Effective Date: 6/21/2018

This Privacy Policy discloses the privacy practices of Financial Partners Group in connection with FinancialPartnersGroup.com website and any features and online services provided by Financial Partners Group that post or include a link to this Privacy Policy (collectively, the “Services”). We have provided this statement of our Privacy Policy to answer your questions about the types of information that we gather, the ways in which we use and share this information, and your rights and choices regarding such information.

Please read this Privacy Policy carefully. By visiting and using the Services, you agree that your use of the Services is governed by this Privacy Policy. In addition to our Privacy Policy, your use of the Services is governed by our Terms of Use, which govern in the event of any conflict with this Privacy Policy.

1. SCOPE OF PRIVACY POLICY

This Privacy Policy applies to FinancialPartnersGroup.com website and any features and online services provided by Financial Partners Group that post or include a link to this Privacy Policy. It does not apply to Financial Partners Group services that Financial Partners Group customers may use on their own websites, to other companies’ or organizations’ sites to which we link, or to companies that Financial Partners Group does not own or control, even if such companies are contractors or business partners of Financial Partners Group.

This Privacy Policy also does not cover how Financial Partners Group customers may treat your information as the use of your information by such parties is governed by the privacy policies of such parties and is not subject to Financial Partners Group control. If you are a data subject located in Europe, please see the section below entitled “Data Controller” for more information on our relationship with our customers.

2. INFORMATION Financial Partners Group COLLECTS
   Information You Provide

We collect information that you voluntarily provide to us while using the Services, such as when you register an account, make a purchase of one of our products or services, respond to our customer surveys, communicate with our customer service team, or apply for a job.

The information we collect includes information relating to identified or identifiable natural persons. Some examples of information we collect include the following: contact data, including your first and last name, telephone number, email address, and postal address; and billing information; credentials, including your passwords; content data, including the content of the messages you send to us; and resume data, including data necessary to consider you for a job opening (such as your employment history, writing samples, and references). We also use third party payment processes to collect and process payment data, including your payment instrument and security code associated with your payment instrument, on our behalf.

You may choose to voluntarily submit other information to us through the Services that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically

We automatically collect information about your device and how your device interacts with our Service. The types of data we collect and the methods by which we may collect such data include the following:

Cookies, Web Beacons, and Embedded Scripts

The Services use “cookies” and similar technologies, including HTML5 local storage. A cookie is a file stored on your device that may be used to identify an individual as a unique user by storing certain personal preferences and user data. Financial Partners Group uses cookies and other technologies to identify your device, identify authorized users of the Financial Partners Group Account Portal, track affiliate referrals, complete online purchases through Financial Partners Groupshopping carts, and similar Services monitoring activities.

Financial Partners Group may also use web beacons, small graphic images or other web programming code (also known as “1×1 GIFs” or “clear GIFs”), which may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Financial Partners Group may also use embedded scripts in connection with the provision of its Services. “Embedded scripts” are programming code designed to collect information about your interactions with a website, such as the links you click on, and may assist our customers in providing us with information used to provide the Services. The code is temporarily downloaded onto your device from our web server, our customer’s web server, or a third party service provider, is active only while you are connected to the website containing the embedded script, and is deactivated or deleted thereafter.

Log File Information

Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on the Services, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.

User Agent Strings

Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications, such as the operating system and browser you used. A user agent string might be used to identify the device originating a message.

Location Data

Financial Partners Group may also request access to or otherwise receive information about your device location when you access the Services. Your location data may be based on your IP address and other location-aware technologies. We use location data in connection with providing the Services and to help improve the Services.

Unique Identification Number

Financial Partners Group may assign your computer or mobile device a unique identification number (“Unique ID”) based on log file information when you access the Services. Financial Partners Group may set a cookie on your device containing, amongst other things, the device’s Unique ID. Financial Partners Group uses information generated from the Unique ID for purposes of improving our Services, primarily our ability to detect fraud. Financial Partners Group does not share the Unique ID or any associated data with unaffiliated third parties in the traditional sense of sharing. However, some of the services offered by Financial Partners Group, including some that are available through the Services, may require the placement of a snippet of JavaScript on the customer’s own website (either by the customer itself or by Financial Partners Group), and that JavaScript collects the information used by Financial Partners Group to create the Unique ID. If the customer uses the Financial Partners Group minFraud service, it may receive back the Unique ID Financial Partners Group associated with the IP address being used in the request made to the minFraud service.

Information Financial Partners Group Receives from Third Parties

Financial Partners Group receives information about you from third parties. We may combine the information we receive from third parties with information we collect through the Services. If we do so, Financial Partners Group will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included: our business partners and resellers; our customers; and publicly available sources such as open government databases or other data in the public domain. For example, our customers provide us with certain e-commerce transaction information, including IP address, cardholder name, billing and shipping address, email, and phone number.

3. How Financial Partners Group Uses Information

We use information for our legitimate interests, including for the following purposes:

Providing Our Services

As stated above, Financial Partners Group uses information such as your first and last name, telephone number, email address, postal address, billing information, or other contact information we obtain from you, our customers, or our business partners, for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, databases, and other services and products.

Communications with You

Financial Partners Group maintains one or more contact lists (with email addresses and other information) to allow Financial Partners Group to communicate with individuals who do business with Financial Partners Group or who have expressed an interest in the Services. We may contact you to confirm your purchases or respond to requests that you make, notify you of changes to your account or the Services, for marketing purposes, or to otherwise inform you of information related to our business or your account with us.

Website Administration and Customization

Financial Partners Group uses the information we collect about you for a variety of website administration and customization purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customize features and advertising that appear on and off the Services, deliver the Services content to you, measure Services traffic, measure user interests and traffic patterns, and improve the Services.

Usage of IP Addresses

The Financial Partners Group services, including the minFraud service, use IP addresses to help organizations detect and prevent fraudulent activity. Among other things, Financial Partners Group obtains IP addresses and order information (including customer name and billing address) through its minFraud service. Financial Partners Group uses the billing location from this data along with other data to create databases that pair IP addresses with the locations in which they are likely being used, down to a postal code level of resolution.

Consent

We also use information with your consent, including for the following purposes: to allow you to participate in our surveys; to serve advertising tailored to your interests on our Services and third party services; and to fulfill any other purpose disclosed to you and with your consent.

Some of our lawful bases for processing your information stem from our customers on whose behalf we provide services.

Financial Partners Group uses information that does not identify you for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see Section 6 below.

4. How Financial Partners Group Shares Information

Sharing with Our Service Providers

We provide your information to our third party service providers, contractors, business partners, and advertisers, for the purpose of delivering services to you as well as for purposes related to Services administration and operation, including conducting analytics. When sharing information for the purpose of providing you with the services you request, we will share your information only as necessary for the third party working on How Financial Partners Group Shares Information behalf to complete its work for us. For example, if you use a credit or debit card to complete a transaction on the Services, we will share your credit or debit card number with a payment processing and/or a fulfillment company in order to complete your transaction.

Sharing of Databases

One aspect of How Financial Partners Group Shares Information products and services is the provision of databases to our customers and other third parties, including our business partners and resellers. These databases include information such as IP addresses and corresponding data pertaining to such IP addresses, such as geolocation data, fraud analysis data, and related information. Such databases are compiled using numerous data sources, including information we receive from our customers when individuals make purchases or conduct other transactions with our customers. In addition, we respond to API queries from our customers, and such responses may include information about the level of risk we associate with information about your device or email address, or your Unique ID. By following the directions set forth in Section 6 below, you may opt out of us disclosing the information we have about you in our databases. Data subjects located in Europe have additional rights, as explained in Section 6 of this Privacy Policy.

Customers

We share your information with our customers in connection with us processing your information on their behalf. For example, we share your information with our customers to respond to your questions and comments, fulfill your requests, and otherwise comply with applicable law.

Third Parties

We may share your information with third parties for purposes of providing you with tailored advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.

Security and Compliance with the Law

We reserve the right to disclose your information to appropriate third parties if we are required to do so by law or we believe that such action is necessary in order (a) to comply with a legal process such as a search warrant, subpoena, or court order; (b) to protect the company’s rights and property; (c) to investigate reports of users sending material using a false email address or users sending harassing, threatening, or abusive messages; (d) to protect against misuse or unauthorized use of the Website or Services; or (e) to respond to emergencies, such as when we believe someone’s physical safety is at risk. How Financial Partners Group Shares Information may be required to disclose information in a life-threatening emergency or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Transfer of Business

Over time, Financial Partners Group may buy or sell various assets. In the event that we sell some or all of our assets, or our company is acquired by another company, or during the negotiation of such sale or acquisition, our databases and any information we collect may be among the transferred or negotiated assets.

Consent

We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, Financial Partners Group shares information that does not identify you with third parties, including our customers, for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see Section 6 below.

5. THIRD PARTY ANALYTICS; ONLINE TRACKING

Financial Partners Group works with certain third parties (including analytics companies) to provide us with information regarding traffic on and use of the Services. Some of these parties collect information when you visit the Services or other online websites and services. These third parties set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your IP address or other unique identifier, log information, and related information about you. These tracking technologies, including the Google Analytics User ID feature, may be used to assist in providing analytics, marketing, and for other purposes. Financial Partners Group does not control the information collection, use, or sharing practices of such third party providers, and we encourage you to consult their online policies. Some third parties may collect information about your online activities over time and across different websites when you use the Services.

6. YOUR RIGHTS AND CHOICES

Opt-Out of Email Communications

If you are a registered member of the Services, you can make changes to your account information by logging into the Website and modifying your preferences. If you do not wish to receive email notifications from us, you may opt-out by contacting us with your request. In addition, certain email communications we send to you, such as newsletters and promotional announcements, contain a clearly worded “Opt-Out” or “Unsubscribe” link allowing you to withdraw your permission for future mailings. Please note that we reserve the right to send you certain communications relating to your account or use of the Services (for example, administrative and service announcements) and these transactional account messages may be unaffected even if you opt-out from marketing communications.

Opt-Out of Database Sharing

As discussed above in Section 4 of this Privacy Policy, Financial Partners Group may share information we have about you in our databases with our customers and third parties (including but not limited to IP geolocation data we make available through the Services). If you want to opt-out of Financial Partners Group sharing your database information with our customers and third parties, please send your request the address set forth in Section 12, below. This opt-out has several important qualifications:

(a) You will only be able to opt-out to the extent that we can identify information we have about you. It is possible that even after you opt-out our databases will contain some residual information about you.

(b) Financial Partners Group will cease sharing your information in any databases created after your opt-out date. Our customers may continue to have access to legacy database information.

(c) Even if you do opt-out of having us share the information we have about you in our databases, Financial Partners Group must continue to gather, retain, use, and share such information for fraud detection purposes. This is because your IP address may be associated with information that we have received from numerous customers.

(d) If you opt-out based on your IP address, Financial Partners Group will process the opt-out only if the IP address is associated with a single individual or household. Many IP addresses are shared by several if not hundreds of devices, and Financial Partners Groupcannot process an opt-out for sharing for such IP addresses. Further, since some IP address assignments are subject to change or are dynamic, Financial Partners Group will only process an opt-out for sharing of information related to such an IP address until such time that Financial Partners Group reasonably believes the IP address has been assigned to another device (however, in no event will Financial Partners Group remove such an opt out in a time period of less than one year).

Data subjects in Europe have additional rights as set forth in the section entitled “European Privacy Rights” below.

Blocking or Deleting Cookies

You can manually delete cookies, which are normally located in your temporary Internet folder or cookie folder. You can also reset the preferences in your web browser to notify you when you have received a cookie or, alternatively, to refuse to accept cookies. Deleting or blocking cookies will prohibit your ability to make online purchases on the Services and to use and access portions of the Services that require logging in with a username and password, and may affect other functionality.

Analytics and Advertising

You may exercise choice regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about the DAA and how you can exercise certain choices regarding interest-based advertising, visit https://www.aboutads.info/choices. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see https://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Financial Partners Group is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit; however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Website currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit https://www.allaboutdnt.com.

Your California Privacy Rights

California’s “Shine the Light” law permits customers in California to request certain details about how a business shares their personal information as defined by “Shine the Light” with third parties (and in some cases affiliates) for those third parties’ or affiliates’ own direct marketing purposes.

We do not share personal information as defined under California’s “Shine the Light” law with third parties or affiliates for those third parties’ or affiliates’ direct marketing purposes. California customers may request information about our compliance with this law by contacting us by e-mail or by mail at the address set forth in Section 11 below. Any such inquiry must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email or mail address.

To exercise any of these rights, contact us using the information at Section 11 below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfilL the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

7. SECURITY

Financial Partners Group implements reasonable administrative, physical, and technical security measures to help protect your data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. Financial Partners Group cannot guarantee the security of the Service’s servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

8. POLICY REGARDING CHILDREN

The Services are not intended for use by children under the age of thirteen years old. Financial Partners Groupdoes not knowingly collect information from children under the age of thirteen. If you are a parent or guardian, and believe we have collected information about your child in violation of this policy, please contact us at the address set forth in Section 12 below.

9. CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy in response to changing business circumstances and legal developments. If there are material changes to this Privacy Policy or in how we use your information, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this Privacy Policy to be informed of how we are collecting and using your information.

10. DATA CONTROLLER

EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

If you are a data subject located in Europe and want to learn more about how to exercise your rights, please see the section above entitled “European Privacy Rights”.

11. CONTACT FOR ADDITIONAL INFORMATION, OPTING OUT, DATA ACCESS AND CORRECTION, AND DISPUTES

If you have any questions or complaints about this Privacy Policy, or you wish to exercise your opt-out rights hereunder or access or correct data applicable to you, please contact us:

By email:

sales@financialpc.com

By mail:

Financial Partners Group

65 Mechanic Street, Suite 207

Red Bank, NJ

U.S.A.