Privacy Policy

Introduction

[Last updated 23 November 2023]

finova takes its data privacy responsibilities seriously. We respect privacy rights and are committed to managing personal data in a professional, lawful and ethical way.

Personal information is information that can be used to identify an individual either directly or indirectly. This privacy statement explains the types of personal information we process about our business contacts (including visitors to our websites, prospects, customers, partners and service providers), how we use it and the rights that individual shave. It applies to our activities involving personal information about our business contacts, including personal information we collect via our websites and personal information we collect, use and create as part of running and growing the finova business. In certain circumstances, we may provide additional information to supplement this privacy statement (e.g. at the point of collecting information from you or otherwise interacting with you).

For more information in relation to any specific sections in this privacy statement, please click on the relevant links below.

• Who we are
• What personal information do we have and who provides it?
• How do we use personal information?
• Who do we share personal information with?
• Which countries is personal information shared to?
• How long do we keep personal information?
• Additional information on data retention
• What personal information rights may be available?
• Your legal rights
• Cookies and personal advertising
• How to contact the appropriate authority
• Contact us
• Data protection officer
• Changes to our Privacy Statement

If you have any queries regarding this privacy statement or finova’s use of your personal information, please contact privacy@finova.tech.

Who we are

“finova” is a trading name used by the following private limited companies:

• DPR Group Limited, registration number 04438029;
• DPR Consulting Limited, registration number 03178610;
• eKeeper Group Limited, registration number 05144521;
• Burrow Mortgages Limited, registration number 11362212;
• MCI Club Limited, registration number 09204126;
• BEP Systems Limited, registration number 06717822 and
• Spectrum Data Management Limited, registration number 05821010; and
• Finova Technologies Private Limited (finova’s India entity).

This privacy statement is issued on behalf of finova (meaning all of the companies listed above) so when we mention “finova”, “we”, “us” or “our” in this privacy statement, we are referring to the relevant company who is responsible for processing your data.

What personal information do we have and who provides it?

We collect personal information directly from you/individuals, including the type of information included in work email footers and on business cards(e.g. name, work email address, job information, work phone number and work address collected when you get in touch with us, download a document or register for an account) and technical information arising from your interactions with our websites.

We use publicly available information and service providers to provide us with business contact details for businesses and people that we think may be interested in our solutions (“prospects”). We also obtain business contact details from finova affiliates, customers, partners, service providers and those organising or hosting events that we participate in.

The categories of personal information that we have, and the sources of that information are summarized below.

When collecting personal information via forms on our website, we indicate whether it is mandatory for you to provide the information. If it is mandatory to provide personal information (e.g., to register for an account or obtain access to restricted content), you will not be able to complete the request or access the information unless you provide the information to us.

The categories of personal information that we have, and the sources of that information are summarised below.

Business contact details (including professional or employment-related information)

Examples of personal information in this category:

• Name, email address, job information, organisation, phone number and address

Who may provide the personal information to us (categories of sources)?  

• You/individual
• An organisation/group/network or academic institution you have a role with (e.g., a customer, partner or supplier)
• Industry bodies you are associated with
• finova affiliates
• Partners (e.g., distribution partners and/or technology partners providing information about customers and prospects)
• Customers
• Event organisers/hosts (e.g., about people attending an event finova is involved with)
• Service providers including business to business lead generation service providers (e.g., business contact information for prospects and customers)
• Publicly available information (e.g., from internet searches and social networks)

Online and other identifiers

Examples of personal information in this category:

• Username, unique account/user identifier

Who may provide the personal information to us (categories of sources)?  

• You/individual
• Created by us (e.g., unique identifier generated when you register for an account with one of our services)

Images, videos, audio files

Examples of personal information in this category:

• Photograph voluntarily uploaded to finova account profile, video conferencing and recording, filming and photography at events

Who may provide the personal information to us (categories of sources)?  

• You/individual

Interests, activity and preference details

Examples of personal information in this category:

• Registrations for events, downloads of content, information about interaction with our websites, solutions or adverts, query logs, usage logs and inferences drawn from this information to determine interest in our solutions

Who may provide the personal information to us (categories of sources)?  

• You/individual (e.g. by interacting with finova websites, communications, solutions)
• finova affiliates
• Event organisers/hosts (e.g. about people attending an event finova is involved with)

• Advertising and social networks (e.g. LinkedIn) and marketing agencies
• Publicly available information (e.g. from internet searches)

Customer relationship management information, commercial and contractual details

Examples of personal information in this category:

• Records of business contacts that purchase or are interested in our solutions, billing/payment contacts and details (we do not collect or process credit or debit card details), contract signatories

Who may provide the personal information to us (categories of sources)?  

• You/individual
• Organisation/group/network you have a role with (e.g. a customer, partner or supplier)

Correspondence and content

Examples of personal information in this category:

• Any personal information included in communications with us (including audio, electronic, and visual information) and content on websites and forums (e.g. feedback, ideas, suggestions, or commentary on websites and forums provided by us)

Who may provide the personal information to us (categories of sources)?  

• You/individual
• Users of the online services

Training and certification details

Examples of personal information in this category:

• Training issued, date issued, progress, performance completion date, qualifications / certifications achieved

Who may provide the personal information to us (categories of sources)?  

• You/individual

Survey, feedback and customer satisfaction details

Examples of personal information in this category:

• Feedback, ratings, survey responses

Who may provide the personal information to us (categories of sources)?  

• You/individual directly
• Organisation/group/network or academic institution you have a role with (e.g. a customer, partner or supplier)
• Partners
• Customers
• Training participants

Internet, device and technical details

Examples of personal information in this category:

• IP address, device model, the type of browser being used

Who may provide the personal information to us (categories of sources)?  

• You/individual

Security and log-in details

Examples of personal information in this category:

• Username, password, security questions, security logs

Who may provide the personal information to us (categories of sources)?  

• You/individual

Job application information

Examples of personal information in this category:

• Name, email address, job information, organisation, phone number and address

Who may provide the personal information to us (categories of sources)?  

• You/individual
• Employment agency
• Social networks (e.g., LinkedIn)

How do we use personal information?

finova may use the personal information that we collect on you in the following circumstances:

• where it is necessary for our legitimate interests or the legitimate interests of a third party and your interests and fundamental rights do not override those interests.
• to perform the contract we are about to enter into or have entered into with you, including notification of changes to our products and services.
• where we need to comply with a legal obligation.
• to provide you with information, products or services that you request from us, or which finova feel may interest you, where you have consented to be contacted for such purposes.
• to allow you to participate in interactive features of our products or service, when you choose to do so.
• to evaluate your suitability and candidacy for employment or other engagement by or with finova.

More details about our reasons for collecting, creating and using personal information (i.e. the purposes for which we do so) and legal basis for our activities are described below. Our lawful basis for collecting and using personal data will depend on the data concerned and the context in which we collect it.

In most circumstances, we will collect and process personal data because it is in our legitimate interest to do so. In some circumstances, your personal data may also be collected and processed with your consent, or to comply with our legal obligations.

Where we have identified ‘legitimate interest’ as our lawful basis for processing personal data we have also provided the legitimate interests that are appropriate to that processing.

Purpose: To grow the finova business

• Activity: Researching prospects using publicly available information (e.g. from internet searches and social networks) and information obtained from service providers (e.g. business to business lead generation service providers).
• Legal basis: Legitimate interest to grow the finova business.
  

• Activity: Marketing to business contacts, mostly via email and telephone calls.
• Legal basis: Legitimate interest to grow the finova business. Consent if it is required.
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• Activity: Running and participating in events, including webinars, podcasts, in person events and trade shows and other activities, such as advertising, to promote and raise awareness of finova.
• Legal basis: Legitimate interest to grow the finova business.
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• Activity: Maintaining and developing our relationship with business contacts and communicating regarding potentially relevant opportunities.
• Legal basis: Legitimate interest to grow the finova business.
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• Activity: Carrying out surveys and asking for feedback.
• Legal basis: Legitimate interest to grow the finova business.
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• Activity: Improving and developing new websites, content, training and solutions. Where proportionate, we take steps to de-identify data before using it for these purposes and look for ways to minimise the privacy impact on individuals.
• Legal basis: Legitimate interest to grow the finova business. Consent if it is required (where finova uses cookies).
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• Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
• Legal basis: Legitimate interest to grow the finova businesses (to define types of customers for our products and services, to keep our website updated and relevant, to develop the services we offer to customers to enable us to provide the best customer journey and to inform our marketing strategy).
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• Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
• Legal basis: Legitimate interest to grow the finova businesses (to study how customers use our products/services, to develop the services, to grow our business and to inform our marketing strategy).
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• Activity: For recruitment processing and prospective candidate assessment.
• Legal basis: Legitimate interest to grow the finova business (to ensure an applicant’s suitability for a role).
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• Activity: To contact you and send direct marketing communications via email or telephone about our services and product range and current and future job openings.
• Legal basis: Legitimate interest to grow the finova business (where Business to Business Direct Marketing is permissible under the lawful basis of legitimate interests). Consent (we will seek consent to contact you about current and future job opportunities if you apply to a position at finova. More information will be contained within the consent form should we seek this. Please note that all Data Subjects have the right to opt out of Marketing communication and it is not necessary for you to consent to contacting you about current and future job openings for the purpose of your original job application. Where you do consent to your information being held for this purpose, finova will retain your data for up to 6 months, whereupon we shall seek your consent to hold it for a further 6 months or it shall be deleted within 14 days where you do not consent – consent will not be implied it needs to be an affirmative action by you).
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Purpose: To run the finova business

• Activity: To register you as a customer or account holder.
• Legal basis: Necessary for our legitimate interests to run the finova business.
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• Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.)
• Legal basis: Performance of a contract with you. Necessary for our legitimate interests to run the finova business. Necessary to comply with a legal obligation.
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• Activity: Negotiation and performance of contracts, including providing our solutions, support and maintenance and billing and invoicing.
• Legal basis: Processing necessary to perform our contract with you. Legitimate interest to run the finova business.
  

• Activity: Sending service and transactional communications and responding to inquiries and requests.
• Legal basis: Processing necessary to perform our contract with you. Legitimate interest to run the finova business.
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• Activity: Management forecasting and planning, including analysis of sales pipeline.
• Legal basis: Legitimate interest to run the finova business.
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• Activity: Providing training, exams and/or certifications and related support and mentoring.
• Legal basis: Processing necessary to perform our contract with you. Legitimate interest to run the finova business.
  

• Activity: Preventing, detecting and remediating any security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking action, as appropriate, against those responsible.
• Legal basis: Legitimate interest to run the finova business.
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• Activity: Providing our websites, related support and maintenance (e.g. debugging software to identify and repair errors that impair functionality).
• Legal basis: Processing necessary to perform our contract with you. Legitimate interest to run the finova business.
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• Activity: Allow you to access our finova Guest Wi-Fi service.
• Legal basis: Processing necessary to perform our contract with you. Legitimate interest to run the finova business.
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• Activity: Monitoring and auditing (e.g. to assess and verify quality of our solutions and training, compliance with applicable laws, regulations, contractual obligations, policies and procedures).
• Legal basis: Legal obligation. Legitimate interest to run the finova business.
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• Activity: Complying with legal, tax, accounting, and other regulatory or reporting obligations.
• Legal basis: Legal obligation. Legitimate interest to run the finova business.
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• Activity: To assert or defend against legal claims or to enable us to enforce or exercise our rights.
• Legal basis: Legitimate interest to run the finova business.
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• Activity: Other business activities involving processing of personal information in order to run the finova business (e.g. obtaining professional advice).
• Legal basis: Legitimate interest to run the finova business.
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Who do we share personal information with?

We share personal information with our affiliates, customers, partners, event sponsors and organisers, service providers (including IT providers, auditors and professional advisers) as part of running and growing our business. If a regulator, government or law enforcement authority asks for personal information, we will provide the information that we are legally required or permitted to provide. We do not sell personal information.

The below includes information about the categories of recipients (which may include third parties) that may receive personal information from us and the categories of personal information they may receive.

finova affiliates

Categories of personal information we may share:

• Business contact details
• Online and other identifiers
• Interests, activity and preference details
• Customer relationship management information, commercial and contractual details
• Correspondence and content
• Training and certification details
• Survey, feedback and customer satisfaction details
• Internet, device and technical details
• Security and log-in details

Organisation/group/network or academic institution you have a role with and/or their related entities/bodies

Categories of personal information we may share:

• Business contact details
• Interests, activity and preference details

• Customer relationship management information, commercial and contractual details
• Correspondence and content
• Training and certification details
• Survey, feedback and customer satisfaction details

Customers

Categories of personal information we may share:

• Business contact details
• Customer relationship management information, commercial and contractual details
• Correspondence and content
• Training and certification details
• Survey, feedback and customer satisfaction details

Partners

Categories of personal information we may share:

• Business contact details
• Customer relationship management information, commercial and contractual details
• Correspondence and content
• Training and certification details
• Survey, feedback and customer satisfaction details

Users of the online services

Categories of personal information we may share:

• Business contact details
• Correspondence and content

Regulators, government, law enforcement authorities, courts or other third party to assert or defend against legal claims or to enable us to enforce or exercise our rights

Categories of personal information we may share:

• Any of the categories of personal information included in the section “What personal information do we have and who provides it?”  may be shared in order to respond to a request or to assert or defend against legal claims or to enable us to enforce or exercise our rights

Service providers, including: auditors, cloud, IT and SaaS providers, consultants, event organisers, banks, insurers and professional advisers

Categories of personal information we may share:

• Business contact details
• Online and other identifiers
• Interests, activity and preference details
• Customer relationship management information, commercial and contractual details
• Correspondence and content
• Training and certification details
• Survey, feedback and customer satisfaction details
• Internet, device and technical details

• Security and log-in details
• Employment history

Event sponsors (e.g. information about people attending the event being sponsored)

Categories of personal information we may share:

• Business contact details
• Correspondence and content
• Interests, activity and preference details
• Survey, feedback and customer satisfaction details

Third parties as permitted in the section titled “Cookies and Personal Advertising”, including advertising and social networks

Categories of personal information we may share:

• Online and other identifiers
• Interests, activity and preference details
• Internet, device and technical details

See the section titled “Cookies and Personal Advertising” for more details.

Third parties in connection with corporate transactions relating to our business (e.g. potential transaction counterparties, their agents and advisers)

Categories of personal information we may share:

• Any of the categories of personal information included in the section “What personal information do we have and who provides it?” may be shared as reasonably necessary in relation to a proposed purchase, merger or acquisition of any part of our business subject to confidentiality obligations and limits on the use of the personal information for the purposes of the transaction

Other category of recipient/third party included in a separate privacy notice provided to you covering a specific activity

Categories of personal information we may share:

• Any of the categories of personal information included in the section “What personal information do we have and who provides it?” may be shared as described in the separate privacy notice provided
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Which countries is personal information transferred to?

finova may transfer your information outside the UK and EEA for the purpose of growing and running the finova business (e.g. to provide technical support to you in respect of our solutions). Where personal data is transferred overseas, we ensure that the necessary safeguards are in place, for example:

• the European Commission has determined that the destinationcountry offers an adequate level of data protection; or
• the European Commission’s Standard Contractual Clauses (“EUSCCs”); and

the UK Addendum to the EU SCCs, where making transfers outside of the EEA from the UK. Your personal data may also be transferred between the affiliates of finova. Where finova transfers your personal data between its affiliates internationally, finova ensures that the necessary safeguards are in place.

finova places substantial importance on protecting the confidentiality, integrity and security of the personal information it processes and seeks the cooperation of all its suppliers in furthering this goal.

If you have questions or need further information about international data transfers, please email privacy@finova.tech.

How long do we keep personal information?

We keep personal data for as long as is necessary to:

• comply with our legal, tax, accounting, and other regulatory or reporting obligations or to assert or defend against legal claims or to enable us to enforce or exercise our rights;
• to fulfil the purposes for we collected it for; (i) to provide our solutions, and (ii) to run and grow our business (please see the section “How do we use personal information?” for more information).

If you would like to find out more about our retention periods for specific categories of personal information, please email privacy@finova.tech.

Additional information on data retention:

When determining the retention period for personal information, we consider the applicable legal, tax, accounting, and other regulatory or reporting requirements, the purposes for which we process the personal information, the type of personal information (the nature and sensitivity of the personal information) and the potential risk of harm from unauthorized use or disclosure.

If you ask us to delete personal information, object to our processing based on legitimate interests or withdraw consent, where our use of personal information is based on consent, we will delete personal information as appropriate in response to your request. Please see the section “What personal information rights may be available?” for more information.

Where we de-identify personal information so it is no longer reasonably likely to identify an individual (e.g. in order to use it to analyse, improve and develop our business and solutions) we may keep the information indefinitely.

We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

What personal information rights may be available?

You have certain rights to know and control how information about you is collected and used. You can also complain about how your personal information has been handled by us. You will not receive discriminatory treatment if you exercise your rights or raise a concern. We prefer that you let us know about a concern so that we can look into it for you.

Information about the rights that may be available when an organisation processes personal information is set out below.

When processing customer data in the course of providing our solutions, finova acts on the instructions provided by its customer. If you would like to know more about a customer’s processing of personal information using finova solutions, please contact the relevant customer directly. For any questions or concerns about our privacy practices or to submit a request to us, please email privacy@finova.tech or follow any specific instructions below.

Before we provide you with information or delete information in response to a request, we will ask you to provide evidence of your identity so that we can verify that it is a genuine request (e.g. a recognised identification document or information about your account). An authorised agent can make a request to exercise your rights on your behalf by submitting a request to privacy@finova.tech with a signed authorisation, which we may contact you to verify.

Your legal rights:

Know and access – the right to obtain a copy of the information we hold about you.

Individuals have aright to request information about what personal information an organisation processes (which includes collecting, using, disclosing or selling of personal information) and ask for a copy of the personal information that relates to them.We do not sell personal information.

Rectification – the right to correct any inaccurate information we hold about you.

Individual scan ask to have any inaccurate personal information corrected. You can update and correct your finova account information by logging in to your account.

Deletion – the right to have your personal information erased where there is no longer justification.

Individual scan ask an organisation to delete their personal information. We will delete personal information in response to a request only if it is not personal information that we are processing on behalf of a customer and we have no statutory obligation or overriding right to retain it. In some cases, fulling a request to delete personal information will mean that the individual can no longer use our solutions that require personal information.

Restrict – the right to restrict the processing of your personal data in certain circumstances.

Where you have concerns about the accuracy of personal information or how it is being used, you can ask an organisation to limit its use of your personal information.

Stop marketing and/or object to processing.

You have the right to object to processing that is based on legitimate interests and to stop receiving marketing communications from us. You can ask us to stop marketing by clicking on the unsubscribe link in the relevant marketing email from us or by contacting us using the contact details provided below.

Portability – the right to obtain and reuse your personal information for your own purposes.

If the legal basis for processing personal information is consent or contract and the right is being carried out by automated means (i.e. excluding paper files), you have the right to obtain a copy of the relevant personal information in a commonly-used format or ask that it is provided to another organisation if technically feasible.

Please note this right will only applyinsofar as you have provided personal information to finova where it is actingas a controller (e.g. where applying for an open job application).

Withdraw consent – the right to withdraw consent to the processing of your information.

If consent is the legal basis for processing personal information, you have the right to withdraw consent at any time and free of charge, by contacting us via the contact information provided below. To withdraw consent to our use of cookies, please use the cookie settings tool that we provide at the bottom left corner of each page on our website.

Complaints – the right to lodge a complaint about the handling of your personal information.

If you would like to make a complaint about our use of your personal information please send details of your complaint, including the personal information it relates to, to privacy@finova.tech. We will investigate your complaint and respond as soon as we can, and within any statutory timeframes. If you are not satisfied with our response, you have the right to complain to a data protection authority about out collection and use of personal information. The UK data protection authority is the Information Commissioner’s Office (www.ico.org.uk) or you may contact your local data protection authority.

Please see section “How to contact the appropriate authority” for further information.

No discrimination – the right not to be discriminated for exercising your rights.

Some data privacy laws include a right not to receive discriminatory treatment for the exercise of your privacy rights and we take this approach with all the requests we receive.

Cookies and Personal Advertising

finova uses cookies and similar technologies to collect information about your use of our websites and some of our solutions to help create reports and statistics on the performance of the website and solutions.

When you use our sites or apps, we may also use cookies or similar technology to collect extra data, including:

• your IP address - a numerical code to identify your device, together with the country, region or city where you are based
• your geolocation data - your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment
• information on how you interact with our services
• your browsing history of the content you have visited on oursites, including how you were referred to our sites via other websites
• details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content

We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that type of personal data to us.

You can withdraw your consent to us placing these cookies at anytime through our cookie settings link that is found in the bottom left corner of each page on our website.

For additional information on what cookies finova may set, please visit our Cookie Policy.

Google Analytics

Analytics cookies, such asGoogle Analytics, collect information such as your IP address, device type and operating system, referring URLs, location and pages visited. If you wish to opt-out of Google Analytics, you can install the ‘Google Analytics Opt-OutBrowser Add-On’, found at opt-out browser add-on from Google.

You can find out more about the data Google Analytics collects in their privacy statement.

Microsoft Clarity

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

How to contact the appropriate authority

Should you wish to report a complaint or if you believe that finova has not addressed your concern in a satisfactory manner, you have the right to contact the appropriate authority.

UK(subject to UK GDPR (Data Protection Act 2018)):

·      Individuals within the UK should contact the Information Commissioner’s Office:

·       https://ico.org.uk/global/contact-us/

·       Telephone number for general enquiries: 0303 123 1113

EU and the rest of the world:

·     Individuals within the EU and the rest of the world have theright to raise a complain with the supervisory authority in the Member Statewhere they live, where they work, or where the infringement took place.

Contact us

You can contact us about privacy matters by emailing legal@finova.tech  

Data Protection Officer

finova is headquartered in London, United Kingdom. finova has appointed an internal Data Protection Officer for you to contact if you have any questions or concerns about this policy or the way in which we are handling your data. The contact information for the finova Data Protection Officer is as follows:

Data ProtectionOfficer

finova
6th Floor, Commodity Quay
London
UnitedKingdom
E1W 1AZ

legal@finova.tech  

Changes to our Privacy Statement

finova reserves the right to amend this Privacy Statement at anytime, for any reason, without notice to you, other than the posting of the amended Privacy Statement on this site. You should our site to see the current Privacy Statement that is in effect and any changes that may have been made to it.