Website Privacy Statement

We respect your concerns about privacy and the use of your “Personal Information,” which refers to information that, either by itself or in combination with other information, can be used to directly identify an individual. For the purpose of this privacy statement, the “Company”, “we” and “us” refer to FinQuery, LLC and its affiliates, as the context requires; a data controller or a business (“Controller”) is a party that sets out the purposes and means of processing of Personal Information. Data processor or a Service Provider/Contractor/Third Party (“Processor” or “Third Party”) is a party that processes Personal Information on the Controller’s behalf. If you have any questions, please contact us at privacy@finquery.com.

We provide businesses (“Customers”) with subscriptions to a variety of proprietary software-as-a-service applications designed to provide visibility into areas where Customers spend the most including, without limitation, FinQuery, LeaseQuery, LeaseGuru, and LeaseQuery for NetSuite (the “Software”). We also maintain public websites under the domain name www.finquery.com, www.stackshine.io, and www.materialaccounting.com (collectively, the “Public Websites”). Individuals accessing our Public Websites are referred to in this privacy statement as “Visitors.”

Users accessing our Software on behalf of Customers (“Users”) do so only on behalf of the businesses that have contractually agreed to the terms and conditions applicable to the applicable Software. Where the Company processes the Personal Information of or related to Users of the Software, we act as a Processor and the Customer is the Controller of Personal Information. In this case, the processing of Personal Information and use by Customer’s Users is subject to the terms of the agreement between the Company and the Customer, which govern in the event of any conflict between those terms and this Privacy Statement.

This privacy statement applies to FinQuery’s processing of Personal Information; provided, however, that with respect to any conflict between this privacy statement and the terms of any product-specific privacy statement, the terms of such product-specific privacy statement shall govern. This privacy statement does not apply to FinQuery employees, contractors or job applicants, or to information relating to such persons, except for those residing in California (please see below). FinQuery, LLC acts as the controller of Visitor’s Personal Information as described in this privacy statement. This Privacy Statement is intended to inform you about how we collect, use, disclose, and store Personal Information in our role as Controller where: 1) a Visitor visits the Public Websites 2) a party registers or attends an event we host, including webinars or conferences 3) a Visitor provides us with Personal Information in a web form, chatbot, or for purposes; 4) a User enters Personal Information into the Software. If you provide us, our service providers or our affiliates with any Personal Information relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement. Select one of the links below to jump to view the relevant section:

Personal Information We Collect and Sources of Information

We may collect the following types of personal information from the following sources:

• Information About Visitors and Prospective Clients. Through our Public Websites, if voluntarily supplied to us by the Visitor, including that provided through the use of any chatbots or web forms, we may collect the Visitor’s name and business contact information, including telephone number, email address, postal address and place of employment. As permitted by law, third party partners may also provide us with contact information of representatives of prospective clients.
• User Information. Through our Software, we collect business contact information about our Customers’ Users, including their business email address (which is required to be used as the User’s username for the Software) and, at their election, their name, business telephone number and business postal address. We also collect commercial information, including records of the purchased Software and, Personal Information of the designated contacts for the Customer (including business phone numbers and business email).
• Session Information. Through our Public Websites and Software, we may collect information about the Visitor’s or User’s activities, interactions, preferences, transactional information and other computer and connection information (such as IP address, user-agent information, and device information) relating to the Visitor’s use of our Public Website (which may include the website from which the visitor navigates to our Public Website) or the User’s use of our Software. This information may be collected using log files, session recordings, cookies, trackers, and similar technologies. We may use this session information as collected to draw inferences related to a Visitor’s activities, preferences and us of the Websites and Software.
• Information from Customers’ Workforce. For Customers using Saas Spend Management Software, we collect information pertaining to the Customers’ workforce. This includes, for applicable Customers, individual employees’ usage data, IP addresses, business contact information, profile pictures, and, where permission is granted, browser history, and user interactions such as the pages and files viewed, website and webpage interactions.
• Source Document Data. Relevant terms or provisions of our Customers’ leases or the other source documents may be entered into the Software in the form of records. At the option of the customer, a copy of the entire source document may also be uploaded into the Software and linked to the relevant record. These source documents may contain Personal Information, such as names, titles, and business contact information for, as examples, signatories or required recipients of legal notices.
• Correspondence and Survey Data. We may collect and retain records of any correspondence we have with Visitors and Users. When you participate in a survey, we collect Personal Information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use and disclosure of your Personal Information.
• Information from Third Parties. If Personal Information has been collected through your use of the Public Websites or use of the Software, the Personal information, as stored in our customer relationship management service provider, may be supplemented or updated to ensure it is accurate and up to date, and for the purpose for which it was originally collected. This Personal Information may be combined with non-Personal Information related to a Customer’s or Visitor’s organization’s name, structure, industry and similar attributes through the use of third parties’ data sets, for the purpose of supplementing or updating your Personal Information we already hold.
• Social Media. When you interact with our Public Websites through various social media platforms, such as when you click on the social media icon on the Public Websites, follow us on a social media site, or post a comment to one of our pages, we may receive information from the social network such as your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. The data we receive complies with your privacy settings with the social media platform. We use this information to operate, maintain and provide to you the features and functionality of the Public Websites, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

We do not generally collect sensitive Personal Information other than as may be necessary to collect payment from our Customers purchasing the Software. Unless we specifically request such sensitive information from you, we ask that you not send it to us or disclose any sensitive personal information to us.

The purposes for which we process Personal Information, to the extent applicable, are as follows: (1) in connection with engaging with or performing our contracts with our Customers; (2) in connection with complying with our legal obligations; (3) in pursuit of our legitimate business interests, such as, without limitation, the operation of our business, sales and marketing, prevention of fraud, and security of the Software, and (4) compliance with our policies and legal obligations.

How We Use the Personal Information We Obtain

We may use the Personal Information we collect about Visitors and Users on our Public Websites and our Software:

• To improve and personalize their experience when they use our Public Websites;
• To improve our products and services and for the development of future products and services;
• For internal record keeping, administration of records and statistical analysis;
• For compliance with applicable laws and/or regulations or as otherwise required or permitted by applicable laws and/or regulations; and
• For purposes of maintaining the security and integrity of our Public Websites and Software.

In addition, we may use Personal Information about Visitors of our Public Websites and/or representatives of prospective Customers:

• To contact them regarding any inquiry they make or to fulfill a request, such as a request for a demo or information about our Software or related services;
• To share with them an e-newsletter, blog entry or any other updates, communications or publications; and
• For direct marketing purposes (see “Direct Marketing” below).

We may also use Personal Information about Users of our Software:

• In connection with the performance of our services by, for example, verifying login credentials, delivering reminders of relevant days, monitoring compliance with the terms of the Customer’s subscription, maintaining and providing our Customers with logs of changes to records in the Software, providing support services, and informing Users of new features, functionalities or services; and
• To otherwise manage our business, for example, for billing purposes and to research user demographics and behavior to better understand and serve our Customers.

Disclosures of the Personal Information We Collect

We may disclose Personal Information as follows:

• With respect to Users, to our Customers on whose behalf the User accesses our Software;
• To our affiliates;
• To third parties engaged to help us run our business. These types of third parties may include service providers retained to perform functions on our behalf or to provide services to us, including (without limitation) providers of administrative, infrastructure or other support services. These third parties may or may not be located within the United States. Portions of our services may be provided by organizations or individuals with which FinQuery has a contractual relationship, including subcontractors, and, accordingly, your Personal Information may be disclosed to them;
• To referral sources. If you are refrred by a third party to FinQuery for our services, we may share information with such third party in accordance with our business relationship with you and that third party;
• In response to a court order or a request for cooperation or other inquiry from a regulatory, law enforcement or other government agency;
• To establish or exercise our legal rights, to defend legal claims, or as otherwise required or permitted by applicable laws and/or regulations;
• When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing, or compliance with our policies; and
• To acquirors and investors, and, subject to local legal requirements, prospective purchasers in the event that FinQuery disposes of, or considers the disposition of, any of its business or assets.

We do not make a practice of sharing, trading or renting your Personal Information to others in ways that differ from what is disclosed within this policy, agreed to contractually by our Customers or otherwise with their permission; provided, if you are referred by a third party to FinQuery for our services, we may share information with such third party in accordance with our business relationship with you and that third party.

Retention

We retain Personal Information for the minimum time necessary for the purpose for which it was collected, in accordance with our internal retention and archival/backup policies and standards, or as otherwise required or permitted by applicable law. In determining how long we retain Personal Information, we consider the basis of the amount, nature and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

Direct Marketing

We may use your Personal Information to provide you with direct marketing information about our products and services as well as those of our affiliates and third parties, and we may permit those affiliates or other third parties to send their own direct marketing to you. Our direct marketing may be by email, telephone, text or such other methods as may become relevant.

We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

Commitment to Security

We take efforts to protect the security and privacy of the information we receive via our websites. We maintain safeguards designed to protect the Personal Information you provide via our website against unauthorized access, use and disclosure. For more information, please click here.

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, may be regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.

Please remember that communications over the internet such as emails are not secure, and like all website operators, we cannot guarantee the security of any data transmitted through our website.

Transfers

Personal Information subject to this privacy statement may be transferred to the U.S from other countries. To the extent applicable, we support requests to document processing instructions for international transfers as needed, including requests to incorporate the E.U. Standard Contractual Clauses and the U.K. IDTA. Contact us at privacy@finquery.com for more information.

Cookies

Cookies are small text files that our website places on your computer’s hard drive. If your browser is configured to accept cookies, then your browser adds the text in a small file. We do not use cookies to read any other information on your computer’s hard drive. We use cookie technology to authenticate your access to various areas of our websites, understand your interests, help analyze web traffic and tailor content to your preferences. You can configure your browser to refuse cookies, or to warn you before a cookie is placed. If you disable certain cookies, you may not be able to use the full array of features available on our website.

We may include web beacons or transparent GIF files on our websites and messages, which we would use in conjunction with cookies to help us manage our online advertising and measure its effectiveness, identify our users, and analyze traffic. Web beacons may also assist us with understanding which advertisements are most effective by notifying us if webpages, emails or ads have been viewed or clicked.

We may also use other technologies similar to cookies and web beacons such as tags, scripts, and pixels. These technologies are used for similar purposes as cookies and web beacons. We and our third-party partners may also use these technologies to provide certain features on our website, to display advertising based on your web browsing activities, and/or to store content information and preferences. Various browsers may offer their own management tools for removing these technologies.

Analytics

Our website uses Google analytics, a web analytics service provided by Google, Inc. (“Google”). Google analytics uses its own cookies to help us analyze how you and other users use our website. The information generated by the cookie about your use of our website (which may include your IP address, the internet browser and language you use, preferences, the date and hour of your access to the web page and the websites you access after visiting our website) will be transmitted to and stored by Google.

To opt out of being tracked by Google Analytics, visit:

https://tools.google.com/dlpage/gaoptout/

Advertising Cookies

Our Public Websites may use cookies and other tracking technologies so that we can provide advertising or other content to you on our Public Websites or on other sites. We may partner with third-party ad networks to either display advertising on our website or to manage our advertising on other sites. These ad-network partners use data technologies to collect information about your activities on our Public Websites and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may be able to opt-out by visiting:

http://preferences-mgr.truste.com/

http://www.networkadvertising.org/managing/opt_out.asp

http://optout.aboutads.info/?c=2&lang=EN

http://www.youronlinechoices.com/uk/your-ad-choices

These websites and third-party ad networks are not controlled by FinQuery. Please note this does not opt you out of being served advertising generally; you will continue to receive generic ads that are not based on your specific interests.

Blocking Cookies via “Do Not Track” or “Global Privacy Controls”

If you delete or block cookies, some of the features on our website may not function properly. Some browsers have a
“do not track” feature that allows you to notify websites that do not want to have your online activities tracked or a
“Global Privacy Control” feature that allows you notify websites of your internet browsing preference, including the
right not have your Personal Information shared or sold. We comply with applicable law regarding Visitors using any
“do not track” or “Global Privacy Control” features.

External Links

FinQuery may provide links on our website to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects Personal Information. This policy applies solely to information collected by us. You should read any other applicable privacy and cookies policies carefully before accessing and using such other websites.

Children

Our website is not intended for use by children. We do not solicit or knowingly accept any Personal Information from persons under the age of 18. Please do not use our website if you are under the age of 18. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@finquery.com, and we will promptly take steps to delete such information.

Privacy Requests

To the extent allowed by applicable law, you may (1) request access to the Personal Information we maintain about you, (2) request to update and correct inaccuracies in your Personal Information, (3) request to restrict or object to the processing of your Personal Information, (4) request to have Personal Information deleted, (5) request that we transmit Personal Information to another company; and (6) lodge a complaint with a supervisory authority. To the extent we have previously obtained your consent regarding the processing of your Personal Information, you may have a right to withdraw such consent at any time and free of charge. In such case, we will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Updates

We may change this policy from time to time by updating this page. We will not necessarily bring changes or updates to your attention, so please revisit this page periodically to re-read this policy and to ensure you are aware of any changes when you visit the website.

Additional Notice for California, Virginia, Colorado, and Connecticut Residents

This section of our Privacy Statement applies solely to California, Virginia, Colorado, and Connecticut residents.

Information We Collect from Residents in the above states. We describe the Personal Information we have collected in the twelve (12) months preceding the effective date of this Privacy Statement in the section titled, “Personal Information We Collect” The information we have obtained includes the following:

1. Identifiers such as name, postal address, email address, telephone number, IP address, online identifier, account name, and other similar identifiers;
2. Commercial information, such as records of products or services considered;
3. Internet or other electronic network activity information described in “Session Information,” “Cookies”, and “Analytics” above, including browsing history, search history, and information regarding interactions with FinQuery websites, applications, or advertisements;
4. Financial information;
5. Geolocation data;
6. In the case of Customers or Users, audio information, such as call recordings (you will be notified at the beginning of a call if recording is occurring);
7. Professional or employment-related information, such as the company you work for; and
8. Inferences drawn from the Personal Information listed above, to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the above categories of Personal Information either directly from you, automatically through your use of our Public Websites, or from third party partners who provide us with information.

Disclosure of Information. Within the last 12 months, we have disclosed the information identified in all of the above categories (1)-(8) for a business purpose, including to our affiliates, service providers, and business partners. To learn more about the categories of third parties with whom we share such information, please see the section of this privacy statement titled “Disclosures of Personal Information”.

Disclosures regarding “Sale” of Personal Information. We do not sell Personal Information for monetary consideration. We do share Personal Information for other benefits, for example, those as defined by Cal. Civ. Code 1798.140(ad)(2). Like many companies, our website uses cookies and similar technologies as described in the “Cookies” section above. You may opt out of data sharing via cookies and similar technologies on our site at any time – click here.

Privacy Rights

If you are a resident or authorized agent for a resident in any of the above states, you may request that we:

• Disclose to you the Personal Information we have collected about you, why we collected this information, and the categories of third parties with which we shared it.
• Delete certain Personal Information we have collected from you and coordinate with any of our service
  providers to ensure such data is deleted by them as well.
• Correct any Personal Information we have collected about you, taking into account the nature of the Personal
  Information as well as the purpose for processing the Personal Information,
• Opt-out of our sharing or selling of Personal Information for use in cross-contextual behavioral advertising
  or targeted advertising or for profiling in furtherance of decision-making that would have legal or other
  similarly significant effects.
• Restrict or limit our processing or sharing sensitive Personal Information.
• Receive your Personal Information in a structured, machine-readable format and have it transferred to another
  controller, where the Personal Information is processed by automated means and that the processing is based
  on your consent, on a contract which you are a party to, or on pre-contractual obligations thereof.
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal
  effects.

Residents in these states have the right to exercise of any of the above rights without discrimination, and we will not discriminate against you because of your exercise of any of the above rights. Please note that, as required by applicable law, we may take steps to verify your identity by contacting you at the email address or phone number we have on file (and may require supporting documentation) before acting on your request to exercise any of the above rights. We may limit our response to your exercise of the above rights as permitted under applicable law. To request to exercise these rights, click here, call 1-866-486-5489, or contact us at privacy@finquery.com.

If we decline to honor one of the above requests, you may have the ability to appeal our decision. To do so, please contact privacy@finquery.com. If we do not take action within the 45-day response period, or in the event of an extension, we will inform you in writing of the reasons for not taking action and provide an explanation of any rights you have to appeal the decision. If you are in Virginia or Connecticut and the appeal is denied, you will be provided with a method through which you may contact the Attorney General of that state to submit a complaint.

Privacy Rights for California Current and Former Employees, Applicants and Independent Contractors. If you are a California resident and are and employee, applicant independent contractor or former applicant, contractor, or employee who resided in California during the tenure of your employment, you may exercise the rights listed above in the Section entitled “California Privacy Rights” by clicking here, calling 1-866-486-5489, or contacting us at privacy@finquery.com. We will provide you with a separate notice of collection at the time of your application, hire, or contract start date.

Additional Notice for Users in the European Economic Area

We are based in the United States, and we process and store information on servers located in the United States. By accessing or using our Software, visiting our Public Websites, or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the United States.

Information We May Collect from Residents. We describe the Personal Information we may collect in this Privacy Statement in the section titled, “Personal Information We Collect.” We do not collect sensitive Personal Information and prohibit such information from being entered into our Software or submitted to our Public Websites. In the event that you do submit such information, it will be processed in the manner described in this Privacy Statement.

Legal Basis for Processing. The legal bases for processing your Personal Information are listed below. We may additionally process Personal Information as necessary to comply with applicable law.

• Access the Personal Information we have collected about you, as well as how long we have stored it, and the basis for such retention.
• Delete your Personal Information.
• Correct any Personal Information we have collected about you for accuracy and completeness,
• Restrict or limit our processing of your Personal Information.
• Restrict or limit our processing or sharing sensitive Personal Information.
• Receive your Personal Information in a commonly readable format and/or have it transferred to a third party at your direction.
• Object to the legitimate interest that serves as the legal basis for processing your Personal Information.
• Object to processing of Personal Information that utilizes automated decision making for direct marketing.

EU/Swiss/UK Representative. If we have processed your Personal Information, you may be entitled to exercise the above-listed rights. For more details on the rights you have with respect to your Personal Information, please refer to the national Data Protection Authority in your country, the European Commission in the EU (https://commission.europa.eu/law_en), the Information Commissioner’s Office (https://ico.org.uk/for-the-public/) or the Federal Data Protection and Information Commission in Switzerland (https://www.edoeb.admin.ch/edoeb/en/home.html). We have appointed DataRep as out Article 27 representative for data subjects located in the European Economic Area, Switzerland, and the United Kingdom.

If you would like to exercise any of the above rights, you can contact our appointed representative by:

• Email: finquery@datarep.com; or
• Online: http://www.datarep.com/finquery

Please ensure that any communications are directed to “DataRep” and not to us directly.

This website privacy statement was last updated on February 8th, 2024.