Privacy Policy
1. INTRODUCTION
Finlay Stakes (the “Platform”) is a portal that helps individuals organize their financial information through our Personal Financial Review (“PFR”) and connects them with independent insurance agents and investment consultants.
IMPORTANT: Finlay Stakes is a technology platform only. We are not a financial advisor, insurance agency, investment firm, or licensed professional. We do not provide financial advice, insurance products, or investment services.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform.
By using Finlay Stakes, you consent to the practices described in this Privacy Policy.
2. PLATFORM OPERATOR
| Region | Operator | Address |
|---|---|---|
| Europe Office | Finlay Stakes Holdings LTD | Ireland |
| Asia Office | Finlay Stakes Holdings Limited | Hong-Kong |
3. INFORMATION WE COLLECT
3.1 Information You Provide Through PFR (Chatbot Interview)
| Category | Information Collected |
|---|---|
| Personal Information | Full name, date of birth, email, phone number, address, nationality |
| Income Information | Employment status, annual income, additional income sources |
| Expense Information | Monthly living expenses, housing costs, debt payments, dependents |
| Assets & Liabilities | Savings, investments, insurance policies, real estate, loans, credit card debt |
| Goals | Retirement goals, education goals, major purchases, risk tolerance |
3.2 Identity Verification Documents
When requested by your assigned consultant, you may upload:
- • Government-issued identification
- • Proof of address
- • Signed insurance or investment applications
- • Other documents required by consultants
3.3 Documents Uploaded by Consultants
Consultants may upload to your account:
- • Issued insurance certificates
- • Investment account statements
- • Policy confirmation documents
3.4 Information Automatically Collected
IP address, browser type, device information, usage data, location data, cookies.
3.5 For Consultants
License numbers, certifications, business contact information, firm affiliation.
4. HOW WE USE YOUR INFORMATION
| Purpose | Description |
|---|---|
| PFR Generation | Create your Personal Financial Review report |
| Consultant Matching | Connect you with independent consultants |
| Document Management | Store, share, and manage documents between you and your consultant |
| Platform Operation | Maintain and improve the Portal |
| Security | Protect against fraud and unauthorized access |
We do not:
- • Provide financial advice
- • Sell insurance or investment products
- • Make decisions about your applications
- • Verify consultant recommendations
5. HOW WE SHARE YOUR INFORMATION
| Recipient | When Shared |
|---|---|
| Assigned Consultant | When you consent to matching |
| Service Providers | For platform operations (hosting, storage, communication) |
| Legal Authorities | When required by law |
We do not sell your personal information.
6. DATA SECURITY
We implement standard security measures including:
- • Encryption for data in transit and at rest
- • Access controls
- • Regular backups
7. DATA RETENTION
| Data Type | Retention Period |
|---|---|
| Active Account Data | Duration of account + 30 days |
| PFR Reports | Duration of account + 7 years |
| Documents | Duration of account + 7 years |
| Inactive Accounts | Up to 24 months |
8. YOUR RIGHTS
| Right | Description |
|---|---|
| Access | Request a copy of your data |
| Correction | Update inaccurate information |
| Deletion | Request account and data deletion |
| Document Download | Download any document in your account |
To exercise your rights, email hello@finlaystakes.com
9. CONTACT INFORMATION
| Purpose | Contact |
|---|---|
| Privacy Inquiries | hello@finlaystakes.com |
| Europe Office | Finlay Stakes Holdings LTD, Ireland |
| Asia Office | Finlay Stakes Holdings Limited, Hong-Kong |
These Terms & Conditions are effective as of March 23, 2026.