Terms & Policies

California Residents’ Privacy Notice

Last updated: January 2024

1. Who are we?

FINBOURNE Technology Limited and its subsidiaries ("We", "us", "our" or "FINBOURNE") and www.FINBOURNE.com is a website (referred to as the "Site") of FINBOURNE Technology Limited and its subsidiaries. We provide our product ‘Lusid’ as a software service to customers (“Service”) You can find all our details or contact us on our Contact Page.

2. What is this document?

This is a privacy notice for California Residents and supplements the information set out in the Website Privacy Policy. This notice applies to residents of California and is provided in compliance with the privacy laws of California, including the California Consumer Privacy Act (the “CCPA”) and the California Privacy Rights Act (the “CPRA”).


We process certain information, for example, when you contact us to enquire about or use our Service or visit our Site. Some of that information may enable you to be identifiable ("Personal Data"). Personal Data does not include (i) publicly available information; (ii) de-identified or aggregated customer information; or (iii) information excluded from the scope of the CCPA and CPRA (for example, Personal Data that is explicitly covered by other regulations).


This Privacy Notice explains how we process that Personal Data.


This Site is not intended for children and we do not knowingly collect data relating to children.


FINBOURNE does not sell personal information as we understand sale to be defined by the CCPA and its implementing regulations.

3. What Personal Data do we collect from you?

We collect Personal Data relevant to your use of our Service, contact with us or the activity you choose to undertake with us or on our Site. This includes the following categories of Personal Data:

  1. Identifiers includes a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
  2. Customer Records Information includes name, signature, Social Security number, address, telephone number, education, employment, employment history, or financial information. Some Personal Information included in this category may overlap with other categories.
  3. Commercial Information includes records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
  4. Internet or Other Network Activity Information includes records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
  5. Geolocation Data includes approximate location information inferred from your IP address, city, country.
  6. Sensory Data includes audio, electronic.
  7. Professional or Employment-related Information includes current or past job history or performance evaluations.
  8. Education Information includes education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
  9. Inferences includes information drawn from the above about an individual to create a summary or profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

4. How do we collect your Personal Data?

We use different methods to collect Personal Data from you including as follows:

Enquiring about our Service or subscribing to our publications

If you contact us to ask about our Service or about us generally, either through the Site or otherwise, we will collect and process Identifiers, Customer Records Information and Commercial Information.

Signing up for the Service

If you sign up for the Service, either through the evaluation agreement or the subscription agreement, we will collect and process Identity, Contact, Financial Data and Geolocation data.

Correspondence

If you correspond with us using our contact form then we will collect and process Identifiers and Customer Records Information.

Browsing and third parties

We collect some Internet or Other Network Activity Information including information from third parties such as our cookies providers.

Candidates applying for a role at FINBOURNE

We will collect your Identity, Contact Data and Profile Data and information relating to your employment history.


We will also collect Personal Data such as Professional or Employment-related Information about you during telephone calls, in emails, during face to face interviews and from Recruitment Companies, Head-Hunters and Professional Social Sites.


We would always like to keep in touch with excellent candidates regarding any future vacancies and as a result, your consent also includes the ability for FINBOURNE Technology Limited to retain your personal details.

5. How do we use Personal Data collected from you?

We will only use your Personal Data when the law allows us to. Most commonly, we use it in the following circumstances:

  1. Where we need to perform the contract we are about to or have entered into with you.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending you third party direct marketing communications to you via email or text message. You have the right to withdraw your consent at any time.


The provision of your Personal Data is necessary when Personal Data is required for the purposes of entering into a contract with you or to receive the Services you request or is otherwise voluntary. If you do not wish to provide your Personal Data to us, we may not be able to: (a) provide the Services you request; (b) enter into a commercial relationship with you (as a customer or employee, for example) or (c) tell you about other products or services that we offer.

6. Purposes for which we will use your Personal Data?

As well uses of your Personal Data for the purposes noted above, we process and store your Personal Data for purposes set out in the following table:

Purpose/Activity Type of Data
To register you as a new customer (a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Inferences

To perform the contract and provide you with services:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Inferences

(f) Geolocation Data

To process a job application and keep you informed of employment opportunities (a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Professional or Employment- Related Information.

(f) Inferences

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to provide feedback on our Service

(a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Inferences

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identifiers

(b) Customer Records Information

(c) Protected Classifications under Law

(d) Commercial Information

(e) Internet or Other Network Activity Information

(f) Geolocation Data

(g) Sensory Data

(h) Professional or Employment-related Information

(i) Education Information

(j) Inferences

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Inferences

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Geolocation Data

(f) Inferences

To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Inferences

To respond to law enforcement requests and as required by law, court order or regulation. Any Personal Data required by law, court order or regulation.
As described to you when collecting your Personal Data or as otherwise set forth in the CCPA and CPRA. (a) Identifiers

(b) Customer Records Information

(c) Commercial Information

(d) Internet or Other Network Activity Information

(e) Geolocation Data

(f) Sensory Data

(g) Professional or Employment-related Information

(h) Education Information

(e) Inferences

7. Who do we share your Personal Data with?

We may share your Personal Data within FINBOURNE (i.e. our officers, staff and contractors) and with our service providers, for example to service your requests or provide you with information. We may also share your Personal Data if a change happens in our business such as a merger or acquisition. If that happens then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.


We may also share your Personal Data with other organisations or individuals when we determine it is reasonably necessary to:

  1. Meet any applicable law, regulation, legal process or request of a governmental body or public authority.
  2. Enforce applicable legal terms and conditions or our other legal rights, including investigation of potential violations.
  3. Detect, prevent, or otherwise address fraud, crime, security or technical issues.
  4. Protect against or prevent harm to the rights, property or safety of FINBOURNE, our clients or the public as required or permitted by law.

8. How long do we keep your Personal Data?

We will not keep your Personal Data longer than reasonably necessary to fulfil the purposes described in this Privacy Policy or as we reasonably need to in order to meet our legal and governance obligations.

9. What direct marketing do we conduct?

If you provide your contact details, we might contact you individually in the future if we think that our services may be of interest to you.


If we think it appropriate we might also add you to our regular email marketing list.


You can ask us to remove your personal details from our marketing lists using the contact details below.

10. Links to other websites

Our Site may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those websites and are not responsible for their privacy statements.


We encourage you to read the privacy statements on the other websites you visit.

11. Changes

We may update this Privacy Policy from time to time. We will post any Privacy Policy changes on our Site. Please check for any updates to this Privacy Policy when you access our Site again.

12. Your rights

Under certain circumstances, you have rights under the CCPA and CPRA in relation to your Personal Data.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  1. The categories of Personal Data we collected about you.
  2. The categories of sources for the Personal Data we collected about you.
  3. Our business or commercial purpose for collecting that Personal Data.
  4. The categories of third parties with whom we share that Personal Data.
  5. The specific pieces of Personal Data we collected about you (also called a data portability request).
  6. If we sold or disclosed your Personal Data for a business purpose, information setting out:
    • sales, identifying the Personal Data categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

Request Deletion

You have the right to request deletion of your Personal Data in certain circumstances. This enables you to ask us to delete or remove Personal Data where it is no longer necessary for us continuing to process it. However, the right to erasure is not an absolute right and we may not always be required to comply with your request for specific legal reasons which will be notified to you, if applicable, at the time of your request. The circumstances in which we may deny your request include where we require your Personal Data to:

  1. Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Request Correction

You have the right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request Restriction of use and Disclosure of Your Sensitive Personal Data.

This enables you to ask us to suspend the use or disclosure of your Sensitive Personal Data.

Request Restriction on Sharing Your Personal Data.

This enables you to ask us to cease sharing your Personal Data.

13. Exercising rights in relation to your Personal Data

If you wish to exercise any of the rights set out above, please contact data.protection@finbourne.com.


Only you or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.


The verifiable consumer request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorised representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We endeavour to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.


In some cases, the exercise of these rights may be limited if complying with a verifiable consumer request is impossible or would involve a disproportionate effort.


We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

14. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not:

  1. Deny you services.
  2. Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of services.
  4. Suggest that you may receive a different price or rate for services or a different level or quality of services.

15. Contact Us

If you have any questions or comments about this privacy notice, our Website Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at data.protection@finbourne.com.