Last Updated 22/5/18
This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls.
Introduction and General Terms
In this Policy, the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Web browser cookies section below;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)|
|“We/Us/Our”||means Finder US|
Who are we?
finder.com is an information service that provides you with the tools and information you need to compare a wide range of products, providers and services. Our Site is owned and operated by Finder US, a limited company whose main trading address is Level 5, Suite 5a, 35 East Broadway, New York City, NY, USA 10002.
In order to provide you with information, tools and other services we may collect and retain “Personal Information” that may identify you or contribute to identifying you. “Personal Information” can include information such as your name, email address, your photo, contact details and, in some cases, general financial information. We will not collect your personal information unless it’s necessary to provide the information, advice or service you’ve requested and, where possible, you’ll be able to use our services anonymously.
We will generally only collect your personal information from you or from someone you’ve authorised to provide it to us. We will also only collect information by lawful and fair means and not in an unreasonably intrusive way.
EU members’ rights
If you are located in the European Union, as a data subject you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you;
- The right to rectification if any personal data We hold about you is inaccurate or incomplete;
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you;
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
When does finder collect information about me?
When you use our service (or while you’re accessing our services) we may collect personal information about you. Because we take your privacy seriously we will take reasonable steps to ensure that you are aware of:
- who we are and how you can contact us; and
- how you can gain access to the information we have collected about you; and
- the purposes for which the personal information is collected; and
- the organisations (or the types of organisations) to which we may disclose your personal information; and
- the laws that require us to collect this information; and
- the main consequences (if any) for you if you choose not to provide us with personal information about you.
We provide general advice and comparative information about a range of financial and credit products and can help you connect with businesses that provide relevant products and services. We are often required to collect some personal information to provide some services and, if you choose not to provide this information, then there is a chance that the information or advice you receive may not be suitable.
We prefer to collect personal information about an individual only from that individual but when you use our services you may provide us with personal information about someone else. We won’t ask you for personal information about someone else unless it’s needed to provide you with the service, advice or information you’ve requested but if you provide us with information about another person, you need to ensure that you are authorised to disclose that information to us. It’s your responsibility to ensure that they understand how we will collect, use or disclose the information you provide. You need to take reasonable steps to ensure that they understand that we will not take any additional steps to confirm their understanding of these issues.
What information will finder collect about me?
We collect different types of information from or through the Service. The legal bases for finder.com processing of personal data are primarily that the processing is necessary for providing the Service in accordance with our Terms of Service and that the processing is carried out in finder.com‘s legitimate interests, which are further explained in the section “How will finder use personal information about me?” of this Policy. We may also process data upon your consent, asking for it as appropriate.
- User-provided Information. When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with the Service through communication or messaging capabilities, or send us customer service -related requests.
- Automatically Collected Information. When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, pixels or web beacons. This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. We may also use these technologies to collect data on your interaction with our advertising and your interactions with finder.com‘s partners (conversion data). This information is gathered from all Users and Visitors.
- Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
How will finder use personal information about me?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the applicable legal requirements at all times. For more details on security see section ”Will finder share my personal information with anyone else?” below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- answering your general queries about financial products, credit products and related matters;
- confirming your identity;
- communicating with you;
- administering our services;
- notifying you of the services we offer;
- carrying out marketing, training or promotional activities;
- responding to feedback, comments, or any other contact;
- sending you email(s) or newsletters to which you have subscribed;
- carrying out competitions;
- enhancing our Site or Services;
- helping you to resolve technical issues with our site;
- helping you to identify products and product providers appropriate for your needs and circumstances;
- referring you to product providers;
- in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or
- in marketing, educative, relevant and promotional material (and then only with your express permission);
- where we provide personalised services, we may analyse the information you supply, as well as your activity on our (and other) services, so that we can offer a more relevant, tailored experience;
- providing and managing your account.
By using our services, you consent to us collecting, holding and using your personal information in this way.
We may also access, hold and use aggregated information about the people that use our services. Aggregated information won’t identify you or any other individual but simply provides us with non-personally identifiable data that we’ll use to improve our services, understand our users’ needs and develop tailored content. Although you would have provided us with the information we aggregate for these purposes, it won’t identify you or enable you to be personally identified.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
How long will finder.com keep my data?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with the finder.com. If you delete your finder account then your personal information is deleted immediately, and the remaining information is anonymised for analytical purposes. For further information about deleting your finder.comdata, please see section ”Can I find out what personal information finder.com keeps about me?” below.
Will I be contacted for marketing purposes?
With your permission and/or where permitted by law, finder.com may also use your data for marketing purposes which may include contacting you by email or text message or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the applicable legal requirements.
We may use information which we hold about you to show you relevant advertising on third party sites (e.g. Facebook, Google). This could involve showing you an advertising message where we know you have a finder account and have used finder services. If you don’t want to be shown targeted advertising messages from finder.com, some third party sites allow you to request not to see messages from specific advertisers on that site in future.
Will finder share my personal information with anyone else?
As a general principle, we won’t disclose your personal information without your express permission unless:
- we are required to do so by the law, to comply with our obligations or exercise our rights;
- it’s necessary to lessen or prevent a serious and imminent threat to a person’s health, life or safety;
- it’s required to facilitate a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or
- it’s necessary to lessen or prevent a threat to public health or public safety.
Generally, we will use your information within finder and will only share it outside finder where you have requested it or given your consent. However, we may share with the following entities:
- Third-party vendors who provide services or functions on our behalf, including business analytics, customer service, marketing, distribution of surveys, and fraud prevention. We may also authorise third-party partners to gather information on our behalf, including as necessary to operate features of our website. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
- Advertising partners. We share personal data with advertising partners, including your email address, as part of marketing of our services via third parties (to ensure that relevant advertisements are shown to the right audience). We strive to only share email addresses in hashed form to enable the matching of your email address with an existing customer database so that your email address cannot be used for other purposes.
We may share your information with third parties when we forward Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.
Protecting the privacy of children
We do not allow children under 16 years of age to become registered users nor will we knowingly collect or maintain information from them. If you identify or suspect that we have acted contrary to this policy, please alert us at firstname.lastname@example.org and ask for that information to either be deleted or secured.
How we maintain accurate information
Although we will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date, it is your responsibility to ensure that the information you provide to us is accurate, complete and current. You control the information you provide to us and you can correct or update any information you choose to provide to us. If you want us to correct our records simply tell us what needs to be changed and why.
How and where does finder.com keep my data?
finder.com is a global business. To offer our services, we may need to transfer your personal information among several locations, including Australia, where we are headquartered. Some of our product and service providers will process your data in other countries, however, we require all our partners to ensure that your data is kept securely at all times. If you choose to access the Site from the European Economic Area (“EEA”) or Switzerland, please understand that you will be transferring your information to the location other than in which the information was originally collected.
The information we collect is entered into our site by you, imported on your instruction and transmitted across the internet to our servers. By using our service, you are consenting to this process. The service providers who host our servers are not permitted to access your personal information except for the purposes of storing it. Although we will take reasonable steps to protect the information you provide to us, you should appreciate that the Internet itself is not secure and take care about the personal information that you transfer over the internet or by email.
In a limited number of circumstances we may use third party providers to facilitate surveys or mail outs on our behalf. Should this occur, we will only do so where the Service Provider:
- has committed to securing your personal information in a manner consistent with our policy; or
- neither holds, accesses, uses or retains the personal information other than as we have engaged them.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. We use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit score data. finder.com engages a company that is an industry leader in online security and verification to strengthen the security of our services. finder.com is registered with site identification authorities so that your browser can confirm finder.com‘s identity before any personally identifiable information is sent. In addition, our secure servers protect this information using advanced firewall technology.
What happens if your business changes hands?
In the event that any of your data is to be transferred in such a manner, you may be contacted in advance and informed of the changes. If contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
How can I control information about me?
When you submit personal data via finder.com, you may be given options to restrict Our use of your data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
The right to withhold information
You may access some areas of the site without providing any data at all. However, to use all features and functions available on Our Site you amy be required to submit or allow for the collection of certain data.
Can I find out what personal information finder.com keeps about me?
You have the right to request a copy of the personal information the finder.com holds about you (where such data is hold) and to have any inaccuracies corrected. We will not restrict your access to the information unless:
- providing access would pose a serious threat to someone’s life or health; or
- providing access would have an unreasonable impact upon someone else’s privacy; or
- the request for access is frivolous or vexatious; or
- the information relates to existing or anticipated legal proceedings between you and us;
- providing access would prejudice our negotiations; or
- providing access would be unlawful; or
- denying access is required or authorized by or under law; or
- providing access would be prejudicial or commercially sensitive.
If we can’t provide you with access to the information because of one or more of these reasons (which we will confirm in writing) we will consider reasonable alternatives that may satisfy all parties. You’ll generally be able to access your personal information without cost but, if we think a charge is reasonable it will not be excessive and will not apply to lodging a request for access.
We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you on our files. If you are within the European Economic Area (“the EEA”), where the The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein, please address requests and questions about this or any other question about this Privacy and Cookies Policy to the Global Data Protection Team, Finder AU, Level 10, 99 York St, Sydney, NSW, Australia 2000 or email email@example.com.
We will need two copies of forms of identification, which can be:
- Driving licence
- Birth certificate
- Utility bill (from last 3 months)
- Current vehicle registration document
- Bank statement (from last 3 months)
- Rent book (from last 3 months).
Where my personal information may end up?
Unless you choose to provide your personal information, or instruct us to do so, the personal information we hold will be secured on our servers and not be transferred elsewhere. There are some exceptions, but we won’t transfer personal information to a foreign country unless:
- We believe that the recipient of the information is subject to a law or arrangements that are substantially similar to our commitment; or
- you consent to the transfer; or
- the transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken in response to your request; or
- the transfer is necessary for the conclusion or performance of a contract concluded by you;
We will not transfer information contrary to this policy, without your consent or in a manner inconsistent with this policy.
Web browser cookies
What is a cookie?
A cookie is a small amount of data, often containing a unique identifier, sent to your computer or mobile device web browser from a website’s server and is kept on your device’s hard drive.
We use different types of cookies for different things, such as:
- Analysing how you use finder
- Giving you a better, more personalised experience
- Recognising when you’ve signed in.
First party cookies
Third party cookies
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on finder for adverting services or social media. For more details, please refer to How We Use Your Data?.
The following Cookies may be placed on your computer or device:
|Cookie||Name||Purpose||First or Third Party?||Cookie type||Manage preferences|
|These cookies allow us to collect information about website visitor interaction in order to optimise our pages.||First party||General service||n/a|
|These cookies allow us to collect information about website visitor interaction in order to optimise our pages.||First party||Performance||Learn more|
|These cookies allow us to track conversions on our partners’ websites.||Third party||General service||n/a|
|These cookies allow us to collect information about website visitor interaction in order to optimise our pages.||Third party||Performance||Learn more|
|Boomtrain||_bti||These cookies allow us to understand whether the email has been read or if any links have been clicked.||Third party||Performance||Learn more|
|These cookies are used to understand how users interact with the ads served on our site.||Third party||Targeting||Learn more|
|These cookies are used to understand how users interact with the ads served on our site.||Third party||Targeting||Learn more|
|Google Tag Manager||https://googletagservices.com||These cookies are used to manage third party tags on our site.||Third party||General service||Learn more|
|Google AdWords Conversion||
|These cookies are used to understand how effective our advertisement is.||Third party||Performance||Learn more|
|Google Adwords Remarketing||
|These cookies are used to deliver more targeted ads based on your interaction with the finder.com website.||Third party||Targeting||Learn more|
|NewRelic||JSESSIONID||Application monitoring.||Third party||Performance||Learn more|
|Third party||Performance||Learn more|
|Product analytics.||Third party||Performance||Learn more|
|Facebook Social Plugins||
|These cookies send data to Facebook when site with a social integration is visited.||Third party||Targeting||Learn more|
|These cookies send data to Facebook when site with a social integration is visited.||Third party||Targeting||Learn more|
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Other information collected from web browsers
Your web browser may also provide the finder with information about your device, such as an IP address and details about the browser that you are using. We use information provided by your browser or by the link that you have clicked to understand the webpage that directed you to finder and this may be captured by performance cookies.
DNT (Do Not Track) browser setting
DNT is a feature offered by some browsers, which, when enabled, sends a sends a signal to websites to request that your browsing is not tracked, such as by third party ad providers, social networks and analytic companies. This website does not currently respond to DNT requests.
Contacting finder about this Privacy and Cookies Policy
We believe in openness and we are committed to ensuring that we respect the privacy of those using the exceptional services we provide. If you want to arrange access to your information or have questions about privacy or the use of this site, please email firstname.lastname@example.org or by mail at 35 East Broadway, Suite 5a, New York, NY 10002.
If you are located in the EEA or Switzerland, finder.com might be the entity responsible for the processing of your personal information. If you are located in the EEA or Switzerland, you may e-mail us at email@example.com or write to us at:
The Global Data Protection Team
Level 10, 99 York St,
Sydney, NSW, Australia 2000
Changes to finder’s Privacy and Cookies Policy