Privacy Policy

Introduction

FE International, Inc. and its subsidiaries ("Company," "We," or "FE International") respect your privacy and The technologies we use for automatic data collection may include:are committed to protecting it through our compliance with this policy. This policy describes the types of information we collect from you, or that you may provide, when you visit the When you interact with our advertising and applications on third-party websites and services, if those website https://www.feinternational.com/ and our related marketplace platform (our "Website"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy and its supplement apply to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through any mobile and desktop applications you may download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
When you voluntarily provide information in order to fulfill a reque

It does NOT apply to information collected by:

Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. We may use third-party service providers to perform certain services, in which case you may navigate through their website, portal, or app. In such instances, that third party's privacy policies govern your data, and we have no connection or relationship to their collection and use of your data. For example, we sometimes use Persona (https://withpersona.com/) to verify your identity for security and anti-fraud purposes. When you navigate through Persona's websites, portals, or apps, Persona's privacy policy applies to the information they collect, and this Privacy Policy does not.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time.Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. We have included further information about rights and disclosures as required under the California Consumer Privacy Act (CCPA) in our [Additional California Privacy Disclosures] supplement.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will immediately delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@feinternational.com. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to: privacy@feinternational.com. Please note that we do not currently sell data triggering that statute's opt-out requirements.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including:

Information by which you may be personally identified, such as your name or email address, or any other identifier by which you may be contacted online or offline ("personal information");
For registered sellers on the marketplace, information regarding your online business or digital asset that you provide to us;
For registered buyers on the marketplace, information regarding your acquisition criteria and investor profile;
Information that is about you but does not individually identify you; and/or
Information about your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

Information you provide by filling in forms on our Website, including at the time of registering, subscribing to our service, submitting a listing, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, or when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on the Website.

You may also provide information to be published or displayed on public areas of the Website, or transmitted to other users or third parties through communications with prospective buyers, sellers, or advisors (collectively, "User Contributions"). Your User Contributions are posted and transmitted to others at your own risk. Although we limit access to certain pages, no security measures are perfect or impenetrable, and we cannot control the actions of other users with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. For a more detailed list of information we collect, please see "Categories of Personal Information under CCPA" in our [Additional California Privacy Disclosures].

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information. We collect this information to help us improve our Website and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return to our Website.

The technologies we use for automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you do so, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you direct your browser to our Website.

Analytics Software. We use Google Analytics and HubSpot to collect information that helps us improve our ability to provide services to you.

Information Provided Voluntarily for Use of Services

We collect information that you voluntarily provide in order to fulfill a request — for example, when you sign up to use our services, request support, write to us by email, complete a contact form, or communicate with us in any way. This information includes your name and surname, company name, physical address, email address, and certain types of business information, such as revenue metrics, analytics data, customer information, and any other information you provide regarding your business or digital asset.

In particular, if you wish to incorporate data from third-party tools and applications — such as Stripe, Google Analytics, ChartMogul, Baremetrics, and ProfitWell — to display on your listing's information page for potential buyers, by connecting your accounts or providing API Keys or View IDs, you authorize FE International and grant us read access to certain information in your accounts with those third parties. Specifically:

Stripe – Read-only access to customer revenue data for the past 12 months
Google Analytics – Sessions, page views, and organic searches for the past 12 months
ChartMogul – Read-only access to customer revenue data for the past 12 months
Baremetrics – Read-only access to customer revenue data for the past 12 months
ProfitWell – Read-only access to customer revenue data for the past 12 months

Third-Party Use of Cookies

Some content or applications on the Website are served by third parties, such as Google Analytics and HubSpot. These third parties may use cookies to collect information about you when you use our Website, which may be associated with your personal information or may relate to your online activities over time and across different websites and services.

How We Use Your Information

We use information we collect about you, or that you provide to us, including any personal information:

To present our Website and its contents to you.
To facilitate the listing of your buyer, seller, or advisor profile on the marketplace.
To provide you with information, products, or services that you request from us, including (for seller users) displaying authorized business information to qualified potential buyers.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide through it.
To allow you to participate in interactive features on our Website.
In any other way we describe when you provide the information.
For any other purpose with your consent.

With your consent, we will use your information to contact you about our own and third-party goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.

Sale of Personal Information

We do not sell your personal information to anyone.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or otherwise fall under the definition of "Personal Information," "Personal Data," or any similar definition under any applicable regulation, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates so that we can provide our services to you.
To contractors, service providers, and other third parties we use to support our business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and Buyer and Seller Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others, including exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.

Your Information Rights and Controls

The General Data Protection Regulation ("GDPR") gives individuals rights over their personal information. While the following rights are specific to members of the European Economic Area (EEA), we aim to provide all of our users with the same rights where feasible.

How to Exercise Your Rights

Access: To make a verifiable request for information about the personal information we have collected about you, please email privacy@feinternational.com. Please note that most of the information we collect from you will be contained in your account profile on the platform.

Rectification: You can edit your personal information directly in your account profile on our platform.

Erasure: You may exercise this right by emailing privacy@feinternational.com. Please note that:

We may retain your personal information as necessary for our legitimate business interests, such as fraud detection, prevention of money laundering, and enhancing safety.
We may retain and use your personal information to the extent necessary to comply with our legal obligations, including tax, legal reporting, and auditing obligations, or as a record of any dispute with you.
Some copies of your information (e.g., email correspondence) may remain in our database but will be disassociated from personal identifiers and kept for record-keeping purposes only.

Restriction: You may exercise this right by emailing privacy@feinternational.com or by discontinuing your use of the platform.

‍Object: You may exercise this right by emailing privacy@feinternational.com.

Data Portability: You may exercise this right by emailing privacy@feinternational.com.

Automated Decision-Making: You may exercise this right by emailing privacy@feinternational.com. Please note that we do not exercise automated decision-making — all decisions regarding your profile are made by our internal team.

You also have the right to contact your local data protection authority with any questions or concerns.

Data Retention and Deletion

Subject to the additional rights of California users set forth in our [Additional California Privacy Disclosures], the rights of EEA members under the GDPR, and other applicable regulations, we will keep your personal information only as long as necessary to provide you with the services available on the FE International platform and for our legitimate and essential business purposes.

Deletion

If you close or request that we close your account, we will delete, de-identify, or anonymize your personal data so it no longer identifies you, unless we are required to keep it or still need to use it for a legally justifiable reason.

Examples of situations where we may be legally required or allowed to retain some personal data include:

If there is an unresolved issue relating to your account, such as an outstanding payment or unresolved claim or dispute.
For legal, tax, audit, and accounting obligations.
For our legitimate business interests such as fraud prevention or maintaining security.

In some cases, we may de-identify or anonymize your personal information to prevent fraud or to determine whether you are a former user if you decide to re-register on the platform.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us and our Data Protection Officer at:

Email: privacy@feinternational.com

Website: https://www.feinternational.com/contact/

To register a complaint or concern, please email privacy@feinternational.com.