Fivvy takes the protection and security of personal data very seriously.
Fivvy privacy statements for visitors of this website.
Our registered office address is at:
- Fivvy Inc
- 407 Lincoln Road
- Suite 9
- Miami, Florida
What are cookies?
Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”) or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).
We may also use Flash cookies or Flash Local Shared Objects (LSOs) through our services. Flash cookies, which can be stored or retrieved whenever a user accesses a page containing a Flash application, are a form of local storage. Similar to cookies, they can be used to store user preferences.
We work with certain third parties (for web analytics service providers, and integration with our sales platform) to provide us with information about our site traffic and usage. These third parties may set and access their own cookies or tracking technologies, such as web beacons and embedded scripts, on our Website in order to recognize your device and for example, identify whether you have visited our Website before, what you have viewed on our Website and how you found us. Such information is used for statistical purposes.
The information collected through our cookies may be used for the following purposes:
- To provide, operate, optimize and maintain the Website;
- To deal with enquiries through our Website or to provide you with information and access to resources that you have requested from us;
- To analyze the use of our Website for trend monitoring, marketing and advertising purposes;
- For network security and administration;
- To investigate and prevent fraud, spam, malware, identity theft or other unauthorized access to or unlawful activity; and
- For other legitimate business purposes and other purposes about which we notify you.
For more information on the choices you have about the cookies we use, please see the Controlling Cookies section below.
We will use appropriate security measures to help protect your personal information. These measures include technical, administrative, physical, and organizational measures to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction. We do our best to protect your personal information. You should only access the Website in a secure environment.
As an individual, you have rights under the GDPR regarding the use of your data, these are:
The right to withdraw consent: you can withdraw consent at any time.
The right to erasure: you can request that Fivvy remove your data from our systems.
The right to restrict processing: you can request that Fivvy only process your data for the purposes you specify.
The right to data portability: you can request that the data you have provided to Fivvy be ported to another organization.
The right to access your data: You have a right to know what data Fivvy holds on you and for what purpose we are processing your data. This is known as a Subject Access Request (SAR).
The right to rectification: you have the right to ask us to rectify any information you believe is inaccurate. You also have the right to ask us to complete information you think is incomplete.
The right to object to processing: you have the right to object to processing if we are able to process your information because the processing is in our legitimate interests.
You are not required to pay any charge for exercising your rights. If Fivvy are unable to comply with your request, we will provide you with an explanation.
If you do not want us to deploy cookies on your browser, you can set your browser to reject cookies. You can find information on popular browsers and how to adjust your cookie preferences at the following websites:
Apple Safari: Blocks cookies by default and accepts cookies only from your current domain. To change, click Safari, Preferences, Security, and choose your preference.
You can manage Flash cookies storage through your browser settings where supported, or you may manage Flash storage. To learn how to manage these, click here for Windows and here for OS/Mac.
Please note, however, that if you don’t accept cookies on our Website, you may not be able to access all portions or features of the site.
How can you contact us?
If you have any questions about this policy or any of the above, please email us at email@example.com.
Fivvy Supplemental Privacy Statement for Californian consumers (FSPS).
Effective Date: March 24, 2022
Fivvy Inc. (“Fivvy,” “we,” “us” or “our”) takes the protection and security of your personal data very seriously.
Please read this Statement if and when an organization of your choice (our customer) has assigned to us your consent to access your personal data as a part of the services we provide to them.
Capitalized terms used but not defined herein, shall have the meanings ascribed to such terms in California Civil Code § 1798.100, et seq. (together with the regulations thereunder, the “FSPS”), as applicable.
This Statement reflects our good faith understanding of the law and our data practices as of the date posted (set forth above). Accordingly, we may from time-to-time update information in this Statement and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
If you have any questions about how we use your personal data, please contact our Data Protection Officer by email at firstname.lastname@example.org.
Our registered office address is at:
- Fivvy Inc
- 407 Lincoln Road
- Suite 9
- Miami, Florida
This Statement addresses the following topics:
- Purpose for collecting data;
- How we collect data;
- What data we collect;
- California Consumer privacy rights.
Purpose for collecting data
Your User’s Data may be collected for the purpose of helping financial and other organizations produce real-time credit decisions based on our alternative credit score (the “Purpose”). We provide this alternative credit score only in relation to the service that you are applying for at the organization of your choice (our customer). We use mobile and web device metadata and/or personal information (“personal information” or “PI”) to produce the alternative credit score via our proprietary technology. This includes highly sophisticated algorithms and predictive analytics applied to metadata accessed via our mobile applications (Fivvy) and a mobile SDK (FivvySDK). We do NOT share your alternative credit score with any third party other than the organization of your choice (our customer).
How we collect data
Your User’s Data may be collected directly from you in three ways:
- When you download our application (Fivvy); or
- When you use the mobile application of the organization of your choice (our customer) that has embedded Fivvy’s mobile technology(FivvySDK); or
- any other add-ons developed by Fivvy.
What data we collect
We may collect the following categories of User’s Data about you:
On mobile phones, contacts, list and storage of applications, as well as registered accounts, which might include social accounts, and installed applications, we provided an anti-fraud service that included the detection of VPN-type applications, including TOR and VPN-type applications. The core purpose of detecting these types of applications involves financial transaction functionality (for example, dedicated banking or a dedicated digital wallet) and obtaining broader visibility into installed applications solely for security-based purposes.
This may still sound complex, so an example is often the easiest way to explain:
You are going to engage with the financial organization of your choice (our customer).
In order to provide you with the tools to prevent scams that could result in the loss of your personal funds, the financial organization of your choice can identify if any malware has been installed on your phone. Additionally, they might detect if someone is attempting to use your phone for illicit purposes. If you apply for a credit or loan, they will also assess your creditworthiness. That measurement can be complemented with our models.
At our customers request, Fivvy collects specific personal information and/or metadata from your mobile devices (via our products and services) (the “User`s Data”) and processes this User`s Data with Fivvy`s proprietary technology.
We pass your alternative score (but in no event your personal data) and malware alerts to an organization of your choice (our customer).
The financial organization of your choice (our customer) then decides how it will respond to you, e.g., provide you with specific alerts via their app, accept or decline your request for a new product, etc.
Fivvy does not have visibility, nor can we influence how the financial organization of your choice responds to you.
California Consumer privacy rights
Due to how Fivvy processes data, your Personal Information is pseudonymized, therefore it is not possible for Fivvy to identify you as an individual.
Therefore, to exercise any of your rights outlined below, you have to consult with the organization you have been interacting with (our customer). You will be asked to provide your name, email address, country of residence, state, and request details. A confirmation email will be sent to the email address you provide to begin the process of verifying your identity. To protect your privacy and security, the organization you have been interacting with may require verification of your identity to a high degree of certainty based on information they already have about you. If you cannot meet that standard, we, together with the organization you have been interacting with, will treat your request as a “category request” as explained in the next section.
The organization you have been interacting with (our customer) will be able to provide Fivvy with information to assist in exercising the rights listed below (“Rights”).
1) Right to Know:
Specific Pieces: You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected and are maintaining for the period that is 12 months prior to the request date. To protect your security and the rights of others, we may not be able to provide you with all of the PI we may have on you.
Categories: California Consumers have the right, no more than twice in a twelve-month period, to request that we disclose the categories of PI collected in the prior 12 months, the categories of sources from which such PI is collected, the purpose for such collection or its sale (if applicable), the categories of third parties with which the business shares such PI, and, for each category of such PI, the categories of recipients of business purposes disclosures and, if applicable, of sales.
2) Right to Delete
Except to the extent we have a basis for retention under the FSPS, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, the ability to complete transactions and provide services you have requested or that are reasonably anticipated, for security purposes or legitimate internal business purposes, including maintaining business records, complying with the law, exercising or defending legal claims, and cooperating with law enforcement.
Rather than exercising a deletion request, you may alternatively exercise more limited control of your PI by opting out of email marketing communications by following the unsubscribe instructions on the footer of those emails.
3) “Do Not Sell My Personal Information”
While California law also allows for California residents to opt-out of the sale of their PI, we do not sell the PI of California consumers as those terms are defined by the FSPS.
4) Verification Process
When you submit a request to know or delete your PI to the organization you have been interacting with (our customer), that organization is required to verify your request to ensure that the request is not fraudulent (“Verifiable Consumer Request”). Thus, upon receiving your request, the organization shall take measures to verify that the request is legitimate. These verification efforts may require additional information from you, which may include information you have provided us in the past. For instance, if you have previously provided your name to them, they may ask you for other information (e.g., email address, phone number, or transaction history) so that they can match the new information you provide with the information they have. They may also use other verification methods as the circumstances dictate. If, through reasonable efforts, they are unable to verify your request to the appropriate degree of certainty, they will notify you. They shall use the PI provided in a Verifiable Consumer Request only to verify your identity or your authority to make the request and to track and document request responses, unless you also gave it to them for another purpose.
5) Agent Requests
Note you can authorize an agent to exercise any of these California privacy rights on your behalf, subject to the agent request requirements of the FSPS. Note that the organization you have been interacting with (our customer), shall take additional measures to verify the legal authority of your agent.
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your FSPS rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
Some PI we maintain about California Consumers is not associated with PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the FSPS’s verification standards is made to the organization you have been interacting with (our customer). If we cannot comply fully with a request, we will explain the reasons in our response, unless we are prohibited from doing so by applicable law.
Together with the organization you have been interacting with (our customer), we will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer rights requests. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests, provided, however, that we may charge a reasonable fee or refuse to act upon a request if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we charge you for responding to your request. As permitted by the FSPS, we are also not required to search for PI not maintained in a searchable or reasonably accessible format that is used for certain internal purposes only, but if we apply this exception, we will respond to your request with a description of the categories of PI to which this exception applies.
In addition, as explained above, we will reject requests to the extent we and the organization you have been interacting with (our customer) are not able to sufficiently verify your identity, or your agent’s authority. If we conclude we have a basis for not fully responding to your request, our response to you will explain the basis for the limitation, unless we are prohibited from doing so by applicable law.
7) Financial Incentives and Non-discrimination
California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the California Consumer Privacy Act. As of the Effective Date of this CA Statement we did not offer any programs requiring you to limit any of your FSPS rights, or otherwise require you to limit your FSPS rights in connection with charging a different price or rate, or offering a different level or quality of good or service. If we do so, the FSPS requires certain program terms and notices for California Consumer and the material aspects of any such program, and the rights of California participants, will be explained and described in its program terms. Participating in any such programs will be entirely optional. We may add or change programs and/or their terms by posting notices on the program descriptions, so check them regularly.