Privacy Policy

Effective date: 2025.05.01

At Finisterra, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our website in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent to our collection, use and disclosure of your Personal Data as described in this Privacy Policy. 

We may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on our website. If you use the website after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What This Privacy Policy Covers 

This Privacy Policy covers how Finisterra collects and processes data that identifies or relates to you (“Personal Data”) This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data We May Collect 

Device or Web Data. If you visit our website, we may collect information about your device and/or browser such as your IP address, device ID, and type of device or operating system used to connect with us. 

Contact Data. We may collect your contact information such as your name and email if you contact us.

Other Personal Data. We may collect other Personal Data that you make available to us, such as in communications you send us.

Sources of Personal Data

We collect Personal Data when you provide it directly to us (e.g., contact us) and certain Personal Data automatically when you access our website (e.g., through Cookies – as defined in the “Cookies” section below).

Purpose for Collection and Processing Personal Data

To Provide our Services. 

  • Providing you with the information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the website.
  • Doing fraud protection, security and debugging.

Corresponding with You

  • Responding to correspondence that we receive from you and contacting you when necessary or requested.

Legal or Security 

  • Meeting legal requirements and enforcing legal terms.
  • Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Finisterra or another party.
  • Enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

Who We May Share Personal Data With 

Service Providers. These parties help us provide the website or perform business functions on our behalf, including hosting, technology and communication providers.

Others. We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the “Legal or Security” subsection above. Additionally, all of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Cookies

The website uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) that may collect or facilitate the collection of your Personal Data for various purposes. We may also supplement the information we collect via Cookies with information received from third parties, including third parties that have placed their own Cookies on your device(s). 

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our website, maintain your preferences over time and recognize you when you return to our website. 

Most internet browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the functionalities may not work. 

Data Security and Retention

Although we work to protect the security of the Personal Data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. You can help protect your Personal Data by practicing password hygiene – for example, limiting access to your computer or device and browser. 

We retain Personal Data about you for as long as necessary to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for certain categories of Personal Data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, to resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

U.S. State Privacy Rights 

If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the ‘Exercising Your Rights under U.S. State Privacy Laws’ section below for instructions regarding how to exercise these rights. Please note that your rights may be subject to certain conditions or exceptions in accordance applicable U.S. State Privacy Laws. 

If you have any questions about this section or whether any of the following rights apply to you, please contact us at legal@finisterra.ai.

  • Access: You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to which we has disclosed your Personal Data.
  • Deletion: You may have the right to request that we delete the Personal Data that we have collected about you. 
  • Correction: You may have the right to request that we correct any inaccurate Personal Data we have collected about you. 
  • Portability: You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

“Selling,” “Sharing,” or “Targeted Advertising” 

We do not sell, share, or process your Personal Data for the purposes of targeted advertising, and have not done so over the last 12 months.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy laws.

Other State-Specific Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at legal@finisterra.ai.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our website does not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Exercising Your Rights under U.S. State Privacy Laws 

To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.

We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Access, Delete, or Correct

As applicable, you may submit a Valid Request for your right to access, delete, correct, or obtain a copy of your Personal Data described in this Privacy Policy, or any other rights afforded to you, by emailing us at: legal@finisterra.ai.

Depending on your U.S. state of residence, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Appealing a Denial

Depending on your U.S. state of residence, if we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by emailing us at: legal@finisterra.ai (title must include “[STATE OF RESIDENCE] Appeal”).

If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, and Virginia.

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below. Finisterra will be the controller of your Personal Data processed in connection with the Services. If you have any questions about this section or whether any of the following applies to you, please contact us at legal@finisterra.ai. 

Personal Data Use and Processing Grounds

The “Purposes for Collecting Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity:  We process the following categories of Personal Data as a matter of “contractual necessity.” When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the website that require such data.
    • Device or Web Data
    • Contact Data
    • Other Personal Data
  • Legitimate Interest:  We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
    • Device or Web Data
    • Contact Data
    • Other Personal Data
    • We may also de-identify or anonymize Personal Data to further our legitimate interests. 
    • Examples of these legitimate interests include (as described in more detail above):
      • To provide our services to you.
      • Corresponding with you.
      • Meeting legal requirements and enforcing legal terms.
      • Completing corporate transactions.
  • Consent:  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 
  • Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

EU, UK and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at legal@finisterra.ai. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

  • Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. 
  • Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 
  • Erasure:  You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability:  You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection:  You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint:  You have the right to lodge a complaint about Finisterra’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Finisterra and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Finisterra in the U.S. and will be hosted on U.S. servers, and you authorize Finisterra to transfer, store and process your information to and in the U.S., and possibly other countries.

Contact Information:

If you have any questions or comments about this Privacy Policy or the ways in which we collect and use your Personal Data, please do not hesitate to contact us at legal@finisterra.ai