Privacy Policy

Last Updated: April 2026

Company: Focus Systems Consulting Corp. (DBA FintekFlow)

1. Introduction and Our Role

Focus Systems Consulting Corp. ("FintekFlow", "we", "us", or "our") operates as a secure, "pass-through" compliance clearinghouse and data verification platform. We provide Cash-Flow Underwriting and Ability-to-Repay (ATR) calculations to assist landlords, property managers, and real estate developers in complying with federal underwriting standards. We are not a lender, we do not originate loans, and we do not make final credit decisions.

2. Information We Collect

When you use the FintekFlow platform to verify your financial capacity, we collect:

• Personally Identifiable Information (PII): Name, email address, phone number, target zip code, and the last 4 digits of your SSN/ITIN (strictly for identity verification).
• Financial Data via Open Banking: With your explicit consent, we utilize third-party Open Banking providers (such as Plaid) to securely access your bank account information. We analyze up to 90 days of transaction history to determine your true monthly net income and recurring liabilities.

3. Data Minimization and Zero-Retention Architecture

We strictly adhere to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule through a Data Minimization policy.

• No Credential Storage: We never see, collect, or store your raw bank usernames or passwords. Authentication is handled entirely via secure, tokenized sessions through our data partners (e.g., Plaid Link).
• Zero-Retention of Raw Data: After our algorithm calculates your Debt-to-Income (DTI) or Coverage Ratio, the raw transactional data retrieved from your bank is permanently purged from our active databases.
• Audit Trail Retention: For federal auditing purposes (including DOJ, TILA, and ECOA compliance), we only retain the minimum required evidence: your basic PII, the final compliance verdict, and an immutable cryptographic hash (SHA-256) of the transaction.

4. Data Security and Encryption

Protecting your financial data is our highest priority. We employ enterprise-grade security measures:

• In-Transit Encryption: All data transmitted between your device, our servers, and third-party APIs is encrypted using TLS 1.2 or higher protocols.
• At-Rest Encryption: Any sensitive PII or compliance data retained in our isolated PostgreSQL databases is encrypted at-rest using military-grade AES-256 encryption standards.
• Access Controls: We enforce strict Role-Based Access Control (RBAC) and Multi-Factor Authentication (MFA) for all administrative access to our production servers.

5. How We Share Your Information

• With Authorized Parties: We share your generated "Compliance Verdict" and DTI/Coverage Ratio strictly with the specific landlord, property manager, or seller associated with your application.
• No Sale of Data: We absolutely do not sell, rent, or market your personal or financial data to unauthorized third parties, data brokers, or marketing agencies.

6. Fair Credit Reporting Act (FCRA) and Your Right to Dispute

FintekFlow acts as a technological conduit and does not subjectively evaluate your data. If your application results in an "Adverse Action" (denial or restructuring) based on information provided by our third-party data aggregators (e.g., Plaid or Checkr), you have the right under the FCRA to obtain a free copy of your report from that agency and dispute the accuracy of the information directly with them.

7. Contact Us

If you have any questions about this Privacy Policy, our data practices, or our GLBA compliance program, please contact our compliance team at:

Email: ceo@fintekflow.com

Entity: Focus Systems Consulting Corp. (Texas Taxpayer No. 32103509330)