulation (GDPR), to request access to your Personal Data, as well as to request its rectification, erasure, restriction of processing, or portability. You also have the right to object to the processing of your data where such processing is based on our legitimate interests, and you may withdraw your consent at any time if processing is based on consent.
We process your Personal Data primarily to perform our contractual obligations to you (e.g., when you subscribe to the Services), and additionally where it is necessary for compliance with legal obligations or for purposes of our legitimate business interests, such as service improvement, technical support, or legal protection.
If you are a resident of the United States, you may at any time opt out of receiving marketing communications from us by clicking the unsubscribe link included in our emails or by sending a request to info@finglobal.ai. Please note that even if you opt out of marketing, we may still send you service-related communications that are necessary for your use of the Services.

12. CHANGES TO THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time to reflect changes in legal, regulatory, or operational requirements, or to update our data practices. Any modifications will take effect upon publication of the updated version on the Site, unless otherwise specified. The "Last Updated" date at the top of this document will indicate the date of the latest revision. We may, but are not obliged to, notify you separately of material changes by email or through your user account. By continuing to use the Site or participate in the Services after such updates are published, you acknowledge and accept the revised terms. If you do not agree to any changes, you must cease use of the Site and Services. If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your Personal Data, you may contact us using the information below:

FINGLOBAL LLC
EIN 39-5056007
Address: 418 Broadway, Ste N, Albany, NY 12207, USA
Email: info@finglobal.ai