Privacy Policy

Privacy Policy 

Last updated: July 22, 2025
 

Owner and Data Controller 

Fintoro Solution, Inc. 
7742 N Kendall Dr, Ste 306 
Miami, FL. 33156 USA 
Owner contact email: hello@fintoro.net 

Type of Data We Collect 

The Owner does not provide a public list of Personal Data types collected. 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or in specific explanatory texts displayed prior to the Data collection. 

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide it may make it impossible for this Website to provide its services. Where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or functioning of the Service. 

Users who are uncertain about which Personal Data is mandatory are encouraged to contact the Owner. 

Any use of cookies—or other tracking tools—by this Website or by the owners of thirdparty services used by this Website serves the purpose of providing the Service requested by the User in addition to any other purposes described in this document and in the Cookie Policy. 

Users are responsible for any thirdparty Personal Data obtained, published, or shared through this Website. 

Mode and Place of Processing the Data 

Methods of Processing 

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. 

Data processing is carried out using computers and/or ITenabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessible to certain categories of persons in charge— involved with the operation of this Website (administration, sales, marketing, legal, system administration)—or external parties (such as thirdparty technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time. 

Place 

Data is processed at the Owner’s operating offices and at any other locations where the parties involved in the processing are situated. 

Depending on the User’s location, Data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. 

Retention Time 

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose for which it has been collected and may be retained for longer due to applicable legal obligations or on the basis of Users’ consent. 

Cookie Policy 

This Website uses trackers (“Cookies”). To learn more, Users may consult the Cookie Policy. 

Further Information for Users in the European Union 

Legal Basis of Processing 

The Owner may process Personal Data relating to Users if one of the following applies: 

• Users have given their consent for one or more specific purposes; 

• provision of Data is necessary for the performance of an agreement with the User and/or for any precontractual obligations thereof; 

• processing is necessary for compliance with a legal obligation to which the Owner is subject; 

• processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner; 

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. 

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Further Information About Retention Time 

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose for which it has been collected and may be retained for longer due to applicable legal obligations or on the basis of Users’ consent. 

Therefore: 

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. 

• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner. 

• The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority. 

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period. 

The Rights of Users Based on the General Data Protection Regulation (GDPR) 

Users may exercise certain rights regarding their Data processed by the Owner. 

In particular, Users have the right to do the following, to the extent permitted by law: 

1. Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. 

1. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. 

1. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing. 

1. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. 

1. Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. 

1. Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner. 

1. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machinereadable format and, if technically feasible, to have it transmitted to another controller without any hindrance. 

1. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. 
   
   

Users are also entitled to learn about the legal basis for Data transfers abroad—including to any international organization governed by public international law or set up by two or more countries, such as the UN—and about the security measures taken by the Owner to safeguard their Data. 

Details About the Right to Object to Processing 

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. 

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

How to Exercise These Rights 

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients. 

Further Information for Users in Switzerland 

This section applies to Users in Switzerland and, for such Users, supersedes any other possibly divergent or conflicting information contained in this Privacy Policy. 

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients (if any), the retention period, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data.” 

The Rights of Users According to the Swiss Federal Act on Data Protection 

Users may exercise certain rights regarding their Data within the limits of law, including the following: 

• Right of access to Personal Data; 

• Right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, or specific disclosures of Personal Data to third parties be prohibited); 

• Right to receive their Personal Data and have it transferred to another controller (data portability); 

• Right to ask for incorrect Personal Data to be corrected. 
  
  
  

How to Exercise These Rights 

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law. 

Further Information for Users in Brazil 

This section of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by the entity running this Website and, if applicable, its parent, subsidiaries, and affiliates (collectively referred to in this section as “we,” “us,” “our”). 

This section applies to all Users in Brazil (Users are referred to below as “you,” “your,” or “yours”) according to the Lei Geral de Proteção de Dados (LGPD). For such Users, it supersedes any other possibly divergent or conflicting information contained in the Privacy Policy. 

This part of the document uses the term “personal information” as it is defined in the LGPD. 

The Grounds on Which We Process Your Personal Information 

We may process your personal information solely if we have a legal basis for such processing. Legal bases include: 

• Your consent to the relevant processing activities; 

• Compliance with a legal or regulatory obligation that lies with us; 

• The carrying out of public policies provided in laws or regulations or based on contracts, agreements, and similar legal instruments; 

• Studies conducted by research entities, preferably carried out on anonymized personal information; 

• The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract; 

• The exercising of our rights in judicial, administrative, or arbitration procedures; 

• Protection of your physical safety or that of a third party; 

• The protection of health—in procedures carried out by health entities or professionals; 

• Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and 

• Credit protection. 

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document. 

Categories of Personal Information Processed 

To learn what categories of your personal information are processed, please refer to the section titled “Detailed information on the processing of Personal Data.” 

Why We Process Your Personal Information 

To learn why we process your personal information, please refer to the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document. 

Your Brazilian Privacy Rights, How to File a Request, and Our Response 

Your Brazilian privacy rights include the right to: 

1. Obtain confirmation of the existence of processing activities on your personal information; 

1. Access your personal information; 

1. Have incomplete, inaccurate, or outdated personal information rectified; 

1. Obtain the anonymization, blocking, or elimination of unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD; 

1. Obtain information on the possibility to provide or deny your consent and the consequences thereof; 

1. Obtain information about the third parties with whom we share your personal information; 

1. Obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded; 

1. Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Article 16 of the LGPD apply; 

1. Revoke your consent at any time; 

1. Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumerprotection bodies; 

1. Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law; 

1. Request clear and adequate information regarding the criteria and procedures used for an automated decision; and 

1. Request the review of decisions made solely on the basis of the automated processing of your personal information that affect your interests. 
   
   

You will never be discriminated against—or otherwise suffer any detriment—for exercising your rights. 

How to File Your Request 

You can file an express request to exercise your rights free of charge at any time by using the contact details provided in this document or via your legal representative. 

How and When We Will Respond to Your Request 

We will strive to respond to your requests promptly. Should it be impossible for us to do so, we will communicate the factual or legal reasons that prevent us from complying. 

In cases where we need additional time, we will inform you of the reason and expected time frame. If we are not processing your personal information, we will indicate, where possible, the entity responsible for such processing. 

Further Information for Users in the United States 

This section integrates with and supplements the information contained in the rest of the Privacy Policy and applies to Users who are residents of certain U.S. states, including but not limited to California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, and Montana. 

The information in this section supersedes any other possibly divergent or conflicting provisions contained in the Privacy Policy. It uses the term Personal Information as defined under applicable U.S. state privacy laws. 

Notice at Collection 

The following Notice at Collection provides timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that information. While the categorization is based primarily on California privacy laws, it can also be helpful for Users in other states. 

ℹ️ For definitions of these concepts, see the “Definitions and Legal References” section of this Privacy Policy. 

To learn more about your rights, please refer to the “Your Privacy Rights Under U.S. State Laws” section below. 

For more details on the collection of Personal Information, please read the section “Detailed Information on the Processing of Personal Data.” 

We do not process your Personal Information for unexpected purposes or for purposes that are not reasonably necessary or compatible with the purposes originally disclosed without your consent. 

Sources of the Personal Information We Collect 

We collect the categories of Personal Information mentioned above, either directly or indirectly, from you when you use this Website. For example, you provide Personal Information directly when you submit requests through forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected. 

Your Privacy Rights Under U.S. State Laws 

You may exercise certain rights regarding your Personal Information. To the extent permitted by applicable law, these rights include: 

1. Right to Know / Access. You have the right to request confirmation of whether we are processing your Personal Information and to access such information. 

1. Right to Correct. You have the right to request correction of inaccurate Personal Information we maintain about you. 

1. Right to Delete. You have the right to request deletion of your Personal Information. 

1. Right to Obtain a Copy / Portability. You have the right to obtain your Personal Information in a portable, usable format. 

1. Right to Opt Out of Sale. You have the right to opt out of the sale of your Personal Information. 

1. Right to NonDiscrimination. We will not discriminate against you for exercising your privacy rights. 
   
   

Additional rights are available to residents of specific states (e.g., opt out of Sharing for crosscontext behavioral advertising in California; opt out of targeted advertising or certain profiling activities in Virginia, Colorado, Connecticut, and other states). Please see your statespecific provisions below for details. 

How to Exercise Your Privacy Rights Under U.S. State Laws 

To exercise these rights, submit your request by contacting us via the contact details provided in this document. We must be able to verify your identity to respond to your request. We will use Personal Information collected from you in connection with your request solely for verification purposes. 

You may also use browserbased optout signals such as the Global Privacy Control (GPC) to opt out of certain dataprocessing activities where legally required. 

How and When We Will Handle Your Request 

We will respond to your request without undue delay and within the time frames required by applicable law. Should we require more time, we will inform you of the reason and extension period in writing. 

We will not charge a fee to process or respond to your request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse to act on the request, explaining the reasons behind our decision. 

Additional Information About Data Collection and Processing 

Legal Action 

The User’s Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. 

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities. 

Additional Information About User’s Personal Data 

In addition to the information contained in this Privacy Policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. 

System Logs and Maintenance 

For operation and maintenance purposes, this Website and any thirdparty services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose. 

Information Not Contained in This Policy 

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document. 

Changes to This Privacy Policy 

The Owner reserves the right to make changes to this Privacy Policy at any time by notifying its Users on this page and possibly within this Website and, as far as technically and legally feasible, sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities carried out on the basis of the User’s consent, the Owner will collect new consent from the User where required. 

Definitions and Legal References 

• Personal Data (or Data) / Personal Information: Any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person. 

• Sensitive Personal Information: Any Personal Information that is not publicly available and reveals information considered sensitive under applicable privacy laws. 

• Usage Data: Information collected automatically through this Website (or thirdparty services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the application) and the details about the path followed within the application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. 

• User: The individual using this Website who, unless otherwise specified, coincides with the Data Subject. 

• Data Subject: The natural person to whom the Personal Data refers. 

• Data Processor (or Processor): The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy. 

• Data Controller (or Owner): The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website. 

• This Website (or this Application): The means by which the Personal Data of the User is collected and processed. 

• Service: The service provided by this Website as described in the relative terms (if available) and on this site/application. 

• Sale: Any exchange of Personal Information by the Owner to a third party for monetary or other valuable consideration, as defined by applicable U.S. privacy law. The exchange of Personal Information with a service provider pursuant to a written contract that meets statutory requirements does not constitute a Sale. 

• Sharing: Any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s Personal Information to a third party for crosscontext behavioral advertising, as defined by California privacy laws. The exchange of Personal Information with a service provider pursuant to a written contract that meets statutory requirements does not constitute Sharing. 

• Targeted Advertising: Displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by applicable U.S. privacy law. 

• European Union (EU): Unless otherwise specified, all references made within this document to the European Union include all current member states of the European Union and the European Economic Area.