Last Updated: October 2, 2025
1. Introduction
This policy applies to all personal data we obtain from:
Information submitted through website forms and interactive functions
Information automatically generated when you use the website
Information submitted when you apply for a job
Information we obtain from third-party service providers or public sources
“Personal data” means any information that can directly or indirectly identify a specific natural person.
If you have a disability, you can request an alternative access format for this policy at privacy@finvia.com.
2. Personal Data We Collect
The categories of personal data we have collected in the past 12 months include:
2.1 Information You Provide Voluntarily
Contact Information: Name, Email, Phone Number, Mailing Address
Employment Information: Job Title, Employer, Social Media Profiles (e.g., LinkedIn)
Job Search and Applicant Tracking Information: Resume, Cover Letter, Interview Materials, Referee Information
Information You Provide Through "Contact Us," Forms, Registration, Uploading Files, or Other Means
2.2 Automatically Collected Information
When you use the website, we automatically collect:
IP Address, Device Type, Operating System, Browser Type
Approximate Geographic Location (Country/Region, City, Time Zone)
Website Usage Logs, Access Timestamps
Data collected by tracking technologies such as cookies, pixel tags, and web beacons
We use cookies (necessary, functional, performance/analytic) to:
Identify your browser
Analyze trends and behaviors
Improve user experience
We use third-party analytics tools such as Google Analytics. Please see our privacy policy for details.
2.3 Information from Third Parties
Publicly available career information obtained from recruitment platforms (such as LinkedIn, Hunt Club)
Compliance, fraud prevention, or identity verification information obtained from third-party service providers
Information obtained from customers, partners, and public databases
3. How We Use Your Personal Data
We may use your personal data for the following purposes:
3.1 Providing and Improving Website Services
Providing, maintaining, operating, and improving the website
Personalizing website content and experience
Website debugging, research, testing, and analysis
3.2 Communicating with You
Responding to your inquiries
Sending FINVIA communications, reminders, or updates (if you consent)
3.3 Recruiting and Applicant Management
For job seekers and candidates, we will use your information to:
Assess your suitability for opportunities at FINVIA or portfolio companies
Invite you to recruitment events
Review and verify qualifications, including background checks (if applicable)
3.4 Security and Compliance
We use data to:
Detect, prevent, or investigate fraud, security incidents, and illegal activities
Comply with legal, regulatory, or court requirements
Enforce our agreement with you
3.5 Other Uses
For internal record management
For aggregation and anonymization for analysis
Any use for which you have given explicit consent
4. Disclosure
We may disclose personal data to:
4.1 Service Providers
Including security, hosting, technology operations, analytics platforms, and recruitment service providers.
4.2 FINVIA Entities
Including companies under FINVIA Family Office GmbH, affiliated funds, and portfolio companies (for talent assessment, etc.).
4.3 Recipients Authorized by You
We will comply when you authorize us to share information.
4.4 Legal or Security Reasons
We may disclose data in the following circumstances:
Legal requirements
Investigating or preventing illegal activities
Protecting the rights or safety of FINVIA, users, or third parties
4.5 Corporate Transactions
In the event of a merger, acquisition, or reorganization, data may be transferred to the successor.
4.6 Anonymous Information
We may share non-personally identifiable statistical data (such as analytical data and trend reports).
5. International Data Transfer
Your data may be transferred to the United States or other countries with varying levels of legal protection. We will use legal data protection measures, such as:
GDPR Standard Contractual Clauses (SCCs)
Data Processing Agreements (DPAs)
Compliant cross-border transfer mechanisms
6. Your Choices, Consent, and Opt-out
You can:
Refuse or withdraw your consent to marketing communications
Manage your cookie preferences
Contact us to exercise your privacy rights
Contact: info@FinGrey.top
7. Data Retention
We will retain your personal data only in the following circumstances:
For the purposes for which it was collected
To comply with legal obligations
Within the applicable statute of limitations
For audit or regulatory requirements
Expired data will be deleted or anonymized.
8. Data Security
We take reasonable technical and organizational measures to protect your data, but absolute security cannot be guaranteed.
9. Children's Privacy
This website is not intended for children under the age of 13, and we do not knowingly collect their data.
10. Third-Party Websites
Our website may contain third-party links. We do not control these websites and are not responsible for their privacy practices. Please read their privacy policies before visiting. 11. Regional Specific Notices
11.1 EU and UK Users (GDPR)
You have the following rights:
Right to access
Right to correction
Right to erasure
Right to restrict processing
Right to data portability
Right to object
Right to withdraw consent
Right to file a complaint with a data regulator
11.2 Chinese Users (Personal Information Protection Law PIPL)
Based on PIPL:
We will process information according to the principle of minimum necessity
Some sharing or transmission requires your "separate consent"
You have the rights to access, correct, erase, and withdraw consent.
11.3 California Residents (CCPA/CPRA)
You have the following rights:
Right to know
Right to access
Right to erasure
Right to correction
Right to opt out of selling/sharing your personal data (we do not sell)
Right to avoid discrimination
We will process a valid request within 45 days.
Contact: info@FinGrey.top
11.4 Nevada Residents
You may choose not to sell your information (we currently do not). Please contact us at info@FinGrey.top.
12. Applicant Tracking Privacy Statement
We may collect applicant information through the FINVIA Atlas system, including:
Name, contact information, work experience
Resume, interview records, assessment results
Referrer information
Background investigation information, if authorized
Uses include:
Assessing job fit
Sharing with FINVIA portfolio companies to facilitate career opportunity matching
Scheduling interviews and responding to inquiries
Conducting statistical analysis and internal management
Complying with legal requirements
You can request the removal of your candidate profile at any time at info@FinGrey.top.
13. Updates to this Policy
We may update this Privacy Policy from time to time. Significant changes may be communicated via email or website.
14. Contact Us
For any questions or requests regarding this policy:
Email: info@FinGrey.top
To: Compliance Department
Address: FINVIA Family Office GmbH
Oberlindau 54 – 56, 60323
Frankfurt am Main, Germany
