Privacy Policy

Fingro AI, Inc. ("Fingro," "we," "us," or "our") Version: 1.15 Effective Date: 2026-09-26 Last Updated: 2026-10-25

Version 1.15 changes (2026-10-25): Corrects what 1.14 said about location. 1.14 stated that a visit records "the country your request came from", taken from our content delivery network. That collection was never actually happening — the code read a header that does not reach the service receiving the data, so no country was ever recorded for anyone. Rather than start collecting what the document described, we now record something coarser and say so plainly: the time zone your browser reports about itself, such as "America/Chicago". It is volunteered by your browser to every site it loads, it needs no lookup of your address, and it covers a continent-sized region rather than a place. Still no IP address is stored, and nothing else about this section changes.

Version 1.14 changes (2026-10-25): Discloses first-party website analytics on fingro.ai, added the same day. Section 2.3 now states exactly what a visit records — pages, time on page, scroll depth, clicks on our own links, referrer, campaign tag, device, browser and the time zone your browser reports — and what it does not: no IP address is stored, no third-party analytics service, no advertising pixel, no session recording, no identity matching against any outside database.

Also states that a random browser identifier lets us recognise a return visit, that it is readable only by our site, and that a form submission is connected to the visit it came from. "Reject non-essential" stops all of it, including that connection.

Nothing here is retroactive: collection begins with the release that carries this version. Traffic before it was never measured this way.

Version 1.13 changes (2026-10-23): Describes the Recycle Bin, which changes who can recover a deleted document — from us to you.

Version 1.12 (2026-10-19) said a deleted file's retained copies were "not reachable through the product by you" and were "recoverable only by Fingro staff acting on a support request from you". That was true of the storage layer and is no longer true of the product: the 30 days are now a Recycle Bin you can open, see and restore from yourself, which is the only reason a retention window is worth having. Section 6 now says so, and the retention table row is rewritten to match.

Nothing about the window changed — still 30 days, still permanent destruction after that, still removed from your Vault's folders, your search, WelX and anyone you shared it with on the day you press delete. What changed is that you can act within it without asking us.

Version 1.12 changes (2026-10-19): States how long a deleted document's bytes actually survive, because the previous wording was wrong in the customer's disfavour.

Section 6 said Fingro "permanently removes the source content — the file itself, our stored copy" on deletion, and the only mention of anything surviving was "encrypted backup copies ... for a brief period". Neither described the real behaviour: the document store keeps the previous version of a deleted file, and no rule expired it, so those copies were retained indefinitely. On the day this was found there were 71 delete markers and 9 retained versions in production.

Fixed at the storage layer first and then written down: retained copies are now destroyed 30 days after deletion, the retention table says so, and the Derived Data paragraph points at it. The 30 days exist so an accidental deletion or a failed upload can be recovered on request; during that window the file is already gone from the Vault, from search, from WelX and from anyone it was shared with, and is reachable only by Fingro staff acting on a request from the owner.

Version 1.11 changes (2026-10-14): Two disclosures, one new and one overdue.

Section 3.5 now states that images uploaded to the Vault are screened automatically for sexually explicit content, where that runs, and what it does not do: no facial recognition, no identification of people, no face data — the permissions it runs under forbid every facial API outright. The corresponding acceptable-use policy is new Section 6.2–6.4 of the Terms of Service, which takes effect on publication under the amended Section 14 of those Terms. Screening is on.

Section 9 said the Services are "offered only to residents of the United States". That stopped being true on 2026-10-12, when Terms v4.3 opened eligibility to Canada. It now says the United States and Canada, and states plainly what a Canadian customer needs to know: personal information is stored and processed in the United States, not in Canada, and is subject to United States law. A published policy that contradicts the published Terms is worse than one that says nothing.

Version 1.10 changes (2026-10-06): Brings Section 6 into line with what the product actually does, and discloses one thing it did not mention. The Derived Data paragraph previously said derived data "is not retained where it would identify deleted source content". That was not accurate: we keep the extracted figures from a deleted document along with its type and tax year, because a figure we still show you has to be explainable. It now says so plainly, and documents the choice we now put in front of you — when you delete a document, Fingro shows which figures and facts depend on it and offers to remove them in the same step. If you do, only a one-way fingerprint of the file is kept, to avoid re-processing and detect abuse. New retention-table row for that record. A figure whose source document was deleted is now labelled as such, and the policy commits to that. Section 7.4 names the per-document route rather than pointing at a request process that had no in-app path. Also adds a short disclosure of the session storage, interface preferences and the single first-party fingro_travel cookie (travel access, six months, off by default) — previously the policy only said what we do NOT set. No new collection, no new sharing, no weakening of any prior commitment.

Version 1.9 changes (2026-10-01): Section on international processing rewritten. It previously said that if you access the Services from outside the United States your information would be transferred here and that by using the Services you consent to the transfer — which read as an invitation to use Fingro from anywhere. Fingro is offered only to U.S. residents and registration from outside the United States is now refused at signup, so the section says that instead. It still states plainly that an existing U.S.-resident customer travelling abroad continues to have their information processed in the United States, because that remains true and is deliberately allowed. No change to what we collect, how long we keep it, or who we share it with.

Version 1.8 changes (2026-09-26): Section 7.4 now names the correct in-app locations for exercising your rights. It previously pointed to "Administration > Privacy & Security", a screen that held only display settings — there was no in-app way to request an export or delete your account. Both now exist: Settings > Your data requests an export, and Settings > Plan & Payment deletes your account, showing what is removed and what we must retain before you confirm. No change to what we collect, how long we keep it, or any right you hold.

Version 1.7 changes (2026-07-15): Removed all references to Teller.io as a data-aggregation sub-processor. Plaid, Inc. is now our sole account-aggregation partner. Sub-processor table (Section 8) and account-connection language updated accordingly. No change to categories of personal data collected, retention periods, or your rights.

Version 1.6 changes (2026-06-25): Sub-processor table (Section 8) updated to reflect the true production stack: Google Cloud Vertex AI (Gemini 2.5 Flash, us-central1) named as the document-understanding (OCR) sub-processor under the executed Google Cloud Data Processing Addendum; Perplexity AI named as the web-search augmentation sub-processor for WelX; Finnhub named for market-data lookups on user-curated watchlists; Resend named as the live transactional email provider (Amazon SES remains provisioned inside our AWS VPC as a pending alternative — SES production-access approval is in flight and SES is not currently in use). No reduction of prior commitments. No change to categories of personal data collected, retention periods, or your rights.

Version 1.5 changes (2026-06-20): Rebrand of the AI assistant from "GroX" to WelX — Fingro's AI-powered financial assistant ("Financial wellness, compounded."). All references to the assistant have been updated. No change to data collection, processing, retention, sharing, or user-rights provisions.

Version 1.4 changes (2026-06-07): Section 6 (Data Retention) extended to disclose two new entries supporting the Revenue Leakage Guardrails program: (a) Suspended account preservation for up to 90 days post-sponsorship with deletion at Day 121, and (b) the hashed identifier registry — one-way SHA-256 hashes of email, phone, payment fingerprint, SSN, EIN, and a name/DOB composite — retained for 7 years after deletion for fraud and anti-abuse pattern detection only. No plaintext personal data is retained. See ToS §5.11 for the matching enforcement disclosure.

Version 1.3 changes (2026-05-23): Added Section 2.5 (Data Minimization), Section 2.6 (Biometric Information — no collection), Section 3.6 (Legal Bases for Processing under GDPR-style frameworks), Section 5.7 (AI-Generated Output Accuracy), expanded Section 7.4 (verification + permitted denial of unverifiable requests + Global Privacy Control), expanded Section 10 (GLBA service-provider framing), and added "Authorized personnel may review AI interactions for security / fraud / debugging / support" transparency to Section 3.2. No softening of prior commitments — all prior obligations preserved.

Version 1.2 changes (2026-05-22): Legal entity name updated to Fingro AI, Inc. (previously "Fingro, Inc."). No change to data practices or your rights — only the formal name of the contracting entity.

Version 1.1 changes (2026-05-19): Section 2.1 now describes the household roles you can grant to a spouse, adult dependent, teen, or minor and the data each role can access. Section 4.4 now describes the Coverage Policy your employer may configure when household events grow your plan, what happens when your employer ends sponsorship, and what each party can and cannot see at each stage.

1. Introduction

Fingro AI, Inc. operates the Fingro.ai platform ("Platform"), a personal financial intelligence service that helps individuals understand, organize, and optimize their financial lives. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our Platform, website (fingro.ai), and related services (collectively, "Services").

By creating an account or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, do not use our Services.

2. Information We Collect

2.1 Information You Provide Directly

2.2 Information Collected Through Financial Account Connections

When you connect your financial accounts through our third-party provider (Plaid, Inc.), we receive:

• Account details: Institution name, account name, account type (checking, savings, investment, credit, loan), account and routing numbers (masked)
• Balance information: Current, available, and limit balances
• Transaction history: Date, amount, merchant name, category, pending status
• Investment holdings: Security name, quantity, cost basis, current value
• Account owner information: Name and address on file with your financial institution

Important: We never receive or store your bank login credentials. Authentication occurs directly between you and your financial institution through Plaid's secure connection. We receive a secure access token that allows us to retrieve your financial data.

2.3 Information Collected Automatically

We do not use third-party tracking cookies or advertising pixels. We do not sell or share your data for advertising purposes.

Website analytics on fingro.ai. We measure how our public website is used — which pages are read, how long for, how far down the page, and which links are clicked — so we can make it better. This is first-party only: the information goes to Fingro and to nobody else. There is no third-party analytics service, no advertising pixel, no session-recording tool, and nothing on the site is loaded from another company's servers, including fonts.

What we record for a visit: the pages viewed and in what order, time on each page, scroll depth, clicks on our own navigation and buttons, the site that referred you, any campaign tag in the link you followed, your device type and browser, and the time zone your browser reports about itself — for example "America/Chicago". We do not record your IP address, and we do not look up your location. The time zone is a setting your browser already volunteers to every site it loads; it covers a continent-sized region, not a place, and we store it exactly as given rather than converting it into a country.

We give your browser a random identifier so that a return visit is recognisable as a return visit. It is generated by our site, readable only by our site, and is not matched against any outside database, advertising network or identity service. It never tells us who you are. If you later give us your email address through a form on the site, we connect that submission to the visit it came from, so that we understand which pages led people to get in touch.

The cookie banner tells you this before we collect anything, and choosing "Reject non-essential" stops it — including the link between a form you submit and the visit it came from. You can change your mind at any time through the banner's preferences.

Cookies and local storage we do use. Fingro stores your sign-in session in your browser's session storage, and remembers interface preferences (such as a chosen view or a collapsed panel) in local storage; both stay on your device. We set one persistent first-party cookie, fingro_travel, and only if you turn on travel access in Settings. It lets you reach the sign-in screen while you are outside the United States, lasts six months, carries no personal information, and can be switched off at any time in Settings. It does not sign you in on its own — your password and verification code still apply.

2.4 Household Member Access Roles

If you invite a member of your household to share access to your Fingro account, the data they can see and the actions they can take depend on the role you assign at invitation:

You can change a household member's role, suspend their access, or remove them at any time from Settings > Family. Removing a household member terminates their access immediately; data they previously viewed remains within your account but is no longer accessible to them.

2.5 Data Minimization

Fingro collects only the personal information reasonably necessary to provide, maintain, secure, and improve the Services. We do not collect categories of personal information we do not use, and we periodically review our collection practices to remove fields that are no longer necessary. You may opt out of providing optional information (e.g., profile fields that personalize insights) at any time from your account settings, although doing so may reduce the relevance of certain features.

2.6 Biometric Information

Fingro does not knowingly collect, store, or process biometric identifiers or biometric information as defined under applicable law (including the Illinois Biometric Information Privacy Act, Texas Capture or Use of Biometric Identifier Act, and similar statutes). Authentication relies on passwords, multi-factor codes, and (where you elect to use it) device-level biometric unlock that is performed entirely on your device by your operating system — Fingro never receives the biometric template.

3. How We Use Your Information

3.1 Core Service Delivery

• Financial aggregation: Display your accounts, balances, transactions, and net worth in a unified dashboard
• AI-powered insights: WelX, our AI assistant, analyzes your financial data to provide personalized insights, spending analysis, cash flow forecasts, and wealth intelligence
• Document management: Store, organize, and analyze documents in your Vault
• Transaction categorization: Automatically classify transactions by spending category
• Alerts and notifications: Proactive monitoring of account changes, unusual activity, and financial opportunities
• Morning Brief: Daily personalized financial summary

3.2 AI Processing

Your financial data is processed by artificial intelligence models to generate insights. See our AI Disclosure for detailed information about how AI processes your data, what models are used, and your rights regarding AI-generated content.

Fingro does not use your identifiable personal financial information to train generalized public AI models for unrelated users. Fingro may use de-identified, aggregated, or anonymized information to improve, evaluate, secure, and maintain the Services and our machine-learning systems, consistent with applicable law. Third-party AI providers processing data on Fingro's behalf are contractually restricted from using your data to train their public or generalized models except as expressly disclosed in our AI Disclosure.

Authorized Fingro personnel may review limited AI interactions for security, fraud-prevention, debugging, support, abuse-mitigation, and service-improvement purposes, subject to confidentiality obligations and least-privilege access controls. Reviewed interactions are not used to train generalized AI models.

AI-generated outputs may contain inaccuracies, omissions, hallucinations, or outdated information and should not be relied upon as legal, tax, accounting, investment, or financial advice. Users should independently verify AI-generated insights before making financial decisions.

3.3 Service Improvement

• Analyze aggregate, de-identified usage patterns to improve features
• Monitor Platform performance and reliability
• Identify and fix technical issues

3.4 Communications

• Service-related emails (account verification, security alerts, sync status)
• Product updates and new feature announcements (you may opt out)
• Responses to your support requests

3.5 Security and Compliance

• Detect and prevent fraud, unauthorized access, and abuse
• Comply with legal obligations
• Enforce our Terms of Service
• Maintain audit logs for regulatory compliance
• Screen images uploaded to your Vault for sexually explicit content. This runs automatically inside Fingro's own cloud environment using Amazon Rekognition, which is listed in our sub-processor register. An image identified as sexually explicit is refused at upload and is not stored. The screen reads the image only to answer that one question: it does not perform facial recognition, does not identify people, and derives no face data — the permissions it runs under explicitly forbid every facial API. Documents that are not images are not sent to it. See Section 6 of the Terms of Service for what this does and does not promise, including what happens when it gets something wrong.

3.6 Legal Bases for Processing

The Services are offered only in the United States, so the privacy laws that apply to you are United States federal law and the law of your state of residence. Within that framework, Fingro processes personal information under one or more of the following legal bases:

• Performance of a contract with you (most processing necessary to deliver the Services)
• Your consent (for optional processing such as marketing communications, beta features, and certain AI features you elect to enable)
• Compliance with legal obligations (KYC, AML, tax-reporting, response to legal process)
• Our legitimate interests in operating, securing, improving, and benchmarking the Services, where those interests are not overridden by your rights and freedoms

Where required by law, you may withdraw consent for consent-based processing at any time without affecting the lawfulness of processing prior to withdrawal.

4. How We Share Your Information

Categories of Third Parties. In the preceding 12 months, Fingro has disclosed personal information to the following categories of third parties for the business purposes described below: (i) service providers (cloud hosting, financial data aggregators, email delivery, error monitoring, subprocessors listed at /security/subprocessors); (ii) your CPA, financial advisor, or attorney, only when you explicitly grant them access; (iii) your employer's benefits administrator, only for the operational fields described in Section 4.4; (iv) government or law-enforcement agencies, only when legally compelled per Section 4.5; and (v) a successor entity in the event of a business transfer per Section 4.6. Fingro does not sell or share personal information for cross-context behavioral advertising.

4.1 We Do Not Sell Your Personal Information

We have not sold personal information in the preceding 12 months and will not sell your personal information.

4.2 Service Providers

We share information with the following categories of service providers, solely to operate our Services:

The categories and named providers above reflect Fingro's current sub-processor roster. The authoritative, always-current list — including specific model versions, document-processing vendors, and any new sub-processors — is published at fingro.ai/sub-processors and updated when sub-processors change. We will notify users by email or in-product banner of any material change to the sub-processor list before it takes effect, as further described in our Data Processing Agreement.

All service providers are contractually required to:

• Use your data only to provide services to us
• Maintain appropriate security measures
• Not sell, share, or use your data for their own purposes
• Delete your data upon contract termination or your request

Plaid — account aggregation. Your use of Plaid to connect your financial accounts is also governed by its own privacy policy, in addition to ours:

• Plaid End User Privacy Policy

Fingro uses Plaid solely to retrieve the financial data you have authorized us to receive. We do not direct Plaid to use your data for any purpose beyond what you have authorized in our Services. You may revoke a connection at any time:

• From within Fingro: Settings > Holdings > Disconnect on the institution card.
• Directly with the aggregator: visit Plaid's privacy portal at https://my.plaid.com to view and revoke every Plaid connection you have ever made (not only those involving Fingro).

Revoking a connection through any of these channels prevents further data retrieval. Historical data that was already synced into your Fingro account remains in your account until you delete it or request account deletion (see Section 7).

The current list of all sub-processors who may process your data is maintained in our Data Processing Agreement and updated when sub-processors change. We will notify users of material changes to the sub-processor list before they take effect.

4.3 Your CPA or Financial Advisor

If you were invited to Fingro by a CPA or financial advisor, or if you grant access to one:

• They may view your financial dashboard, documents, and AI insights
• Access is governed by the specific permissions you grant
• You may revoke access at any time from your Administration settings
• All CPA access is logged in our audit system

4.4 Employer (B2B2E Channel)

If you access Fingro through an employer wellness program:

• Your employer has zero visibility into the financial content of your Fingro account — this is an architectural constraint, not a setting.
• Your employer cannot see: your financial data, transactions, AI conversations, documents, the substance of your activity, or which household members you have added.
• Your employer can see only the following operational fields, in their admin console, for each employee they sponsor: your name and work email (which they provided when inviting you), your account status (invited, active, inactive), the most recent date you logged in (no times, no actions), and the tier they are paying for on your behalf ("Individual," "Couple," or "Business Owner"). They cannot drill down into any financial data behind these fields.
• Aggregate enrollment counts for the overall program (e.g., "42 of 100 eligible employees enrolled") may also be visible.

Coverage Policy. Your employer configures, in their admin console, a Coverage Policy that determines who pays when household events grow your plan beyond what they originally purchased (see Terms of Service Section 5.6). The policy applies to three categories independently — spouse, dependent, and business entity — and each is either "Employer Pays" or "Employee Pays." When you take an action that would grow your plan (adding a spouse, dependent, or entity), Fingro shows you an in-product prompt that discloses the applicable policy and the amount that will be charged, before any change is applied. The disclosure of who pays is the only signal your employer receives about a household change; the identity of the household member, the document that triggered detection, or any other personal data is not shared with your employer.

When sponsorship ends. If your employer cancels your sponsorship (either by removing you from their admin console or by allowing their subscription to lapse), your account, data, household members, and household-member access are preserved without interruption. Your subscription converts to a personal subscription at the same tier you were on, and you are prompted to add a personal payment method before any further paid action is required. Your employer cannot delete your data, export your data, or instruct us to do either.

See our Data Processing Agreement for the contractual basis of these protections and the full sub-processor list.

4.5 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, including:

• Response to subpoenas, court orders, or legal process
• Cooperation with law enforcement when legally compelled
• Protection of our rights, property, or safety, or that of our users or the public

We will notify you of such requests unless prohibited by law or court order.

4.6 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity. We will notify you via email and/or prominent notice on our Platform before your information becomes subject to a different privacy policy.

5. Data Security

5.1 Encryption

5.2 Infrastructure Security

• Network isolation: Our servers run in private network segments with no direct internet access
• Web Application Firewall: Protection against SQL injection, cross-site scripting, and OWASP Top 10 vulnerabilities
• DDoS protection: AWS Shield protects against distributed denial-of-service attacks
• Access logging: All system access is logged and monitored
• Intrusion detection: Continuous monitoring for unauthorized access attempts

5.3 Application Security

• Tenant isolation: Your data is logically isolated from all other users at the database level. Every query is scoped to your unique tenant identifier.
• Authentication: Passwords are hashed using industry-standard algorithms. Multi-factor authentication (MFA) is available.
• Session management: Sessions expire after inactivity. Tokens are stored in session storage (not persistent).
• Audit trail: All data access is logged with timestamps, user identifiers, and action details.

5.4 Organizational Security

• Background checks for all team members with data access
• Principle of least privilege for system access
• Regular security assessments and code reviews
• Incident response procedures documented and tested

5.5 Third-Party Certifications and Our Own Roadmap

Inherited from our infrastructure providers. Our infrastructure runs on Amazon Web Services, which maintains independently audited SOC 1, SOC 2, SOC 3, ISO 27001, ISO 27017, ISO 27018, and PCI DSS Level 1 certifications. Our payments are processed by Stripe (PCI DSS Level 1). Our account-aggregation partner (Plaid) is SOC 2 audited.

Fingro AI, Inc.'s own certifications. Fingro is targeting SOC 2 Type I in the second half of our first production year and SOC 2 Type II within twelve months of go-live. We have not yet engaged an audit firm or completed a formal third-party assessment; that work is on the roadmap and tracked publicly to enterprise customers.

In the interim, what we will provide today to enterprise customers and regulators under NDA, by emailing security@fingro.ai:

• A current security questionnaire response (SIG, CAIQ, or custom)
• An architecture diagram (data flow, isolation, encryption boundaries)
• The list of sub-processors and the DPA we sign with each
• Our incident-notification commitments (72 hours for personal data breaches; see Section 5.6)
• Our cyber-insurance certificate of liability (upon request)

We will not represent that we hold certifications we have not yet earned. If a customer's procurement process requires a current SOC 2 Type II report as a pre-condition, we will say so and decline the engagement until the report is in hand.

5.6 Personal Data Breach Notification

If a personal data breach affects the security or confidentiality of your personal information, we will:

• Notify affected users without undue delay and in any event within 72 hours of becoming aware of the breach, where the breach is likely to result in a risk to your rights or freedoms.
• Provide, at minimum, the nature of the breach (categories of data involved, approximate number of affected individuals), the likely consequences, the measures we have taken or propose to take, and a point of contact for further information.
• Notify the relevant supervisory authorities and our employer customers (where applicable, see the Data Processing Agreement) within the timeframes required by applicable law.
• Cooperate in good faith with affected users, regulators, and law enforcement to investigate and remediate the incident.

To report a suspected security issue, contact security@fingro.ai. We acknowledge responsible-disclosure reports within one business day.

6. Data Retention

After account deletion, we permanently delete your personal data within 30 days, except where retention is required by law (e.g., tax records, audit logs) or for the limited anti-abuse hashed-identifier registry described above.

The hashed-identifier registry contains no plaintext personal information. A salted SHA-256 hash is a one-way transformation: it cannot be reversed to recover the original identifier. We use this registry solely to detect repeat sign-up patterns covered by Section 5.11 of our Terms of Service. We do not share, sell, or use this registry for any other purpose.

Derived Data. When you delete an individual document, transaction, or memory item, Fingro removes the source content — the file itself, our stored copy, and WelX's ability to search or quote it. It leaves your Vault's folders, your search results and WelX immediately, and moves to your Recycle Bin for 30 days so that you can put it back; after that the document and the encrypted bytes behind it are destroyed, as described under How long a deleted document survives below.

By default we retain the derived data: the figures we extracted, categorizations, financial insights, net-worth snapshots, AI-generated summaries, and facts WelX learned. We keep these so your historical financial picture does not silently rewrite itself — deleting last year's tax form should not change what your net worth was last year.

Because we keep them, we also keep enough to explain them. For a deleted document that is its file name, document type and tax year, so that a figure we still show you can say where it came from. We tell you this before you delete, not after: when you delete a document, Fingro shows you exactly which figures and facts it is holding up and offers to remove those at the same time. If you choose to remove them, we delete the figures and the facts, and we retain only a one-way fingerprint of the file — no name, no type, no year — solely so that re-uploading the same file does not cost you a second round of processing, and to detect abuse. We also record that a deletion occurred, and whether you asked for the derived data to go, so the request is auditable.

A figure whose source document you have deleted is labelled as such wherever we show it. We will not describe a number as coming from a filed form when the form is no longer on file.

To remove derived data you did not remove at the time, or to make a broader request, contact privacy@fingro.ai (see Section 7) or delete your account.

How long a deleted document survives, and how you get it back. A document you delete goes to your Recycle Bin and stays there for 30 days. You can see what is in it, how long each item has left, and restore any of them yourself — Vault, then Recycle Bin. On the 31st day the document and the encrypted bytes behind it are permanently destroyed and cannot be recovered by you or by us.

During those 30 days the document is already gone from everywhere else: it is out of your Vault's folders and search results, WelX can no longer read, quote or cite it, and anyone you had shared it with has lost access. Only you (and anyone you have given write access to your documents, such as a spouse) can see it in your Recycle Bin and put it back.

Re-uploading the same file while it is in the Recycle Bin restores it rather than creating a second copy.

Encrypted backup copies of certain other information may persist for a brief period through routine backup-lifecycle processes before they are overwritten.

7. Your Privacy Rights

7.1 All Users

Regardless of where you live, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate personal information
• Deletion: Request deletion of your personal information
• Portability: Receive your data in a structured, machine-readable format
• Withdraw consent: Withdraw consent for optional data processing at any time
• Disconnect accounts: Remove any connected financial account at any time

7.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You may request the categories and specific pieces of personal information we have collected about you, the sources, the business purposes, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioral advertising. This right does not apply to our Services.
• Right to Limit Use of Sensitive Personal Information: We use sensitive personal information (financial account data) only to provide the Services you requested. We do not use it for profiling or advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Categories of personal information collected (per CCPA):

• Identifiers (name, email, phone)
• Financial information (account numbers, transaction history, balances)
• Internet activity (usage data, log data)
• Professional information (CPA relationship, employer)
• Inferences (AI-generated financial insights)

Authorized agents: You may designate an authorized agent to submit requests on your behalf. We will require verification of both your identity and the agent's authority.

7.3 Other State Privacy Laws

We comply with applicable state privacy laws, including those in Colorado (CPA), Connecticut (CTDPA), Virginia (VCDPA), and other states with comprehensive privacy legislation. Residents of these states may exercise rights similar to those described above.

7.4 How to Exercise Your Rights

To exercise any privacy right:

• In-app: Settings › Your data to request an export, or Settings › Plan & Payment to delete your account. To remove the figures and facts extracted from a single document, delete that document from your Vault and choose to remove its derived data when prompted.
• Email: privacy@fingro.ai
• WelX: Ask "delete my account" or "download my data" in any WelX conversation, and WelX will walk you through it

We will respond to verifiable requests within 45 days (or 90 days for complex requests, with notice). We will verify your identity before processing any request and may deny or limit a request where we are unable to reasonably verify your identity, your authority to act on behalf of another person, or where fulfilling the request would interfere with our legal obligations, compromise the security of the Services, reveal trade secrets, adversely affect the rights of other users, or prevent us from providing the Services you have requested.

Global Privacy Control (GPC). Where required by applicable law, Fingro recognizes the Global Privacy Control browser signal as a valid request to opt out of the sale or sharing of personal information for cross-context behavioral advertising. As stated in Section 4.1, Fingro does not sell or share personal information in the first place; the GPC signal is honored as confirmation of that posture.

8. Children's Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will promptly delete it. If you believe a child has provided us with personal information, contact us at privacy@fingro.ai.

9. International Data Transfers

Our Services are hosted in the United States (AWS us-east-1 region) and are offered to residents of the United States and Canada. We do not offer the Services to individuals located in the European Economic Area, the United Kingdom, or Switzerland, and account registration from outside the United States and Canada is refused at signup.

If you are a Canadian resident, your personal information is stored and processed in the United States, not in Canada. It is subject to United States law, including lawful access requests by United States authorities, and we handle it under this Privacy Policy. Your rights under Section 7 apply to you in the same way they apply to our United States customers.

If you access your account while travelling outside your country of residence, your information continues to be stored and processed in the United States.

10. Gramm-Leach-Bliley Act (GLBA) Notice

Fingro collects nonpublic personal financial information ("NPI") in the course of providing our Services. Under the GLBA:

• We collect NPI from your financial account connections (via Plaid) and from information you provide directly
• We do not share NPI with non-affiliated third parties except as described in this Privacy Policy, with your consent, or as permitted by law
• We maintain administrative, technical, and physical safeguards to protect NPI as described in Section 5
• We limit access to NPI to employees, contractors, and service providers who need it to provide our Services

Depending on the context of a particular engagement, Fingro may act as a "service provider," "financial institution," or similarly regulated entity under GLBA and analogous state financial-privacy laws. Fingro is not itself a bank, broker-dealer, investment adviser, tax preparer, or fiduciary, and the Services do not establish any such professional relationship between you and Fingro.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Email notification to the address associated with your account
• Prominent notice on our Platform
• Updating the "Last Updated" date at the top of this policy

Your continued use of our Services after notification constitutes acceptance of the updated policy.

12. Contact Us

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

• Privacy inquiries: privacy@fingro.ai
• Data protection requests: privacy@fingro.ai
• Security incidents / responsible disclosure: security@fingro.ai
• Legal inquiries: legal@fingro.ai
• General inquiries: support@fingro.ai

For unresolved privacy concerns, you may file a complaint with your state attorney general or applicable data protection authority.

This Privacy Policy is provided as part of Fingro's commitment to transparency about data practices. Fingro encourages all users to read this document carefully and reach out with any questions.