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LEGAL

Privacy Policy

Effective: 28 August 2026

1. Introduction

Finovis Software Solutions LLC-FZ (“FINOVIS”, “we”, “us” or “our”) respects the privacy of individuals who visit finovis.ai, communicate with FINOVIS or use FINOVIS digital services.

This Privacy Policy explains how FINOVIS collects, uses, discloses, stores and protects personal data in connection with:

  • finovis.ai;

  • communications with FINOVIS;

  • FINOVIS research and editorial activities;

  • the FINOVIS Read-Only App; and

  • other services expressly referring to this Privacy Policy.

FINOVIS seeks to process personal data lawfully, fairly, transparently and only to the extent reasonably necessary for the relevant purpose.

2. Data Controller

The controller responsible for personal data processing covered by this Privacy Policy is:

​

Finovis Software Solutions LLC-FZ
Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates

​

For privacy-related matters:

legal@finovis.ai

​

FINOVIS acts as controller where it determines the purposes and means of processing.

Where a third party independently determines the purposes and means of its own processing, that third party remains responsible for its own processing.

3. Applicable Data Protection Laws

FINOVIS processes personal data in accordance with applicable data-protection laws and regulations, including the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL).

The UAE PDPL applies to the processing activities of FINOVIS to the extent applicable under UAE law.

Depending on the circumstances of a particular processing activity, additional data-protection laws may apply.

Where the EU General Data Protection Regulation (GDPR) or another data-protection regime applies to a particular processing activity, FINOVIS will comply with the applicable requirements to the extent required by law.

Nothing in this Privacy Policy is intended to exclude or restrict mandatory rights available to individuals under applicable data-protection legislation.

4. Personal Data We May Collect

The categories of personal data depend on how an individual interacts with FINOVIS.

 

4.1 Website Visitors

Technical information may include:

  • IP address;

  • browser type;

  • operating system;

  • device information;

  • approximate location derived from IP address;

  • pages visited;

  • referring pages;

  • access times;

  • technical logs; and

  • error information.

FINOVIS does not intentionally use general Website browsing to collect identity documents or comparable KYC documentation.

5. Contact Forms and Direct Communications

Where an individual contacts FINOVIS, FINOVIS may process voluntarily provided information including:

  • name;

  • email address;

  • telephone number;

  • company;

  • job title;

  • country or business location;

  • message content;

  • business enquiry information; and

  • other voluntarily supplied information.

 

Such information may be used to:

  • respond to enquiries;

  • provide requested information;

  • evaluate potential business relationships;

  • communicate concerning FINOVIS services;

  • maintain business records; and

  • take requested steps before entering into a business relationship.

6. LinkedIn and Social Media

FINOVIS may receive communications through LinkedIn or other social-media platforms.

Information voluntarily provided may be used to:

  • respond to enquiries;

  • communicate with the individual;

  • evaluate potential business relationships;

  • maintain business records; and

  • manage potential business contacts.

Relevant information may be entered into HubSpot or another CRM where appropriate and permitted by applicable law.

The social-media provider remains responsible for its own processing on its platform.

7. HubSpot and CRM

FINOVIS may use HubSpot or comparable CRM systems to manage:

  • business contacts;

  • enquiries;

  • lead status;

  • communications;

  • business relationships; and

  • relevant contact history.

FINOVIS may record LinkedIn-originated business enquiries in such systems where appropriate.

FINOVIS does not intentionally use CRM information for purposes incompatible with the purpose for which it was collected.

8. Google Analytics

FINOVIS may use Google Analytics to obtain aggregated statistical information concerning Website usage.

Analytics may be used to understand:

  • Website traffic;

  • page views;

  • traffic sources;

  • general visitor behavior;

  • Website performance; and

  • aggregated usage trends.

Where applicable law requires consent, non-essential analytics technologies will only be activated after the required consent has been obtained.

Google may independently process information in accordance with its own policies.

FINOVIS does not intentionally transfer Google Analytics data to HubSpot for individual marketing profiling.

9. Google reCAPTCHA

FINOVIS may use Google reCAPTCHA to protect Website forms and functionality against spam, abuse and automated attacks.

reCAPTCHA may process technical information concerning the device, browser and interaction with the Website.

Google may independently process information according to its own policies.

10. Wix

The Website may be hosted and operated using Wix technology.

Wix may process information necessary to:

  • host the Website;

  • provide infrastructure;

  • maintain security;

  • process forms;

  • provide Website functionality; and

  • manage consent and related technical functions.

The precise role of Wix may depend on the particular service and processing activity.

11. Cookies

FINOVIS may use cookies and similar technologies for:

  • essential Website functionality;

  • security;

  • analytics;

  • performance measurement; and

  • other purposes described in the Cookie Policy.

Where required, non-essential technologies are activated only following consent.

12. Read-Only App

FINOVIS may provide a Read-Only App allowing users to view selected information from a connected broker.

Depending on the broker connection, the App may display:

  • balance;

  • equity;

  • performance; and

  • charts derived from such information.

The intended refresh interval is approximately five minutes.

13. Broker Data

The Read-Only App is designed to obtain relevant information directly from the connected broker through a broker-provided read-only or investor access mechanism.

FINOVIS does not intend to obtain trading authority through the Read-Only App.

The App does not provide FINOVIS with the ability to:

  • place trades;

  • modify orders;

  • withdraw funds;

  • transfer funds;

  • deposit funds; or

  • otherwise control the underlying broker account.

14. Read-Only Access belonging to Another Person

A user may use read-only access belonging to another person only where the user has been properly authorized by the account holder and/or broker.

The account holder remains responsible for ensuring that such sharing is permitted by the broker.

FINOVIS does not generally determine legal or beneficial ownership of the underlying account.

15. Read-Only Data Minimization

FINOVIS intends to retrieve only information reasonably necessary for the App’s monitoring functionality.

This principally includes:

  • balance;

  • equity;

  • performance; and

  • chart-related information.

FINOVIS does not intend to retrieve unrelated personal information from the broker account.

16. Storage of Read-Only Account Data

FINOVIS does not intend to maintain underlying balance, equity and performance information as a separate permanent long-term customer database.

Technical logs and security records may nevertheless be retained for as long as reasonably necessary for:

  • security;

  • fraud prevention;

  • troubleshooting;

  • service operation;

  • compliance obligations; and

  • legal claims.

17. App Technical Data

FINOVIS may process technical information required for secure operation, including:

  • IP address;

  • device type;

  • operating system;

  • App version;

  • access times;

  • connection status;

  • error logs; and

  • security events.

Such information may be used for security, troubleshooting, service improvement, fraud prevention and operational analysis.

FINOVIS does not intend to use such information for individual investment profiling.

18. Notifications

The Read-Only App may provide notifications concerning:

  • Technical issues;

  • connection interruptions;

  • material performance changes;

  • selected thresholds; or

  • other App-related information.

Notifications are informational only and do not constitute investment advice.

19. Biometric Authentication

Where the Read-Only App supports device-based biometric authentication such as Face ID, Touch ID or comparable Android functionality:

  • biometric verification is performed by the user’s device;

  • FINOVIS does not receive biometric characteristics;

  • FINOVIS does not store fingerprints or facial-recognition templates; and

  • FINOVIS receives only the authentication result necessary for the App to proceed.

20. Device Permissions

The Read-Only App is not intended to require access to:

  • contacts;

  • photographs;

  • camera;

  • microphone;

  • files; or

  • precise GPS location.

Internet/network access may be required for secure communication and account-information retrieval.

21. App Stores

The App may be distributed through official Apple and Google app stores.

The App is intended to be available without a separate purchase, subscription or in-App payment.

App-store providers may independently process information relating to downloads, devices, store accounts and other store activities.

22. Purposes of Processing

FINOVIS may process personal data for:

  1. operating and securing finovis.ai;

  2. responding to enquiries;

  3. managing business relationships;

  4. providing requested services;

  5. operating the Read-Only App;

  6. providing technical support;

  7. security and fraud prevention;

  8. aggregated analytics;

  9. improving products and services;

  10. maintaining appropriate records;

  11. complying with legal obligations;

  12. establishing, exercising or defending legal claims; and

  13. other purposes disclosed at collection or otherwise permitted by law.

23. Legal Bases

Depending on applicable law, FINOVIS may rely on:

  • consent;

  • contract performance;

  • steps requested before entering into a contract;

  • legal obligations;

  • legitimate interests where permitted;

  • vital interests where applicable; and

  • other lawful grounds.

Where processing is based on consent, consent may be withdrawn where permitted by law.

Withdrawal does not affect prior lawful processing.

24. Data Minimization

FINOVIS seeks to collect only information reasonably necessary for the relevant purpose.

FINOVIS does not intentionally collect through ordinary Website use:

  • passport copies;

  • identity documents;

  • national identification numbers;

  • payment-card details; or

  • bank-account information.

Where such information is required by a broker or other provider, it may be collected directly by that provider under its own framework.

25. Service Providers

FINOVIS may disclose personal data to selected providers where reasonably necessary, including:

  • Wix;

  • HubSpot;

  • Google services;

  • cloud infrastructure providers;

  • cybersecurity providers;

  • communications providers; and

  • professional advisers.

FINOVIS seeks appropriate contractual and organizational safeguards where required.

26. No Sale of Personal Data

FINOVIS does not sell personal data to third parties.

FINOVIS does not intend to create or sell personal investment profiles using Website or Read-Only App data.

27. Marketing

FINOVIS may communicate regarding business opportunities, services or relevant commercial matters where legally permitted.

Where consent is legally required for electronic marketing, FINOVIS will obtain the required consent.

Users may request that marketing communications cease.

Operational, security and service communications are not marketing merely because they are electronic.

28. International Transfer

Because FINOVIS and certain service providers operate internationally, personal data may be processed or transferred across national borders, including between the United Arab Emirates and other jurisdictions.

Where applicable law requires safeguards for international transfers, FINOVIS will implement or seek to implement an appropriate lawful transfer mechanism or other legally recognized safeguard.

29. Security

FINOVIS implements reasonable technical and organizational measures intended to protect personal data against:

  • unauthorized access;

  • unauthorized disclosure;

  • alteration;

  • loss;

  • destruction; and

  • misuse.

Measures may include access controls, authentication, encryption where appropriate, secure communications, logging and organizational safeguards.

No Internet-based system can be guaranteed completely secure.

30. Retention

FINOVIS retains personal data only as long as reasonably necessary unless a longer period is required or permitted by law.

Retention may depend on:

  • the nature of the information;

  • the purpose of processing;

  • business relationships;

  • legal obligations;

  • accounting requirements; and

  • legal claims.

There is no universal retention period for every category of data.

31. Data Subject Rights

Subject to applicable law, individuals may have rights including:

  • access;

  • correction;

  • deletion;

  • restriction;

  • objection;

  • withdrawal of consent;

  • portability where applicable; and

  • complaint to a competent authority.

The precise scope depends on applicable law.

32. Exercising Rights

Privacy requests may be submitted to:

legal@finovis.ai

​

FINOVIS may request information reasonably necessary to verify identity or authority.

FINOVIS will respond within the period required by applicable law.

Where required by applicable law, FINOVIS may designate an appropriate data-protection representative or Data Protection Officer and will publish the relevant contact details where required.

33. Another Persons Broker Account

Where the Read-Only App displays information from an account belonging to another person, FINOVIS may rely on the authorization represented by the connecting user.

Requests concerning another person’s account information may need to be addressed to the account holder or broker unless appropriate legal authority is demonstrated.

34. Children

FINOVIS services are not directed to persons under 18.

FINOVIS does not knowingly collect personal data from children through general Website services.

35. Third-Party Websites

Third-party websites and services are governed by their own privacy policies.

FINOVIS is not responsible for their privacy practices or security.

36. Research and Public Content

FINOVIS may publish research papers, insights, articles, charts and other public content.

Such content is generally intended for informational purposes.

Where personal data is published, FINOVIS seeks an appropriate legal basis.

37. AI/ML and Personal Data

The AI/ML permissions contained in the Terms of Use do not authorize the processing of personal data.

In particular, the permission does not cover:

  • customer information;

  • broker information;

  • Read-Only App data;

  • account information;

  • KYC information;

  • contact information; or

  • other non-public personal data.

38. Automated Decision Making

FINOVIS does not intend to use personal data collected through finovis.ai for automated decision-making producing legal or similarly significant effects on individuals.

If such processing is introduced and subject to specific legal requirements, FINOVIS will update this Privacy Policy as appropriate.

39. Privacy by Design

FINOVIS seeks to incorporate privacy and security considerations into its digital services.

The Read-Only App is designed around:

  • direct broker connections;

  • read-only access;

  • limited data retrieval;

  • no trading authority;

  • no withdrawal authority;

  • no deposit functionality;

  • no precise location tracking; and

  • limited retention of underlying account-performance data.

40. Data Breaches

Where FINOVIS becomes aware of a personal-data breach requiring notification under applicable law, FINOVIS will take reasonable steps to investigate, contain and remediate the incident and make legally required notifications.

41. Changes

FINOVIS may update this Privacy Policy from time to time.

The updated version will be published on finovis.ai with its effective date.

FINOVIS does not undertake to provide individual email notification of every change unless required by applicable law.

42. Contact

For privacy and data-protection matters:

legal@finovis.ai

​

For general enquiries:

contact@finovis.ai

© 2026 Finovis Software Solutions LLC-FZ. All rights reserved.

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