Privacy Notice

Last updated on: 2023/07/07

Thank you for using Fineasy .Fineasy is operated by Finshell Financing, INC. (hereinafter referred to as “we”, “us” or “our”) and is a product that provides you with Coupon center and access to other third-party services. During your use of our accounts, websites, mobile apps, or other products or services, we may collect and use your personal information. In this Privacy Notice, “personal information” or “personal data” refers to all information that can be used alone or in combination with other information to identify a specific natural person.

This Privacy Notice describes how we collect, use, disclose, transfer, store and otherwise process your personal data when you are using our services, including our websites, our smartphones or wearable devices, apps, online services and other products (hereinafter collectively referred to as "Services"). Within the meaning applicable law, we will act as a data controller when we process your personal data. Please read the Privacy Notice carefully and familiarise yourself with our privacy practices before using our Services or providing your personal data.

This Privacy Notice will help you understand the following:

1. How We Collect Personal Data and What Types of Personal Data We Collect
2. How We Use Your Personal Data

   III. How We Use Cookies and Similar Technologies

1. How Long We Keep Your Personal Data
2. How We Disclose Your Personal Data
3. How Your Personal Data Is Transferred Globally

   VII. How We Protect Your Personal Data

   VIII. Your Rights Regarding Your Personal Data

1. How We Process Children's Personal Data
2. Third-Party Websites
3. How This Privacy Notice Is Updated

   XII. Contact Us

In addition to this Privacy Notice, specific privacy notices might apply depending on the Services used. We will, in each case, provide you with the applicable privacy notice.

1. How We Collect Personal Data and What Types of Personal Data We Collect

The term personal data is broadly defined and means any information relating to an identified or identifiable individual. This means that not only the data that, for example, identifies you directly, such as your name or address, is personal data but also other data, which when combined with other information accessible to us, enables us to link that data to you, for example, an IP address.

Our channels for collecting personal data include: 1. personal data that you provide to us directly; 2. personal data that we automatically obtain when you interact with our Services, such as information on your interactions with our Services or us, and/or; 3. personal data that we obtain about you from third parties.

The personal data we collect depends on the environment in which you interact with us and the choices you make, including your privacy settings and the features and Services you use.

1. Personal Data Provided by You andAutomatically Collected About Your Use of Our Services by us

You may provide personal data to us directly, in which case you are generally free to choose which personal data you want to provide to us. However, if some personal data is required for the performance of our Services and you choose not to provide that personal data, we may not be able to provide you with the Services you requested. In addition to the personal data you provide yourself, we may also automatically collect information about your use of our Services, particularly when you are using your device.

• When you hope to provide the suggestions: You can provide feedback or suggestions in the "Fineasy Support" module in Fineasy. At that time, you need to fill in the feedback content. At the same time, you can provide your mobile phone number, and/or email address, so that we can get in touch with you about your feedback or suggestions.
• When you use the replicated physical access card service：we will obtain your device model, operating system version number and access card information ( UID ) as the identification of your access card and establish the corresponding relationship between the equipment and the access card to enter your physical access card and use mobile phone access card to open the door.
• Inorder to match the local language with your APP: We may collect the Language and Region public Codes so that we can set the suitable language for the APP used.
• In order to optimize the product experience of the project and the subsequent optimization iteration：We may collect your Device ID （DUID） in order to save and count your browsing and clicking behavior data on the app.
• In order touse Fineasy: you need to first sign up for a HeyTap account, which is provided by BRAVO UNICORN PTE. LTD. ("Bravo"), and then sign in to Fineasy with your HeyTap account. During the sign-up process, please carefully read the account privacy statement at Account Privacy Statement before creating HeyTap account and signing in to Fineasy with your HeyTap Account. To associate your HeyTap Account with your actions performed in Fineasy, when you sign into this APP using your HeyTap Account, we will collect your HeyTap Account information from Bravo, including the account ID, nickname and avatar. We collect this information for the purpose of providing you with the sign-in service, protecting the security of your account. If you do not provide this information to HeyTap and permit HeyTap to provide such information to us then you will not be able to sign in to Fineasy, When you login your HeyTap account, Fineasy provides you with access to the Rewards services provided by Bravo, where you may manage your reward points and orders. Before using the Rewards services, please carefully read the rewards privacy statement at https://muc.heytap.com/document/heytap/creditsShop/creditsShop
• In order to provide you with notification and push functions:we may collect your device information including your Registration ID and Firebase installation ID, etc. The Notification and Push services include App update and installation, sales and promotion data, etc. You can stop receiving data through "Settings" on your device.

2. Personal Data We Obtain From Third Parties

We don't obtain personal data about you from third parties in this version.

1. How We Use Your Personal Data
2. We may use your personal data for the following purposes:

• to provide you with our Services, process your orders or fulfil the contract between you and us;
• to diagnose product issues and provide other customer care and support Services;
• to conduct customer surveys in order to enhance your user experience and improve our Services along with their security features;
• to analyse the customer market on the basis of the country where the users use our Services;
• to analyse the efficiency of our business operations;
• to analyse error logs to improve phone quality and app functions;
• to provide you with personalised Services and to recommend and display content and advertisements tailored to you through our Services;
• to allow and manage your participation in prize draws, contests or similar promotional activities held by us;
• to communicate with you and reply to your questions or comments submitted through email or our online platforms, including social media accounts;
• to ensure the functionality and safety of our Services, verify your identity, conduct internal auditing and prevent and investigate fraud, cybersecurity threats or other improper use;
• to enhance and develop our Services, so as to improve the product usage experience, user-friendliness, operational performance, functions and design;
• to pursue or defend against legal claims;
• to comply with our legal obligations.
• to provide notification and push services;

2. When we want to use the personal data for other purposes not covered by this Privacy Notice, we will inform you thereof and ensure that said use of your personal data is lawful.
3. We do not make any decisions involving the use of algorithms or profiling that produces legal effects or other effects that significantly affect you.

III. How We Use Cookies and Similar Technologies

We don't Use Cookies and Similar Technologies in this version.

1. How Long We Keep Your Personal Data

We will only store your personal data for as long as necessary to achieve the collection purposes set out in this Privacy Notice, unless a longer retention period is required by law. If we are required by law to store your personal data beyond this period (such as for tax and commercial law reasons), we will delete the personal data at the end of this storage period.

After the expiry of the aforementioned retention periods, we will delete or anonymise your personal data.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use and disclosure of your personal data, the purposes for which we process the personal data and the applicable legal requirements.

1. How We Disclose Your Personal Data

At times we may make certain personal data available to other companies that are wholly or jointly controlled by us ("Affiliates") and other third parties that work with us in order to provide Services to you. Your personal data will not be shared with third parties for their own independent marketing purposes.

• Affiliates: Your personal data may be shared with our Affiliates for the purpose of rendering our Services to you. If Affiliates wish to process data for a different purpose, they must first seek your consent, unless another lawful basis exists.
• Service Providers and Partners: Some of our Services will be provided with the assistance of third parties. We may also share some personal data with our partners in particular so as to deliver you a better service and improve your user experience. We will share the Firebase installation ID with Google, so that we can use Google's Firebase system to send notification and push functions .
• Purchasers and third parties in connection with a business transaction: Where a merger, acquisition, bankruptcy liquidation or similar action takes place, we may transfer or disclose your personal data to a limited, but necessary extent to the applicable third party.
• Law enforcement, regulators and other parties for legal reasons:We may also disclose your personal data to third parties as required by law, or if we reasonably believe that such action is necessary (a) to comply with a subpoena or other legal proceedings, legal actions or government agency requests; (b) when we believe in good faith that a disclosure is necessary to comply with the law and the reasonable requests of law enforcement; (c) to protect and exercise our legal claims, rights and property; (d) to protect your rights, property or personal safety or that of others; (e) to investigate fraud and (f) to protect the security or integrity of our Services.
• The public, when posted in certain public spaces:Some of our Services allow you to connect and interact with others. Your profile information or information that you post in a forum or on a blog, including personal data, will be accessible to other users or the general public by default when you create it. Such content will be accessible by the general public or the members of the Service depending on the Service used.
• Otherwise with consent:We may disclose your personal data to certain other third parties with your consent.

1. How Your Personal Data Is Transferred Globally
2. We leverage our resources and servers around the world to provide Services. We have data centres in the U.S., France, Singapore, India and Indonesia, which means that in compliance with applicable laws, your personal data might be transferred to or accessed from countries or regions outside of where you use our Services.
3. Please note that different countries or regions offer different levels of data protection. This means that your personal data could be stored in a country that offers a level of protection that may, in certain instances, be less protective of your personal data than the country or region in which you are located. However, in such cases, we will take measures to ensure that the personal data we collect is processed in accordance with this Privacy Notice and applicable laws, and that your personal data is adequately protected. For example, we might ask your permission to transfer your personal data across borders, and we will implement adequate security measures (such as encryption and de-identification where feasible) and sign the necessary data transmission/sharing agreements with the recipients of your personal data prior to the transfer taking place. We will also specifically ensure that we comply with laws that require us to store data locally within a specific country or region.

VII. How We Protect Your Personal Data

1. The security of your personal data is very important to us. We have taken reasonably practical, technical and organisational measures in accordance with industry standards to protect personal data collected in connection with our Service and prevent it from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. However, please note that while we have taken reasonable measures to protect your personal data, no websites, Internet transmissions, computer systems or wireless connections are absolutely secure. In particular:

• Where appropriate, we will de-identify your personal data to mitigate the risk that other organisations or individuals may identify you on the basis of that personal data. We may also implement full security encryption during storage and transmission to prevent your personal data from unauthorised access, use or disclosure (such as by using SSL to encrypt many Services). We regularly review practices regarding personal data collection, storage and processing (including physical security measures) to prevent unauthorised access to or tampering with our various systems and your personal data.
• We only allow our employees and personnel of authorised service companies to access such personal data on a need-to-know basis, in order to process such personal data or provide relevant Services to you. These employees and external personnel are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held liable and/or their relationship with usmay be terminated.
• When transmitting and storing special categories of personal data, we use extra security measures, such as encryption of the transmitted content. We also use technical measures to process your personal biometric information so that we only need to store essential data (such as basic parameters necessary to identify a person, but not the raw facial and fingerprint data).
• We carefully select our business partners and service providers and ensure that they are sufficiently bound to protect personal data and will be subject to privacy audits and assessments.
• We conduct security and privacy protection training, testing and other activities to enhance employee awareness of and proficiency in personal data protection.
• We use international and industry-recognised standards to protect your personal data and actively pursue relevant security and privacy protection accreditation.
• We promise not to sell personal data to any third party and guarantees the legitimate and fair use of user information only to the extent permitted by law.

2. In case of a personal data security incident, we will act in accordance with applicable law and notify you and/or the competent data protection authority of any such security incident where required, and take measures to mitigate any risks arising therefrom.

VIII. Your Rights Regarding Your Personal Data

1. Subject to applicable laws in your jurisdiction, you may have specific rights regarding your personal data. This may include the following rights in particular:

• The right to be informed:We are publishing this Privacy Notice to keep you informed as to how we handle your personal data and what options and rights you have regarding your personal data.
• The right to access: You can contact us by referring to the "Contact Us" section to request access to your personal information.
• The right to rectification:If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and request the completion of your personal data where appropriate.  You can contact us by referring to the "Contact Us" section to have such personal information corrected or completed.
• The right to Erasure:You may choose to delete some of the personal information you have submitted to us. You can contact us by referring to the "Contact Us" section to have such personal information deleted.

   • The Right to Cancel Account:You have the right to cancel your Fineasy account and HeyTap account.

For HeyTap account, you can go to https://id.heytap.com/static/userdata_index.html to delete your HeyTap Account. After you submit your account cancellation request, we may need to manually review your account cancellation to make sure you meet the conditions for cancellation. After you cancel your account, we will no longer be able to provide you with the HeyTap account registration service and other products and services that require logging in to this App or a HeyTap account.

Process to delete account: Fineasy App-> Go to Me Section-> Settings-> Delete Account

You may also contact us directly and request cancellation of your account by the manners disclosed in this Privacy Notice. We will record your request to cancel your account, conduct a manual review of your request to confirm that you are eligible to cancel your account, and we will assist you in completing the cancellation of your account.

• The right to Withdraw Consent:If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time, and we must stop processing your data. You can withdraw your consent by contacting us.

If you withdraw your consent, we will no longer be able to provide you with the related services. We will also no longer process related personal information, but the withdrawal of your consent will not affect the processing of the personal information that has been collected previously.

2. You may also have further legal rights concerning your personal data, depending on the jurisdiction in which you are located.
3. If you wish to make a request, you can submit it through email.
4. Please note that, in the interest of security, we may ask you to verify your identity before processing your request.
5. Certain jurisdictions might entitle you to refer the complaint to the relevant regulatory authority if you are not satisfied with the response you received.
6. In principle, we do not charge a fee for responding to your reasonable request. However, for multiple and repetitive requests that exceed a reasonable limit, we may charge a reasonable fee to cover some of our costs, depending on the nature of the request. We are entitled to refuse requests in whole or in part, and we may refuse requests that are manifestly unfounded, unreasonably repetitive or that require disproportionate technical effort (for instance, requests that require the development of new systems). In addition, we may not respond to requests that directly concern significant issues of public interest or may cause serious damage to the legitimate rights and interests of you or other individuals or entities.

1. How We Process Children's Personal Data
2. Our Services are mainly intended for adults. A child should not use our Services without his/her legal guardian's consent. We treat anyone less than the equivalent minimum age for full legal capacity in the relevant jurisdiction as a child.
3. If we discover that a child's personal data has been collected, we will delete the corresponding data as soon as possible.
4. If you believe that we might have any personal data concerning a child, please contact us by referring to the "Contact Us" section.

1. Third-Party Websites
2. Our Services may contain links to third-party websites, products and services. You can choose whether to access websites or accept products and services provided by third parties or not. For example, the "Follow us" function on our official website provides links to our official social media accounts (such as Facebook, Instagram, LinkedIn and Twitter) where you can view marketing or promotional information published by us.
3. We do not control third-party privacy and data protection policies and do not accept any responsibility or liability for such policies. At the same time, such third parties are not bound by this Privacy Notice. Therefore, before submitting personal data to third parties, we strongly recommend that you refer to the privacy protection practices of such third parties.

1. How This Privacy Notice Is Updated

We reserve the right to update or modify this Privacy Notice from time to time. We will, as appropriate, send you notifications of material updates to this Privacy Notice in a form we deem appropriate and we will update the "last updated" date at the start of this Privacy Notice.

XII. Contact Us

If you have questions or concerns regarding our Privacy Notice or practices, please submit your request through:

Email : fineasy.wecare@gmail.com