Privacy Policy

Financial Integrity Network, LLC (“FIN”) operates at website https://dolfinapp.finintegrity.com/ (“Site“). We are data controller for this Site.

This Privacy Policy explains what personal data and information we collect when you visit our Site and how we use it and provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (“GDPR”) regarding the transparency of personal data processing. By using our Site and providing Personal Information to FIN, you agree to the collection and use of information in accordance with this Policy. This Privacy Policy should be read along with our Terms of Use, in order to ensure you understand and are comfortable with our use and disclosure of your Personal Information.

If you do not agree to any of the provisions of this Privacy Policy, you should not use the Site. If you have any questions or concerns about this Privacy Policy, you can contact us through dolfin@finintegrity.com.   

Personal Information FIN Collects. Personal Information” is information that identifies you as an individual.  FIN collects certain personal information — such as your first and last name, email address, state and country of residence, company’s name, type of institution, years of industry experience, and area of counter-illicit finance (CIF) that you work in — when you view and use our Site, create an account on our Site, and purchase subscription to DOLFIN™. FIN needs to collect this Personal Information to provide requested services and functionality to you. If you disclose any Personal Information relating to other people to us, to other members of FIN’s online Community, or to our service providers in connection with your use of the Site, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. You are under no statutory or contractual requirement or other obligation to provide Personal Information to us via this Site.

How We Use Personal Information. FIN and its third-party service providers use Personal Information only for business purposes, including to:

  • set up your account and enable you to use the Site and, in case of an institution, to allow authorized individual users to participate in training and certification programs supported by the Site;
  • tailor the content on our Site to the needs of our users;
  • fulfill and respond to your subscription requests and inquiries, whether sent to us by email or via the Contact Us form on the Site;
  • provide updates on industry news and events (which we refer to collectively as “FIN Alerts”); 
  • enable you to receive notifications, engage experts via FINQuiry™ tool, and invite other Members of FIN Community to join your financial integrity network;
  • process subscription payments;
  • communicate with you regarding our services and provide you with related customer service; and
  • send you important information regarding the Site, changes to our terms, conditions and policies and/or other administrative information.

Our third parties provide services such as website hosting, data analysis, payment processing, infrastructure provision, email delivery services, credit card processing, auditing services, and other similar services for the Site. To enable them to provide such services, we have agreed to provide them with access to your Personal Information on a need-to-know basis. If you would like specific information about our providers and the information they received, please contact us at dolfin@finintegrity.com .

We may also use Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including those outside your country of residence; (d) to enforce FIN’s Terms of Use for the Site; (e) to protect FIN’s operations; (f) to protect FIN’s rights, privacy, safety or property, you or others; and (g) to allow FIN to pursue available remedies or limit the damages that we may sustain.

How Personal Information is Disclosed. Your Personal Information might be disclosed (a) within FIN or to any FIN affiliate for the purposes described in this Privacy Policy; (b) to FIN’s third-party service providers; (c) to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of FIN’s business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other Information We Collect. “Other Information” is any anonymous information that does not reveal your specific identity or relate to you as an identifiable individual.

Other Information includes:

  • browser information and log data;
  • information collected through cookies, pixel tags and other technologies;
  • demographic information and other information provided by you;
  • aggregated information;
  • physical location.

Log Data. When you visit this Site, our servers automatically record information and data (the “Log Data”) your browser sends. This Log Data may include IP addresses, browser types (Firefox, Chrome etc.), browser versions, the search terms you use, date and time of your visit, and the pages on our Site that you visit.

Cookies. “Cookies” are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many other websites, we may from time to time use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to take full advantage of our Site.

How We Use and Disclose Other Information. Because Other Information does not personally identify you, we may use and disclose Other Information for any purpose. If we are required to treat Other Information as Personal Information under applicable law, then we use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

Security. FIN uses reasonable organizational, technical, and administrative measures to protect Personal Information under FIN’s control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure. You use the Site and provide us with information at your own discretion and risk. If you suspect or have reason to believe that your interaction with FIN is no longer secure, immediately notify us of the problem by sending an email to dolfin@finintegrity.com.

Links to Other Web Sites. This Privacy Policy does not cover the links within this Site linking to other websites. Those sites are not governed by this Privacy Policy, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.

Analytics. We work with third party service providers such as Google, Inc. and Mixpanel, Inc. to monitor certain pages of our Site for such purposes as reporting traffic and other statistics. Where authorized by us, these providers may use cookies and/or other monitoring technologies to compile statistics about our visitors, including their IP address, web browser, pages viewed, time spent on pages, and links clicked. This information may be used to, among other things, analyze and track data, improve our service, determine the popularity of certain content and better understand our users’ online activity. Further information about Google’s privacy policy may be obtained from http://www.google.com/privacy.html. Mixpanel Privacy Statement is available at https://mixpanel.com/legal/privacy-policy/ . 

How You Can Access, Change or Suppress Your Personal Information. If you would like to request to review, correct, update, suppress or delete, or object to, restrict, or otherwise limit FIN’s use of, your Personal Information that has been previously provided to FIN, you can contact us at dolfin@finintegrity.com.  In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from a FIN database, or otherwise let FIN know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable and in accordance with applicable law. 

Retention Period. We will retain your Personal Information for the length of time we have an ongoing relationship with you and your subscription for the Site is active. Upon expiration of the applicable subscription period or cancellation of the subscription by the user, we will delete User Account and all Personal Information submitted by the user, or in the case of an institutional user, all Personal Information submitted by personnel authorized to access the Site by the institutional user.

If you are located in the European Economic Area. FIN’s main administrative offices are based in the USA and that’s where we process Personal Information collected through our Site.  When you provide Personal Information to us, we request your consent to transfer that personal information to the USA.  The USA does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the USA provide adequate protection for personal information.  Although the laws of the USA do not provide legal protection that is equivalent to EU data protection laws, we safeguard your Personal Information by treating it in accordance with the provisions of GDPR.  We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Information in storage. We use secure transmission methods to collect Personal Information through this Site. We also enter into contracts with our data processors that require them to treat Personal information in a manner that is consistent with this Notice.

You have the right to be informed about our use of your Personal Information, and to correct any mistakes in the Personal Information we have collected and have such information erased. To exercise any of these rights, please contact us at dolfin@finintegrity.com.

Complaint with a Supervisory Authority. You have the right to file a complaint concerning our processing of your Personal Information with your national (or in some countries, regional) data protection authority.   The EU Commission has a list here:  http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Update to this Privacy Policy.  We may change this Privacy Policy. Any changes will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.

If you have questions about this Privacy Policy, contact us at dolfin@finintegrity.com.