Privacy Policy

The last update to our Privacy Policy was posted on 1st April 2021.


Our Privacy Policy governs the privacy terms of the FinLearn Platform and Services which includes all our websites, subdirectories, sub-domains, and any associated web-based and mobile applications, platforms, services, (collectively, “FinLearn Platform”). Any capitalised terms that are not defined in our Privacy Policy, have the meaning as specified in our Terms of Service.


Your privacy is very important to us. We made this Privacy Policy in order for you to understand how we collect, use, process, communicate, disclose, and make use of personal data. By using the FinLearn Platform, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same definition as in our Terms of Service. The following outlines our Privacy Policy:-


  • Before or at the time of collecting personal information, we will identify the purpose for which information is being collected.
  • We will collect and use personal information solely with the objective of fulfilling purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • We will only retain personal information as long as necessary for the fulfilment of those purposes.
  • We will collect personal information by lawful and fair means, and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect personal information by reasonable security safeguard measures against loss or theft, as well as unauthorised access, disclosure, copying, use or modification.
  • We will make readily available to customers information about our policies and practices relating to the management of personal information. 

1. Introduction

A. Your Privacy
FinLearn follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. We utilise the Personal Data you provide in a way that is consistent with this Privacy Policy. If you provide Personal Data for a particular reason, we could make use of the Personal Data in connection with the reason for which it was provided. For instance, FinLearn may utilise your Personal Data and various other personally non-identifiable information collected through the FinLearn Platform to help us improve the materials and functionality of the FinLearn Platform, to better understand our users, and subsequently to improve our services.

B. Definitions

i. “Non-Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our FinLearn Platform via a web browser. It may also include publicly available information that is shared between you and others.
ii. “Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order to create an account to access the FinLearn Platform. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we ask for about you.
iii. “Non-Personal Information” and “Personally Identifiable Information” collectively shall be referred to as “Personal Information”.

2. Information We Collect

A. Information You Give Us
We ask for and collect the following personal information about you when you use the FinLearn Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services. Generally, you control the amount and type of information you provide to us when using our FinLearn Platform.

i. Account Information. When you sign up for an FinLearn Account, we require certain information such as your first name, last name, email address, and date of birth.
ii. Profile and Listing Information. To use certain features of the FinLearn Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
iii. Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
iv. Payment Information. To use certain features of the FinLearn Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
v. Communications with FinLearn and other Users. When you communicate with FinLearn or use the FinLearn Platform to communicate with other Users, we collect information about your communication and any information you choose to provide.
vi. Additional Profile Information. You may choose to provide additional information as part of your FinLearn profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
vii. Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the FinLearn Platform, like inviting them to use FinLearn.
viii. Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your FinLearn Account, respond to surveys, post to community forums, participate in promotions, communicate with our FinLearn team, share your review with us, or use other features of the FinLearn Platform.
ix. Geo-location Information. When you use certain features of the FinLearn Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. FinLearn may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
x. Usage Information. We collect information about your interactions with the FinLearn Platform such as the pages or content you view, your searches for Listings, your purchase Orders, and other actions on the FinLearn Platform.
xi. Log Data and Device Information. We automatically collect log data and device information when you access and use the FinLearn Platform, even if you have not created an FinLearn Account or logged in. That information includes, among other things: details about how you’ve used the FinLearn Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the FinLearn Platform.
xii. Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the FinLearn Platform or engage others to track your behavior on our behalf.
xiii. Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads.
xiv. Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the FinLearn Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
xv. Payment Transaction Information. FinLearn collects information related to your payment transactions through the FinLearn Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and FinLearn Payments and to allow the provision of the Payment Services.

B. Information We Collect from Third Parties
FinLearn may collect information, including personal information, that others provide about you when they use the FinLearn Platform, or obtain information from other sources and combine that with information we collect through the FinLearn Platform. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

i. Third Party Services. If you link, connect, or login to your FinLearn Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
ii. Your References. If someone has written a reference for you, it will be published on your FinLearn public profile page.
iii. Background Information. To the extent permitted by applicable laws, FinLearn may obtain reports from public records of criminal convictions, background, or sex offender registrations. We may use your information, including your full name and date of birth, to obtain such reports.
iv. Referrals. If you are invited to FinLearn, the person who invited you may submit personal information about you such as your email address or other contact information.
v. Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the FinLearn Platform through partnerships, or about your experiences and interactions from our partner ad networks.

C. Children’s Data

i. The FinLearn Platform and Services are not directed to children under 16 years old and we do not knowingly collect any personally identifiable information directly from children under 16. If you believe that we processing the personal identifiable information pertaining to a child inappropriately, we take this very seriously and urge you to contact us via email to
i. To comply with the Child’s Online Privacy Security Act (COPPA), General Data Protection Regulation – Kids (GDPR-K), and other national and international kids data privacy laws in our jurisdictions, the FinLearn Platform and any operator should not require, as a condition to involvement in an activity, that a child younger than 16 years old divulge more details than is reasonably required. FinLearn abides by this demand. The company only collects information that are being offered willingly; no information is gathered passively. For Children under 16 years of age, verifiable parental consent must be obtained in order to create an Account and use our Services. In case FinLearn collects and maintains personal information relating to a child under 16 years old, the parent may send us an email to review, alter and / or delete such information, as well as to decline the request to collect any additional information of the child.

3. How We Use The Information We Collect

We may use, store, and process personal information to (1) provide, understand, improve, and develop the FinLearn Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with FinLearn Policies) and (3) provide, personalize, measure, and improve our advertising and marketing. We process this personal information for these purposes given our legitimate interest in improving the FinLearn Platform and our User’s experience with it, and where it is necessary for the adequate performance of the contract with you.
A. Provide, Improve, and Develop the FinLearn Platform. We may use the personal information to provide, improve, and develop the FinLearn Platform such as to:

i. enable you to access and use the FinLearn Platform,
ii. enable you to communicate with other Members,
iii. operate, protect, improve, and optimize the FinLearn Platform and experience, such as by performing analytics and conducting research,
iv. provide customer service,
v. send you service or support messages, updates, security alerts, and account notifications,
vi. if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
vii. to operate, protect, improve, and optimize the FinLearn Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate profiling based on your interactions with the FinLearn Platform, your search and Order history, your profile information and preferences, and other content you submit to the FinLearn Platform, and
viii. enable your use of our Paid Subscription Package products.

B. Create and Maintain a Trusted and Safer Environment. We process this personal information for these purposes given our legitimate interest in protecting the FinLearn Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws. We may use the personal information to create and maintain a trusted and safer environment such as to:

i. detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
ii. conduct security investigations and risk assessments,
iii. verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide),
iv. conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
v. comply with our legal obligations,
vi. Resolve any disputes with any of our Members and enforce our agreements with third parties,
vii. enforce our Terms of Service and other policies, and
viii. in connection with the activities above, we may conduct profiling based on your interactions with the FinLearn Platform, your profile information and other content you submit to the FinLearn Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the FinLearn Platform if such processes detect activity that we think poses a safety or other risk to the FinLearn Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

C. Provide, Personalize, Measure, and Improve our Advertising and Marketing. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

i. send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about FinLearn or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
ii. personalize, measure, and improve our advertising,
iii. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by FinLearn or its third party partners,
iv. conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the FinLearn Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
v. enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any FinLearn Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an FinLearn Account, and
vi. invite you to events and relevant opportunities

D. For the purpose of Payment Services. FinLearn Payment Services processes your personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws. We may use the personal information as a part of Payment Services such as to:

i. Enable you to access and use the Payment Services.
ii. Detect and prevent fraud, abuse, security incidents, and other harmful activity.
iii. Conduct security investigations and risk assessments.
iv. Conduct checks against databases and other information sources.
v. Comply with legal obligations (such as anti-money laundering regulations).
vi. Enforce the Payment Terms and other payment policies.
vii. With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

E. Your Choices. You have choices on the promotional messages that you choose to receive.

i. You can limit the information you provide to FinLearn. Participation in promotions and marketing programs is voluntary and you can limit the communications that FinLearn sends to you.
ii. To opt-out of marketing emails, simply click the link labelled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your FinLearn Account.
iii. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.

F. Other Uses. In addition, we may use the personal information for the following Uses.

i. Data Aggregation. We retain the right to collect and use any Personal Information collected from your use of our FinLearn Platform and aggregate such data for internal analytics, regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes that improve our FinLearn Platform and Service as well as for use or resale to others.

ii. Legally Required Releases of Information. We may be legally required to disclose your Personally Identifiable Information, if such disclosure is (a) required by subpoena, law, or other legal processes; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal actions or claims from third parties including you and / or other Members; and / or (e) necessary to protect the legal rights, personal / real property, or personal safety of FinLearn, our Users, employees, and affiliates.

iii. Google Ads. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website or other websites. Google’s use of advertising cookies enables it and its partners to serve ads to your users based on their visit to your sites and/or other sites on the Internet. Users may opt out of personalized advertising by visiting Ads Settings.

iv. Third Party Marketing Purposes. We may disclose your Personal Information at the discretion of FinLearn to third parties which include such as but not limited to Vendors, Tutors, Users and Members for direct marketing purposes when you show an interest in that third party, in circumstances such as but not limited to, filling a relevant form, navigating to a relevant webpage, or informing us verbally, over the phone, electronic communication, or in writing, that you are interested in that third party.

4. Security

A. Security of Personal Information

a. We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls.
b. The Security of your personal information is important to us, but remember that no method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We utilise practical protection measures to safeguard against the loss, abuse, and modification of the individual data under our control. No Web or email transmission is ever totally protected or mistake cost-free. For example, emails sent out to or from the FinLearn Platform may not be fully protected. Therefore, you must take unique care in deciding what information you want to send to us via email.
c. If you know or have reason to believe that your FinLearn Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your FinLearn Account, please contact us via email to

B. Links To External Websites from FinLearn Platform

a. Our FinLearn Platform may contain links to external websites that are not under our direct control. These external websites may have their own policies regarding privacy. We have no control of or responsibility for linked external websites and provide these links solely for the convenience and information of our visitors.
b. You access such linked external websites at your own risk. These external websites are not subject to this Privacy Policy, and you should check their individual privacy policies to see how operators of such external websites will utilise your personal information.

5. Changes To This Privacy Policy

A. We reserve the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we may notify you on our FinLearn Platform, by a blog post, by email, or by any other methods we shall decide. The method we choose is at our sole discretion.
B. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of the current “Last Updated” date and replace any prior Privacy Policies.

6. Questions About This Privacy Policy

A. We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. If you have any questions about our Privacy Practices or this Policy, please email us at