1.0 Introduction

FLIT Invest LLC has adopted this privacy policy to recognize that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you accurately and efficiently. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.

For more information about our services, please refer to our website https://www.flitinvest.com/.

This Privacy Policy is applicable to FLIT Invest LLC (“we,” “our,” or “us”) as related to our services, which collectively include:

• the use of https://www.flitinvest.com/ (“website”)
• the use of the FLIT Invest iOS mobile application (“application”) 
• social media messages and marketing campaigns and 
• the use of our products and services. 

This Privacy Policy identifies the essential details relating to your personal data relationships with FLIT Invest LLC as:

• A website visitor
• An end user of the application (“end user”)
• A prospective client
• A job applicant and
• Partners

Clients contract the use of our application and give access to their employees and other third parties, as solely decided by them, by creating users who access the application with their email address and credentials. The clients’ administrators grant end users roles, which result in different permissions and access rights to the information held in the Client account.

2.0 Personal Information We Collect 

2.1 Information You Choose to Provide to Us

WHEN

We may ask you to provide personal information when:

• You use the website to sign up for our waitlist.
• You refer a friend to us.
• You connect with us directly via phone calls or video conferencing platforms.
• You upload or enter personal information into the application.
• You participate in a marketing/sales promotion.
• You participate in programs we may offer from time to time.
• You pay for our services. 

If you choose to provide us with a third party’s personal information (the person’s email and name) when taking part in our referral program, you represent that you have the third party’s permission to do so.

WHAT

We collect certain nonpublic information about you (“Customer Information”). The essential purpose of collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

• Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets.
• Identifying information such as your name, age, address, social security number, etc.
• Information about your transactions with us or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).
• Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.

We may also collect your resume and cover letter as a job applicant.

2.2 Information We Collect Automatically

WHEN

We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology.

WHAT

The information collected includes:

• access times
• the pages you view
• the links you click on 
• the search terms you enter 
• actions you take in connection with any of the visited pages
• your device information such as IP address, location, browser type, and language
• the Uniform Resource Locator (URL) of the website that referred you to our website and 
• the URL you browse away from our pages if you click on an external link

We may also collect information when you open email messages from us or click on links within those email messages.

3.0 How We Use Personal Information  

We use your personal information to:

• Deliver the contracted services and allow full use of the application functionality purchased by the clients.
• Deliver training and support to our application end users and carry out the transactions you have requested.
• To communicate with you directly. 
• Process payments for application subscriptions.
• Send communications to you about:
  • New application features and upgrades.
  • Our services and offerings. 
  • Event announcements. 
  • Product notices and changes to our terms and policies.
  • Particular programs in which you have chosen to participate. 
  • Promotional offers and surveys.
  • Scheduling demos and managing free trials.
• Advertise and market our products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites.
• Carry out market research to understand how to improve our services and their delivery.
• Create and manage marketing campaigns.
• Generate sales leads and increase our market share.
• Analyze user clicks and usage of the application and website to improve user experience and maximize the use of our services.
• Manage our website and application to maintain and deliver the contracted functionality and services.
• Enforce our website and application terms and separate contracts (if applicable) with you
• Prevent fraud and other prohibited or illegal activities.
• Protect the security or integrity of the website, application, business, or services.
• Or otherwise, as disclosed to you at the point of collection or as required or permitted by law.

We do not sell your information to any third party.

4.0 How We Share Personal Information

Our Application and Services

We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the authorized services (such as broker-dealers, custodians, independent managers, etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.

We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited from using or sharing the information for any other purpose.

Former Clients

If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.

Service Providers

We use third parties to help us provide our services. They will have access to your information collected by the application as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect personal information, only use it to deliver the contracted services to us, prohibit them from selling it, and not disclose it without our knowledge and permission.

Legal Disclosures

We may need to disclose personal information when required by law, subpoena, or other legal processes identified in the applicable legislation. 

We attempt to notify our clients about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

Change in Control

We can also share your personal data as part of a sale, merger, change in control, or in preparation for any of these events. 

Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5.0 How We Secure Personal Information

We are committed to protecting the security of all personal information we collect and use. 

We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information. We use encryption technologies to protect data at rest and in transit.

6.0 Your Rights

You have the right to obtain information about what personal information we process about you or to obtain a copy of your personal data. 

If you have provided personal information to us, you may contact us to obtain an outline of what information we have about you or a copy of the data. 

If you are an end user of the application, you can log in to see the personal information in the account for more details.

• You have the right to be notified of what personal information we collect about you and how we use it, disclose it, and protect it.

This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly.

• Change or correct your personal information.

You have the right to update/correct your personal information or ask us to do it on your behalf. 

You can edit your information through the user account in the application or ask us to change or correct it by contacting us at [email protected].

If you would like to exercise any of the rights described above, please get in touch with us at [email protected].

You also have the right to lodge a complaint with the local organizations enforcing the privacy legislation applicable in your territory.

7.0 How Long We Keep Your Personal Information

We retain information as long as it is necessary to provide the services to you and our clients, subject to any legal obligations to retain such information further.

We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law. 

The information we retain will be handled following this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data. This information may provide insights that are commercially valuable to FLIT Invest LLC, such as statistics of the use of the services.

8.0 Other Important Information

We process data in the United States and rely on legally-provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations. 

We will only collect and process your personal data where we have a lawful reason for its collection.

When you visit our website and provide us with your personal information, we collect and use it with your consent.  

You can review the terms and conditions of use here: https://flitinvest.com/terms-conditions/

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have questions about the lawful bases upon which we collect and use your personal data, don’t hesitate to contact us at [email protected].

How to select your communications preferences 

You may choose to receive or not receive marketing communications from us. Please click the “Unsubscribe” link in the email we sent you to stop receiving marketing communications. 

Even if you opt-out of receiving marketing communications, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or program in which you may have elected to participate.

Changes to our privacy policy

If there is a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt out of such disclosure arrangements.

9.0 Contact Information

You may contact us to exercise your rights or ask for more information about your personal information and our privacy practices by contacting us at [email protected].

Appendix 

A.1 For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

A.1.1 Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name and email address or other similar identifiers.
• Geolocation data, such as information about your location (at country and city level) collected from your IP address.
• Profession/employment information that you send to us when applying for a position included in your CV and cover letter.
• Other personal information, such as personal information you provide to us concerning a survey, comment, question, request, article download or inquiry, and any additional information you upload to our application.

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information, or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

A.1.2 Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks. 

For more information, please see the “How We Share Information” section of the Privacy Policy above.

A.1.3 California Privacy Rights

As a California resident, you may be able to exercise the following rights concerning the personal information about you that we have collected (subject to certain limitations at law):

• The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):
  • The specific pieces of personal information we have collected about you
  • The categories of personal information we have collected about you
  • The categories of sources of the personal information
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
  • The business or commercial purposes for collecting or selling personal information.
• The right to request deletion of personal information we have collected from you, subject to certain exceptions.
• The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights. 

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

A.1.4 How to Exercise Your California Consumer Rights

To exercise your right to know and/or your right to deletion, please submit a request by contacting us at [email protected].

We will need to verify your identity before processing your request. 

To verify your identity, we will generally require sufficient information from you to match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you. 

We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to request the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority. 

If you are an employee/former employee of a FLIT Invest LLC client that uses our application and services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate, etc.) who was given access to the FLIT Invest LLC application by a FLIT Invest LLC client, please direct your requests and/or questions directly to the FLIT Invest LLC client that gave you access.

Minors Under Age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.