AI Disclosure

Fingro AI, Inc. ("Fingro," "we," "us," or "our") Version: 1.4 Effective Date: 2026-06-25 Last Updated: 2026-06-25

Version 1.4 changes (2026-06-25): Section 3.1 (AI Providers) updated to name Google Cloud Vertex AI (Gemini 2.5 Flash, us-central1) as the document-understanding (OCR) provider — previously listed as "Google AI" without specificity. Section 3.3 (Processing Location) updated to describe the Vertex AI OCR path: document images are sent to Vertex AI in the Google Cloud us-central1 region under the executed Google Cloud Data Processing Addendum; Google does not use the content for model training. No reduction of prior commitments. No change to data categories processed, your rights, or our zero-retention guarantee for AI prompts and outputs.

Version 1.3 changes (2026-06-20): Rebrand of the AI assistant from "GroX" to WelX — Fingro's AI-powered financial assistant. Tagline established: "Financial wellness, compounded." No reduction of prior commitments. No change to data flows, retention, providers, or user rights. Section names and references to the assistant have been updated throughout this document.

Version 1.2 changes (2026-05-23): Added Section 5.2 (WelX Is Not a Fiduciary; No Investment, Tax, Legal, or Accounting Advice), Section 5.6 (No Automated Decision-Making with Legal or Similarly Significant Effects), Section 6.4 (Derived Data — what we may retain after source deletion), and Section 9.5 (Right to Modify AI Models, Providers, and Processing Workflows). Bias-evaluation commitment added to Section 9 (AI Ethics Principles). No reduction of prior commitments.

Version 1.1 changes (2026-05-22): Legal entity name updated to Fingro AI, Inc. (previously "Fingro, Inc."). No change to how AI is used in the Service.

1. Overview

Fingro uses artificial intelligence ("AI") to power our financial intelligence platform. This AI Disclosure explains how AI processes your data, what models we use, how we safeguard your information during AI processing, and your rights regarding AI-generated content.

We believe in transparency about AI. You should know when AI is involved, what it can and cannot do, and how to interpret its outputs.

2. Meet WelX — Your AI Financial Assistant

WelX is Fingro's AI-powered financial assistant. WelX can:

• Answer questions about your finances ("What did I spend on dining last month?")
• Analyze spending patterns and trends
• Generate cash flow forecasts and projections
• Provide wealth intelligence insights (net worth trends, portfolio diagnostics)
• Categorize and enrich transactions
• Generate your daily Morning Brief
• Create action items and financial planning suggestions
• Analyze documents uploaded to your Vault

WelX is designed to be helpful, accurate, and transparent. When WelX is uncertain about something, it will tell you.

3. AI Models We Use

3.1 AI Providers

Fingro uses the following AI providers to power different capabilities:

3.2 Model Routing

Fingro uses intelligent model routing to balance quality, speed, and cost. We automatically select the most appropriate AI model based on the complexity of your query — simpler tasks use faster, lighter models while complex financial analysis uses models with deeper reasoning capabilities. You do not need to choose which model handles your request.

3.3 Processing Location

The primary AI processing path is through AWS Bedrock in our private cloud infrastructure (AWS us-east-1 region). This means:

• Your data stays within our AWS Virtual Private Cloud (VPC)
• Data is transmitted over private AWS network connections — never over the public internet
• AI providers do not retain your prompts or responses when accessed through Bedrock
• No training on your data: your financial information is never used to train or improve AI models

For features that require real-time external information (e.g., Perplexity research queries), data is transmitted securely via encrypted API connections. Only the minimum context necessary is sent — never your full financial profile.

Document understanding (OCR) is processed by Google Cloud Vertex AI in the Google Cloud us-central1 region. When you upload a financial document to your Vault, the document image is sent to Vertex AI over an encrypted, server-side-authenticated connection (Google service account). Vertex AI extracts structured text and returns it to Fingro. Processing is governed by the executed Google Cloud Data Processing Addendum: Google does not use the content for model training, and Google logs only the metadata necessary to operate and bill the service.

In the event that AWS Bedrock is unavailable, the system may fall back to Anthropic's direct API. In this case, Anthropic's standard data handling policies apply. Anthropic does not train on API inputs or outputs.

4. How AI Processes Your Data

4.1 What Data AI Receives

When you interact with WelX or when AI processes your financial data, the AI model receives:

4.2 What AI Does NOT Receive

• Your bank login credentials (we never have these)
• Your password or authentication tokens
• Other users' data (tenant isolation is enforced before AI processing)
• Raw account numbers or routing numbers (masked before AI processing)
• Your Social Security Number

4.3 Transaction Categorization

Fingro uses a three-tier system for categorizing your transactions:

1. Tier 1 — Rule-based (no AI): Plaid provides detailed categories for most transactions at the time of sync. These are mapped to Fingro categories using deterministic rules. No AI is involved.

2. Tier 2 — Merchant memory (no AI): For recurring merchants, Fingro remembers the category from previous transactions. If you've corrected a category, that correction is remembered for all future transactions from that merchant.

3. Tier 3 — AI classification (AI involved): For new, unknown merchants where Tiers 1 and 2 cannot determine the category, AI classifies the transaction based on the merchant name and transaction details. A lightweight, cost-efficient model is used. This typically applies to fewer than 10% of transactions.

4.4 Morning Brief

Your daily Morning Brief is generated by AI using:

• Your account balances and changes since yesterday
• Notable transactions in the past 24 hours
• Upcoming recurring payments
• Market movements affecting your investment holdings
• Any proactive alerts or opportunities detected

The Morning Brief is generated fresh each day and is specific to your financial data.

4.5 Document Analysis

When you upload documents to your Vault, AI may:

• Extract text and structured data from the document
• Classify the document type (W-2, 1099, bank statement, etc.)
• Extract key fields (income amounts, tax withholdings, etc.)
• Identify tax planning opportunities based on document content

Document analysis occurs only on documents you explicitly upload. We do not analyze documents without your action.

5. AI Limitations and Accuracy

5.1 AI Can Be Wrong

AI-generated content may contain errors. Specifically:

• Calculations: While Fingro uses precise calculation engines for numerical operations (balances, net worth, spending totals), AI-generated narrative descriptions of these numbers may occasionally be inaccurate.
• Projections: Cash flow forecasts and financial projections are estimates based on historical patterns. They are not predictions of future results.
• Tax insights: AI-generated tax optimization suggestions are informational starting points — not tax advice. Tax law is complex and situation-specific. Always consult a qualified tax professional.
• Market commentary: AI may reference market conditions or economic factors that are outdated or incomplete.
• Category errors: AI may occasionally miscategorize a transaction. You can always correct categories manually, and corrections improve future accuracy.

5.2 WelX Is Not a Fiduciary; No Investment, Tax, Legal, or Accounting Advice

WelX does not act as a fiduciary. It does not have a legal duty to act in your best interest. AI-generated recommendations are informational tools to help you make more informed decisions — they are not directives.

Fingro is a technology platform; Fingro is not a bank, broker-dealer, registered investment adviser, tax adviser, accounting firm, or law firm. AI-generated outputs are provided for informational and educational purposes only and do not constitute financial, investment, securities, legal, tax, accounting, or other professional advice. Nothing generated by WelX should be interpreted as a recommendation to buy, sell, hold, refinance, transfer, or otherwise take action regarding any financial product, security, or investment strategy. WelX does not provide personalized investment advice or individualized recommendations concerning securities transactions. You are solely responsible for evaluating, verifying, and determining whether any AI-generated output is appropriate for your individual circumstances, and for consulting qualified licensed professionals for tax, legal, accounting, or investment decisions.

5.3 Verification Responsibility

You are responsible for verifying the accuracy of AI-generated content before making financial decisions. Fingro encourages you to:

• Cross-check important numbers with your financial institution
• Consult qualified professionals for tax, legal, and investment decisions
• Report inaccuracies to us so we can improve (use the feedback button or tell WelX)

6. AI Memory and Learning

6.1 Conversation Memory

WelX maintains memory within your account to provide continuity:

• Short-term memory: Active conversation context (current session)
• Long-term memory facts: Verified facts about you (e.g., "married," "has an LLC," "lives in California"). These are extracted from conversations and stored in your profile.
• Hypotheses: Inferred information that has not been verified (e.g., "may be interested in real estate investment"). These are lower-confidence and are confirmed or discarded over time.

6.2 No Cross-User Learning

WelX does not learn from one user to improve responses for another user. Your data is isolated:

• Your conversations are not used to train or fine-tune AI models
• Your data is never mixed with other users' data
• AI model improvements come from Anthropic's general model updates, not your data

6.3 Memory Deletion

You can delete AI memory at any time:

• Delete specific facts: Ask WelX "forget that I..." or manage in Administration > AI & Privacy
• Delete all memory: Clear all stored facts and conversation history
• Delete account: All AI memory is permanently deleted with your account

6.4 Derived Data

Fingro may generate derived data, metadata, categorizations, embeddings, summaries, and analytical outputs from the information you provide to or connect with the Services ("Derived Data"). Subject to applicable law and our Privacy Policy, Fingro may use Derived Data in de-identified or aggregated form to operate, secure, evaluate, and improve the Services, our machine-learning systems, and our AI capabilities. Where you delete an individual document, transaction, or memory item, Fingro permanently removes the source content; we may retain Derived Data that does not identify the deleted source, where reasonably necessary to preserve the accuracy of your historical financial picture, your net-worth snapshots, and the continuity of insights you have already received. To remove Derived Data entirely, submit a full data-deletion request as described in the Privacy Policy.

7. Human Oversight

7.1 No Automated Decision-Making with Legal or Similarly Significant Effects

Fingro does not provide automated decision-making services that produce legal, credit, employment, insurance, tax-filing, regulatory, or similarly significant effects on you without meaningful human involvement — including for purposes of Article 22 of the EU GDPR, the UK GDPR, and analogous U.S. state privacy laws. AI generates insights and recommendations; you decide whether and how to act on them. Specifically:

• Fingro does not automatically execute financial transactions, trades, or transfers
• Fingro does not automatically file taxes or legal documents on your behalf
• Fingro does not automatically change your account settings, beneficiaries, or risk preferences based on AI analysis
• Fingro does not use AI to make credit, lending, insurance-underwriting, employment, housing, or eligibility decisions about you
• Tier upgrade and add-on charges require your explicit, in-product confirmation before any payment method is charged

7.2 Human Support

If you believe AI has provided incorrect or harmful information:

• Use the feedback mechanism in any WelX conversation
• Contact support@fingro.ai
• Our team reviews flagged AI outputs and takes corrective action

8. Your Rights Regarding AI

You have the right to:

9. AI Ethics Principles

Fingro is committed to responsible AI use:

1. Transparency: We disclose how AI works, what data it uses, and its limitations
2. Privacy: Your data is not used to train generalized public AI models, and our AI processing operates within Fingro-controlled cloud infrastructure subject to technical and organizational safeguards designed to isolate customer data
3. Accuracy: We use precise calculation engines for numbers and AI for narrative insights — not the reverse
4. Fairness: AI does not discriminate based on race, gender, age, or other protected characteristics. Fingro evaluates and works to mitigate risks of unfair bias and discriminatory outcomes in AI-assisted features, consistent with the NIST AI Risk Management Framework and applicable algorithmic-fairness standards
5. User control: You can correct, delete, or opt out of AI features at any time
6. Continuous improvement: We regularly evaluate AI outputs for accuracy and bias

10. Future AI Features

As we develop new AI capabilities, we will:

• Update this disclosure before launching new AI features
• Notify you of material changes to how AI processes your data
• Obtain additional consent if new features process data in substantially different ways
• Provide opt-out mechanisms for new AI features

10.1 Right to Modify AI Models, Providers, and Workflows

Fingro may update, replace, suspend, or modify the AI models, AI providers, and processing workflows used to deliver the Services from time to time, including in order to improve security, accuracy, latency, cost-efficiency, regulatory compliance, or functionality. The authoritative current list of AI providers and high-level model categories is published at fingro.ai/sub-processors; the specific in-use model versions may rotate without amendment to this Disclosure, provided that any change that materially alters the categories of data processed, the location of processing, or the data-handling guarantees described in Section 3 will be disclosed in an updated version of this Disclosure with reasonable advance notice.

11. Contact Us

For questions about AI processing, data use, or to report AI-related concerns:

Fingro AI, Inc. 7750 St Marlo Country Club Pkwy Duluth, GA 30097 United States

• Email: privacy@fingro.ai
• In-app: Ask WelX "how does AI use my data?"

This AI Disclosure is part of Fingro's commitment to transparent, responsible AI. We believe AI should augment your financial decision-making — not replace your judgment.