Finray IO, Inc. is a small organization. We do not have a Chief Privacy Officer.  Nonetheless, management is aware of the complex legislation that governs data privacy in many jurisdictions. We strive to ensure compliance with these laws and regulations by maintaining a risk avoidance policy in all that we do.

1. Finray does not sell data about any customer or prospect. 
2. Finray maintains a small database of target contacts.  In communication (mainly email) to the target contacts, the individual is given the opportunity to opt out of further communications and to be forgotten.  Our process of opt-out and forget is automated within our CRM system. 
3. In its consulting services practice, Finray typically works with client hardware and databases.  We do not store data about our client's businesses on our own servers and thus have no need to erase such data. In the rare event that our projects require us to hold data received from a client, this data is deleted at the project completion date. 
4. We act as neither controller nor processor of data.  In our business, we deliver tools that enable our clients to control and process their own data.  In our projects, we adhere to the data risk mitigation strategies listed in item 3 above.