Financial Literacy International, Inc
Financial Literacy International, Inc (FLI) Commits to Protecting Your Privacy
FLI, Inc. (the “Company”, “We”, “Our”) is committed to protecting the privacy of our users (“you”) and being a proactive advocate for consumer protection.
Key Commitments
We believe the most important measure of consumer protection is also the simplest – asking ourselves how we would want to be treated as customers. With this overall philosophy in mind, our data privacy policy is based on three simple commitments to our users:
How We Collect Data
We collect information from our users in two ways:
How We Use Your Data
We use the information we collect in our products in several ways:
Data Security and Loss Prevention
Our solutions incorporate a wide range of best-in-class security and data protection measures designed to secure your personal information from unauthorized access, alteration, disclosure, and data loss. All information you provide to us is encrypted and protected behind multiple layers of security. Your data is also protected from data loss and data corruption by industry-standard technologies and processes.
Our users also play a key role in the security of their own personal information. We encourage users to avoid passcodes that are easy to guess, and to keep their passcodes confidential at all times. Sharing passcodes with others can lead to compromised data.
While we do our best to protect your personal information using industry-standard security technology and processes, we cannot guarantee the security of your personal information and are not responsible for the circumvention of any privacy settings or security measures we provide.
In the unlikely event of a data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so, providing details of the breach, the likely consequences, and the measures being taken to mitigate any adverse effects.
Sharing General and Aggregate Data
When users enter their user ID and agree to allow the franchise to view their records, that franchise and its affiliates will be able to view aggregated information about the group through the FLI portal dashboard for monitoring and evaluation purposes. Franchises with registered groups and accounts on the portal dashboard will only have permission to view specific types of information about your group. Such information includes group transactions, saving and loan history, gender, age, education profile, as well as activity levels.
No person or organization will ever be able to access or view user data through the FLI portal unless they are an official franchise or affiliate of FLI with a verified account. Each portal’s user account will only be able to view data for the groups they support within a given franchise project/program and country.
We engage with various third-party service providers to perform certain processing activities on our behalf. These providers include cloud hosting services, customer support services, and analytics tools. All third-party service providers are contractually obligated to protect your data as stipulated by this privacy policy and are only permitted to process your personal data for specified purposes and in accordance with our instructions.
Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Aggregated data shared with franchises and/or their affiliates will never identify, reveal, or expose the private information of any individual user or group of users in any way without their explicit consent.
Lastly, as a thought leader in our industry, we may at times also share broad general trends and insights based on aggregate data from our systems, in the public domain in the form of blogs or news articles. Such data will never identify, reveal, or expose the private information of any individual user.
Accessing, Correcting, or Deleting Your Personal Data
You are welcome to review and change your personal information at any time by logging in and visiting your personal profile page. You can remove any personal information that you have provided to us at any time, including deleting your user account if desired. Please note that to ensure the data integrity and accuracy of group account financial records, the history of your previous individual transactions will remain viewable in the historical records of savings groups that you were a member of until the end of the current cycle. Your account information and profile will be removed from all future cycles conducted by your savings group. Groups and members may request for their FLI account to be deleted. Please see the detailed steps and implications in the “Data Deletion” section below.
Data Deletion
FLI aims to only retain data necessary to support the effective use of the FLI app and to tailor user experiences or assistance required from our support team. The need to retain data varies widely with the type of data and the purpose for which it was collected. FLI strives to ensure that data is only retained for the period necessary to fulfill the purpose for which it was collected and is deleted from our records when no longer required for their intended purpose.
The type of data we consider necessary to retain, and eventually delete, includes all data collected by the FLI app and is stored on FLI owned or leased systems and media, regardless of location. This applies to data directly collected from users when provided to us via the FLI app (such as user name, phone number, and encrypted passcode), as well as data shared automatically with us when using the app (such as usage, device, location, and stored information).
Account data retained and duration: User account data linked to particular projects run by our franchises will be retained for the lifetime of those projects by default. Once projects expire, FLI will retain both user-inputted and automatically-generated user data from the FLI app for as long as a group or individual account is actively used, or if the data continues to be deemed necessary by our franchises for reporting, monitoring, and evaluation purposes.
Account data validation: Data validation will be performed by FLI representatives with our franchises.
Account data deletion: FLI intends to uphold each account deletion request for data privacy and minimization purposes while also maintaining the integrity and correctness of the financial history recorded for each savings group. For this reason, all personal and financial information related to a deleted account is permanently deleted from internal systems accessible by end users and external franchises of FLI platform. Information stored within our backup system is only retained for security purposes and to preserve the functioning of financial calculations applied within the FLI app. This data is not accessed by FLI for any reason, including account restoration processes.
Data Storage & Retention
Electronic data is stored and retained in multiple servers on Cloud Platforms and maintained by FLI Engineering team.
FLI aims to avoid duplication in data storage whenever possible. However, there may be instances in which, for programmatic or other business reasons, it is necessary for data to be held in more than one place. This policy applies to all data in FLI’s possession, including duplicate copies of data.
The FLI engineering team is responsible for the technical retention and maintenance of stored data, as well as its deletion. FLI is responsible for account validation and authorizing the process for account deactivation and deletion.
Additional Legal Disclaimers
In full accordance with the above guidelines and policies, please note that we also reserve the legal right to disclose data in the following specifically defined circumstances:
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated. We will also include a direct link to this page from within the user interface of all relevant products.
Contact Information
To ask questions or comment about this privacy policy and our privacy
practices, contact us at: [email protected]
FLI, Inc. (the “Company”, “We”, “Our”) is committed to protecting the privacy of our users (“you”) and being a proactive advocate for consumer protection.
Key Commitments
We believe the most important measure of consumer protection is also the simplest – asking ourselves how we would want to be treated as customers. With this overall philosophy in mind, our data privacy policy is based on three simple commitments to our users:
- We will not disclose, or sell your data outside of the organizational staff and management. Your data belongs to you. We will not share unless otherwise disclosed in this privacy policy.
- We will keep your data secure at all times. We will use the highest industry-standard security technology to protect your data while it is stored on your phone, in transmission over the internet, and on our servers.
- Your data will always be available to you. You will always be able to access your personal data, even if you stop using our products. We will do not charge you to access your own information.
How We Collect Data
We collect information from our users in two ways:
- Directly when you provide it to us. When you create an account in our products, you enter personal information such as your name, phone number, and passcode. This information is used to complete your user profile, send you personalized transaction summaries, and allow you to securely log in and access your private information.
- Automatically as you use our products. When you use our products, we also collect information automatically to personalize your user experience and help us support you proactively when you have questions or problems. This data is kept secure at all times and is never disclosed to third parties. The following information may be collected automatically through the normal usage of our products.
- Usage Information: As you use our products, we may collect details such as network data, time stamps, and usage logs to better understand and support your experience.
- Device Information: We may collect information about your mobile device and internet connection, including the phone’s unique device identifier, IP address, operating system, browser type, mobile network information, and telephone number.
- Location Information: We may collect information about the location of your device when it connects to the internet.
- Stored Information: We may access metadata and other information stored on your phone such as device settings to ensure we support your personal preferences.
How We Use Your Data
We use the information we collect in our products in several ways:
- Help you use the product for its primary purpose.
- Personalize your experience by storing helpful information about your preferences.
- Provide personalized support when you have questions or problems.
- Notify you when updates are available.
- Improve our products by better understanding how people are using them.
Data Security and Loss Prevention
Our solutions incorporate a wide range of best-in-class security and data protection measures designed to secure your personal information from unauthorized access, alteration, disclosure, and data loss. All information you provide to us is encrypted and protected behind multiple layers of security. Your data is also protected from data loss and data corruption by industry-standard technologies and processes.
Our users also play a key role in the security of their own personal information. We encourage users to avoid passcodes that are easy to guess, and to keep their passcodes confidential at all times. Sharing passcodes with others can lead to compromised data.
While we do our best to protect your personal information using industry-standard security technology and processes, we cannot guarantee the security of your personal information and are not responsible for the circumvention of any privacy settings or security measures we provide.
In the unlikely event of a data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so, providing details of the breach, the likely consequences, and the measures being taken to mitigate any adverse effects.
Sharing General and Aggregate Data
When users enter their user ID and agree to allow the franchise to view their records, that franchise and its affiliates will be able to view aggregated information about the group through the FLI portal dashboard for monitoring and evaluation purposes. Franchises with registered groups and accounts on the portal dashboard will only have permission to view specific types of information about your group. Such information includes group transactions, saving and loan history, gender, age, education profile, as well as activity levels.
No person or organization will ever be able to access or view user data through the FLI portal unless they are an official franchise or affiliate of FLI with a verified account. Each portal’s user account will only be able to view data for the groups they support within a given franchise project/program and country.
We engage with various third-party service providers to perform certain processing activities on our behalf. These providers include cloud hosting services, customer support services, and analytics tools. All third-party service providers are contractually obligated to protect your data as stipulated by this privacy policy and are only permitted to process your personal data for specified purposes and in accordance with our instructions.
Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Aggregated data shared with franchises and/or their affiliates will never identify, reveal, or expose the private information of any individual user or group of users in any way without their explicit consent.
Lastly, as a thought leader in our industry, we may at times also share broad general trends and insights based on aggregate data from our systems, in the public domain in the form of blogs or news articles. Such data will never identify, reveal, or expose the private information of any individual user.
Accessing, Correcting, or Deleting Your Personal Data
You are welcome to review and change your personal information at any time by logging in and visiting your personal profile page. You can remove any personal information that you have provided to us at any time, including deleting your user account if desired. Please note that to ensure the data integrity and accuracy of group account financial records, the history of your previous individual transactions will remain viewable in the historical records of savings groups that you were a member of until the end of the current cycle. Your account information and profile will be removed from all future cycles conducted by your savings group. Groups and members may request for their FLI account to be deleted. Please see the detailed steps and implications in the “Data Deletion” section below.
Data Deletion
FLI aims to only retain data necessary to support the effective use of the FLI app and to tailor user experiences or assistance required from our support team. The need to retain data varies widely with the type of data and the purpose for which it was collected. FLI strives to ensure that data is only retained for the period necessary to fulfill the purpose for which it was collected and is deleted from our records when no longer required for their intended purpose.
The type of data we consider necessary to retain, and eventually delete, includes all data collected by the FLI app and is stored on FLI owned or leased systems and media, regardless of location. This applies to data directly collected from users when provided to us via the FLI app (such as user name, phone number, and encrypted passcode), as well as data shared automatically with us when using the app (such as usage, device, location, and stored information).
Account data retained and duration: User account data linked to particular projects run by our franchises will be retained for the lifetime of those projects by default. Once projects expire, FLI will retain both user-inputted and automatically-generated user data from the FLI app for as long as a group or individual account is actively used, or if the data continues to be deemed necessary by our franchises for reporting, monitoring, and evaluation purposes.
Account data validation: Data validation will be performed by FLI representatives with our franchises.
Account data deletion: FLI intends to uphold each account deletion request for data privacy and minimization purposes while also maintaining the integrity and correctness of the financial history recorded for each savings group. For this reason, all personal and financial information related to a deleted account is permanently deleted from internal systems accessible by end users and external franchises of FLI platform. Information stored within our backup system is only retained for security purposes and to preserve the functioning of financial calculations applied within the FLI app. This data is not accessed by FLI for any reason, including account restoration processes.
Data Storage & Retention
Electronic data is stored and retained in multiple servers on Cloud Platforms and maintained by FLI Engineering team.
- (Data backup: This immutable storage, backed up, directly receives data from FLI Mobile Applications. The immutable nature ensures that data remains complete, secure, and auditable.
- Read Model: This normalized data model, processes and stores events from the backups in optimized forms. It allows for faster retrieval for both internal and external users.
- Computed Data Read Model: The FLI portal, the analytics dashboard, showcases advanced analytics and user behaviors. Data undergoes advanced computations to calculate metrics and behaviors, stored in the database.
FLI aims to avoid duplication in data storage whenever possible. However, there may be instances in which, for programmatic or other business reasons, it is necessary for data to be held in more than one place. This policy applies to all data in FLI’s possession, including duplicate copies of data.
The FLI engineering team is responsible for the technical retention and maintenance of stored data, as well as its deletion. FLI is responsible for account validation and authorizing the process for account deactivation and deletion.
Additional Legal Disclaimers
In full accordance with the above guidelines and policies, please note that we also reserve the legal right to disclose data in the following specifically defined circumstances:
- When required by law to comply with a court order or legal process.
- If disclosure is necessary or appropriate to protect the legal rights, property, or safety of our customers, stakeholders, or other key parties, including fraud protection and credit risk reduction.
- To enforce legal rights arising from any contracts or license agreements entered into between FLI and our users.
- Note that third-party service providers under contract with FLI may at times need access to our systems to support our business. These entities are bound by strict contractual obligations to support our data privacy policy, to keep personal information confidential, and to use it only for the purposes for which we engage them in the full support of our users.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated. We will also include a direct link to this page from within the user interface of all relevant products.
Contact Information
To ask questions or comment about this privacy policy and our privacy
practices, contact us at: [email protected]
