FinSpectra Privacy Policy for California Residents

Last Updated: 1 July, 2026

This Privacy Policy for California Residents adds to the FinSpectra Privacy Policy and applies only to California residents (“consumers” or “you”). We provide it to meet the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). Terms defined in the CCPA have the same meaning here.

FinSpectra America Inc. is the entity responsible for this notice and for personal information collected from California residents through our Website. To provide and support our products, FinSpectra America Inc. may share personal information with its affiliates, FinSpectra Australia Pty Limited and FinSpectra India Private Limited, which act as service providers and may process information outside the United States. FinSpectra Australia Pty Limited may process information in Australia. FinSpectra India Private Limited supports development and delivery from India and does not routinely access personal information; any access from India is limited to what is necessary, controlled, and logged. FinSpectra is a business to business software company that provides a lending technology platform to lenders and financial institutions. We are not a lender, and we do not originate loans, make lending decisions, set loan terms, or collect borrower payments or payment card information through our Website. Customers that use our platform remain responsible for their own lending compliance and for configuring the platform correctly.

Information We Collect

We collect only the personal information you give us through our contact or demo request forms, such as your name, business email address, company name, and inquiry details, together with limited technical information collected automatically as you use the Website, such as your IP address and usage data. We do not collect financial account or payment card information, health information, or sensitive personal information through the Website. We get information from you directly, through the forms you complete, and indirectly, through your interactions with the Website. Over the past twelve (12) months we have collected the following categories:

We obtain personal information directly from you, through the forms you complete, and indirectly from you, through your interactions with the Website. We do not collect personal information from data brokers or other third party sources.

How We Use Personal Information

We may use or disclose the personal information we collect to:

• do what you asked, such as respond to your inquiry, arrange a demonstration, or send information you request;
• provide, support, improve, and secure our products and services and your account with us;
• administer your business account and prevent fraud;
• respond to your questions and keep the Website and our systems safe and secure;
• carry out testing, research, analysis, and product development;
• respond to law enforcement and meet legal requirements; and
• evaluate or carry out a merger, sale, or similar transaction in which personal information is among the assets involved.

We will not collect new categories of personal information, or use what we collected for unrelated purposes, without telling you first.

How Long We Keep Information

We keep personal information only as long as we reasonably need it for the purposes in this notice, including to meet legal, accounting, or reporting requirements. How long we keep it depends on the type of information and how it is used.

How We Share Personal Information

We may disclose personal information to service providers for a business purpose under written contracts that set the purpose, require confidentiality, and bar them from using it for anything else. Over the past twelve (12) months we have not disclosed personal information for a business purpose to anyone other than these service providers, and we do not sell or share personal information, as those terms are defined under the CCPA, and have not done so.

Your California Privacy Rights

The CCPA gives California residents specific rights over their personal information. You can use the rights below at no charge, and we will not discriminate against you for using them.

Right to Know and Data Portability

You can ask us to disclose, for the 12 months before your request, the categories of personal information we collected about you, the categories of sources, our business or commercial purpose for collecting it, the categories of third parties we share it with, and the specific pieces of personal information we collected about you.

Right to Delete

You can ask us to delete the personal information we collected from you, subject to exceptions. We may keep information where we need it to complete a transaction or provide something you asked for, detect security incidents or prevent fraud, fix errors, exercise free speech, comply with a legal obligation, or make other internal and lawful uses that fit the context in which you gave it to us.

Right to Correct

You can ask us to correct inaccurate personal information we hold about you. After we verify your identity, we will make commercially reasonable efforts to correct it.

Right to Opt Out of Sale or Sharing

We do not sell or share personal information, as those terms are defined under the CCPA, so there is nothing to opt out of. If this ever changes, we will update this notice and provide a clear way to opt out.

How to Submit a Request

To use your right to know, delete, or correct, email us at info@finspectra.com with the subject line “California Privacy Request.” Only you, or someone you legally authorize to act for you, may make a request. You may make a request to know twice in a 12 month period. Your request must give us enough information to confirm your identity or authority and enough detail for us to understand and respond. We cannot respond if we cannot verify you. You do not need an account to make a request, and we use the information in a request only to verify it.

How and When We Respond

We confirm we received your request within ten (10) business days and aim to respond fully within forty five (45) days. If we need more time, up to another forty five (45) days, we will tell you why in writing. Our disclosures cover the 12 months before we received your request. For a data portability request, we provide your information in a format that is readily usable. We do not charge for a request unless it is excessive, repetitive, or clearly unfounded, and if a fee applies we will explain it and give you an estimate first.

Authorized Agents

You can use an authorized agent to submit a request on your behalf. We may ask the agent for proof that you gave them permission to act for you, and we may still ask you to verify your own identity with us.

No Discrimination

We will not discriminate against you for using your CCPA rights. We will not deny you goods or services, charge a different price, give you a different level of quality, or suggest we will, except where the CCPA permits. We do not currently offer financial incentives in exchange for personal information.

CCPA Request Metrics

These are the consumer rights requests we received from California residents during the calendar year that ended December 31, 2025.

Other California Privacy Rights

California’s Shine the Light law (Civil Code § 1798.83) lets California residents ask about our disclosure of personal information to third parties for their direct marketing. To make such a request, email info@finspectra.com.

Changes, Contact, and Accessibility

We may update this notice at any time. When we do, we will post the new notice on this page and update the Last Updated date at the top. For questions, to use your rights, or to request this notice in another format because of a disability, contact us at info@finspectra.com, or write to FinSpectra America Inc., 2603 Camino Ramon, Suite 200, San Ramon, CA 94583, United States.

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