Finturu LLC, together with its subsidiaries, affiliates, and related entities (collectively referred to as "Finturu", "Finturu Group", "we", "our", or "us"), is committed to protecting the privacy and security of personal information entrusted to us by merchants, users, partners, service providers, and other stakeholders.
This Privacy Policy describes how Finturu collects, processes, uses, shares, and safeguards personal information when individuals interact with Finturu's services, platforms, infrastructure, websites, applications, and associated technologies.
Finturu operates a global commerce infrastructure platform that enables businesses to participate in international trade through integrated financial and operational services, including payment processing, merchant enablement technologies, settlement infrastructure, logistics integrations, and related digital services.
This Privacy Policy applies to all personal information processed by Finturu in connection with:
Depending on the context, Finturu may act either as:
In order to provide its services and comply with legal and regulatory obligations, Finturu may collect and process different categories of personal information. The type of information collected depends on the nature of the relationship with the individual and the services being provided.
Identification Information
Finturu may collect personal identifiers necessary to verify identity and establish commercial or contractual relationships. Such information may include an individual's name, date of birth, nationality, identification numbers, government-issued identification documents, tax identification numbers, or other identifiers required for regulatory compliance.
This information is typically collected during onboarding procedures, identity verification processes, or compliance checks associated with anti-money laundering and financial regulations.
Contact Information
To facilitate communication and service delivery, Finturu may collect contact details such as email addresses, telephone numbers, billing addresses, and mailing addresses.
These contact details may be used to communicate operational notifications, account updates, service information, and legally required communications.
Financial and Transactional Information
Where Finturu provides payment-related services, it may process financial or transactional information necessary to facilitate transactions and settlements.
This may include transaction history, payment instructions, merchant identifiers, settlement information, payout details, or other financial data required to process payments or reconcile accounts.
Sensitive payment information, such as card details, is processed through secure and compliant payment infrastructure providers operating under applicable security standards.
Technical and Device Information
When users interact with Finturu's platforms, websites, or digital services, certain technical data may be collected automatically. This may include internet protocol (IP) addresses, browser information, device identifiers, operating system details, timestamps of activity, and system logs.
This information supports system security, fraud prevention, operational monitoring, and service improvements.
Device Intelligence and Behavioral Data
As part of its fraud prevention and risk management activities, Finturu may collect device intelligence signals and behavioral data, including device identifiers, device configuration data, and behavioral biometric indicators such as typing, touch, or navigation patterns observed during onboarding and use of the Services.
This information is processed through Finturu's risk management partners and is used to assess the likelihood of fraudulent or unauthorized activity. It is not used to identify an individual outside of this context and is retained only for as long as necessary for these purposes.
Business and Corporate Information
For merchants, partners, and corporate clients, Finturu may collect business-related information necessary to establish commercial relationships.
This may include corporate registration data, beneficial ownership information, business activity descriptions, website domains, operational details, or other information required for regulatory and onboarding purposes.
Compliance and Risk Data
As part of its compliance obligations, Finturu may collect or generate information related to regulatory screening and risk management activities. This may include sanctions screening results, transaction monitoring indicators, fraud prevention signals, and other data used to assess risk and comply with financial regulations.
Finturu processes personal information for legitimate business purposes consistent with the services it provides and its legal obligations.
Personal data may be used for purposes including the establishment and maintenance of commercial relationships, the provision and improvement of services, regulatory compliance, risk management, operational administration, and communication with stakeholders.
In particular, Finturu processes personal information to:
Where personal information is used for marketing communications, Finturu will obtain consent where required by applicable law.
Finturu may share personal information with certain categories of third parties when necessary for operational, legal, or regulatory purposes.
Such disclosures occur only where appropriate safeguards and contractual protections are in place.
Personal information may be shared with:
Financial Infrastructure Partners
To facilitate payment services and financial operations, Finturu may share information with financial institutions, payment processors, card networks, settlement partners, and banking infrastructure providers involved in transaction processing.
Some Financial Infrastructure Partners Act as Independent Data Controllers
For certain services, a financial infrastructure partner does not merely process personal information on Finturu's instructions; it establishes its own direct account relationship with the User and processes the User's personal information under its own privacy policy, as an independent data controller in its own right. Where this is the case, that partner's privacy policy governs its own collection, use, and disclosure of the User's personal information for those services, in addition to this Privacy Policy. Finturu will identify the applicable partner and a link to its privacy policy within the relevant onboarding or account flow.
Digital Wallet Providers
Where Finturu makes a debit card available, Users may provision an eligible card to a supported digital wallet, such as Apple Pay, or other digital wallet providers made available by Finturu from time to time. Provisioning a card involves sharing account, card, and provisioning-related information with the applicable digital wallet provider, Finturu's card issuing bank, and its program manager, as necessary to process the provisioning request.
Where required by the digital wallet provider, such information is shared only in de-identified or aggregated form, and the provider is contractually prohibited from using it to re-identify the User outside of the provisioning process. A User's use of the digital wallet application itself is governed by that provider's own privacy policy, which is not controlled by Finturu.
Operational Service Providers
Finturu relies on specialized third-party service providers that support operational activities such as cloud hosting, compliance monitoring, identity verification, fraud detection, analytics, and communication services.
These providers process personal information under strict contractual obligations and are permitted to use the information only for the purposes specified by Finturu.
Risk Management and Fraud Prevention Partners
Finturu shares onboarding, identity, device, and transaction information with third-party risk management providers to assess and score the likelihood of fraudulent or unauthorized activity, both at onboarding and on an ongoing basis. This may include the use of automated tools, including artificial-intelligence-based risk-scoring models, to flag, restrict, or hold an account or transaction, as further described in Finturu's Terms and Conditions. Where such an automated determination produces a legal or similarly significant effect on an individual, that individual may request human review by contacting compliance@finturu.com.
Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Screening Partners
Finturu shares identity, business, and beneficial ownership information with third-party providers that perform sanctions screening, adverse media screening, politically exposed person (PEP) screening, and related anti-money laundering and counter-terrorism financing checks, in order to comply with Finturu's regulatory obligations as a registered Money Services Business.
Regulatory Authorities and Legal Obligations
Finturu may disclose personal information to governmental authorities, regulators, courts, or law enforcement agencies where required by applicable law, regulation, or legal process.
Corporate Transactions
In the event of a corporate transaction such as a merger, acquisition, financing event, restructuring, or sale of assets, personal information may be transferred as part of the transaction, subject to appropriate confidentiality protections.
Finturu does not sell personal information to third parties.
Personal information may be shared with non-affiliated service providers only when necessary to support Finturu's operations, provide services, or comply with legal obligations.
Where personal information is used for marketing or promotional communications, individuals will have the ability to opt out of such communications through mechanisms such as unsubscribe links, account settings, or direct requests submitted to Finturu.
Operational communications necessary for the provision of services may continue to be sent even if marketing communications are declined.
Where required by law, Finturu obtains consent from individuals prior to processing personal information for specific purposes, including certain marketing communications.
Consent may be obtained through digital acceptance mechanisms, onboarding processes, or other authorized means.
Individuals may withdraw their consent at any time by contacting Finturu or by using the opt-out mechanisms available in communications.
Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal.
Finturu maintains a comprehensive security program designed to protect personal information against unauthorized access, misuse, loss, or alteration.
Security measures implemented by Finturu include administrative, technical, and organizational safeguards designed to meet industry standards.
These measures may include encryption of sensitive data during transmission, restricted access controls based on operational roles, system monitoring and logging, vendor security assessments, and employee training programs related to data protection.
Finturu periodically reviews and updates its security practices to maintain appropriate levels of protection for the personal information it processes.
Because Finturu operates globally, personal information may be transferred across international borders, including to jurisdictions where Finturu or its service providers operate infrastructure.
When such transfers occur, Finturu implements safeguards designed to ensure that personal information remains protected in accordance with applicable data protection standards.
Finturu retains personal information only for the period necessary to fulfill the purposes for which it was collected, including the provision of services, compliance with legal obligations, dispute resolution, and enforcement of contractual rights.
Certain financial or regulatory requirements may require retention of records for extended periods consistent with applicable laws.
Individuals may have rights regarding their personal information depending on the jurisdiction in which they reside.
For individuals located in Colombia, these rights (the right of Habeas Data) include, without limitation, the right to:
For individuals located in other jurisdictions, applicable rights may vary and may include the ability to access personal information held by Finturu, request correction of inaccurate data, request deletion of personal information where permitted by law, or object to certain types of processing.
Requests related to personal data may be submitted to:
privacy@finturu.com
Finturu will review and respond to such requests in accordance with applicable legal requirements.
Where Finturu processes personal information on behalf of a merchant, partner, or financial institution that determines the purposes and means of such processing (each, an "Ally"), Finturu acts as a Data Processor rather than a Data Controller. This Section sets out Finturu's obligations in that capacity.
Processing Instructions.
Finturu will process personal information only for the purposes set out in the applicable agreement with the Ally and in accordance with the Ally's documented instructions. If Finturu considers that an instruction infringes applicable data protection law, it will promptly inform the Ally.
Confidentiality and Authorized Personnel.
Finturu will maintain the confidentiality of personal information processed on behalf of an Ally, including after the end of the relevant engagement, and will ensure that personnel authorized to process such information are subject to confidentiality obligations and appropriate training.
Sub-processors.
Finturu may engage sub-processors to support the processing of personal information on behalf of an Ally, provided that each sub-processor is bound by data protection obligations substantially equivalent to those set out in this Section.
Security Breach Notification.
Finturu will notify the affected Ally without undue delay after becoming aware of a personal data security breach affecting information processed on its behalf. Where available, such notification will include, at a minimum: (a) a description of the nature of the breach, including, where possible, the categories and approximate number of data subjects and records affected; (b) contact details of a point of contact for further information; (c) a description of the likely consequences of the breach; and (d) a description of the measures taken or proposed to address the breach, including measures to mitigate its possible adverse effects. Where this information cannot be provided at once, it will be provided in phases without undue delay.
Assistance with Data Subject Rights.
Finturu will assist the Ally, as reasonably necessary, in responding to requests from data subjects seeking to exercise their rights of access, rectification, deletion, or objection. If a data subject submits such a request directly to Finturu regarding information processed on behalf of an Ally, Finturu will inform the Ally and will not respond to or act on the request directly, except as required by law.
Data Protection Officer.
Finturu has designated a Data Protection contact, reachable at privacy@finturu.com, responsible for addressing inquiries related to Finturu's role as a Data Processor under this Section.
Return or Deletion of Data.
Upon termination of the relevant engagement, Finturu will, at the Ally's instruction, return or delete the personal information processed on its behalf, except to the extent Finturu is required to retain a copy to comply with applicable legal or regulatory obligations.
Finturu may update this Privacy Policy periodically to reflect changes in legal requirements, business operations, or technological developments.
When material changes are made, Finturu will provide notice through appropriate communication channels, including website updates or direct notifications where applicable.
The updated version of the policy will include the effective revision date.
Finturu LLC and its subsidiaries and affiliates (collectively, "Finturu Group") maintain internal governance structures designed to ensure compliance with applicable privacy, data protection, and financial regulatory requirements.
Oversight of data protection practices is coordinated through Finturu's internal privacy and compliance functions, which are responsible for monitoring adherence to this Privacy Policy, applicable regulatory frameworks, and internal security standards.
Individuals who wish to exercise their data protection rights, submit privacy inquiries, report concerns, or request additional information regarding the processing of personal data may contact Finturu through the designated privacy communication channels.
Requests related to personal data, including access, correction, deletion, or objections to processing, may be submitted to:
privacy@finturu.com
All requests will be reviewed and processed in accordance with applicable data protection regulations and internal compliance procedures.
Questions related to Finturu's privacy practices, security safeguards, or regulatory compliance may be directed to the Finturu privacy and compliance team at:
compliance@finturu.com
Finturu will review such inquiries and respond within a reasonable timeframe consistent with applicable regulatory obligations.