Terms of Service

Fingro AI, Inc. ("Fingro," "we," "us," or "our") Version: 4.6 Effective Date: 2026-09-26 Last Updated: 2026-10-23 Sections 6.2–6.4 take effect: 2026-10-14 (on publication, per Section 14)

Version 4.6 changes (2026-10-23): Describes the Recycle Bin in Section 7.2, because version 4.5 (2026-10-19) told only half of it. 4.5 said a deleted document's bytes were "retained for 30 days so that an accidental deletion can be recovered on request". The 30 days are now a Recycle Bin you can open and restore from yourself, without making a request to anyone.

What was already true is unchanged and restated: on the day you press delete, the document leaves your Vault's folders, your search results and WelX, and anyone you shared it with loses access. What 7.2 now adds is where it goes, that you can get it back, and that on the 31st day it is destroyed beyond recovery by you or by us.

This takes effect on publication under Section 14. It reduces no right — it adds a recovery you did not have and describes it accurately. No change to subscription pricing, renewal terms, refunds, WelX credit allocations, or acceptable use.

Version 4.5 changes (2026-10-19): Corrects Section 7.2, which said a deleted document's file "are permanently removed" — immediately. That was not true of the bytes. Our document storage keeps the previous version of a file when it is deleted, and until 2026-10-19 there was no rule expiring those copies, so they were kept indefinitely. Measured on the day this was found: 71 delete markers and 9 retained versions, none reachable by any customer and none expiring.

Both halves now match. The storage keeps a deleted file's encrypted bytes for 30 days and destroys them after that, and 7.2 says so. What was always true stays true: the document leaves your Vault, your search results and WelX immediately, and stops being visible to anyone you shared it with.

This takes effect on publication under Section 14. It reduces no right — retention went from unbounded to bounded, and a statement that was not accurate became one that is. No change to subscription pricing, renewal terms, refunds, WelX credit allocations, or acceptable use.

Version 4.4 changes (2026-10-14): Adds an acceptable-use content policy to Section 6, which previously described how the Services may be used but never what may be stored in the Vault. New 6.2 lists content that may not be uploaded, naming child sexual abuse material and sexually explicit material explicitly. New 6.3 discloses that uploaded images are screened automatically for sexually explicit content, states that we have the right but not the obligation to monitor, and admits that no screen is perfect in both directions — with an address to write to when it gets something wrong, and an address to report content at. New 6.4 covers enforcement.

No statutory reporting commitment is made in this version. Fingro is not yet registered with NCMEC as an electronic service provider, and a term describing a report we cannot currently file would be a promise rather than a policy. Our obligations under the law apply whether or not these Terms restate them, and how we respond to legal process continues to be described in the Privacy Policy.

6.2 is deliberate about what it does NOT restrict: a bar tab, a casino win/loss statement, a dispensary invoice, a firearm purchase record and a medical bill are ordinary financial documents and are all welcome. The screening is narrowed to sexual content for exactly this reason — the automated classifier also recognises alcohol, gambling and tobacco, and acting on those would refuse real financial records.

Section 14 is amended in the same version. It previously promised 30 days' notice for every material change with no exception, which would have meant running for a month with a published prohibition and nothing enforcing it. Section 14 now separates material changes — ones that reduce a right, increase an obligation, or change what you pay, which still get their 30 days — from changes required by law or addressing safety, security or abuse, which take effect on publication. You are notified either way; for the second kind the notice accompanies the change instead of preceding it.

Sections 6.2–6.4 take effect on publication under that provision, and screening is switched on with them. They reduce no right anyone holds: no stored document is affected, nothing is deleted, and no feature in use is withdrawn. What changes is that a new upload of sexually explicit material is refused. No change to subscription pricing, renewal terms, refunds, WelX credit allocations, or data retention.

Version 4.3 changes (2026-10-12): Opens Section 2 (Eligibility) to residents of Canada alongside the United States, and states how money is displayed for them. Three things this version is careful to separate: billing stays in U.S. dollars; display for a Canadian resident is in Canadian dollars, converted at a published daily reference rate and marked as indicative; and the tax intelligence remains U.S.-only, so a Canadian resident is a wealth-tracking customer and must not rely on Fingro for CRA or provincial obligations. The signup gate enforcing this lives in backend/services/us_residency.py and was changed in the same release — a clause nobody implements is a liability, not a limit.

Version 4.2 changes (2026-10-01): Tightens Section 2 (Eligibility) to match what the system now enforces. The residency requirement previously read "a legal resident of the United States (or have U.S.-based financial accounts)" — the alternative let a non-resident qualify, which is not who Fingro is built for. It now reads United States residency, explicitly including DC and U.S. territories, and a new paragraph states that we do not offer or market the Services in the EEA, the United Kingdom or Switzerland, that registration from outside the United States is refused at signup, that billing is in U.S. dollars only, and that our tax intelligence covers U.S. federal and state law only and must not be relied on for another country's tax obligations. Reason: Fingro's tax engine is built for U.S. law, so serving users elsewhere would mean giving guidance we cannot stand behind. This is now enforced in code, not only stated here.

Version 4.1 changes (2026-09-26): Adds Section 5.1a (Promotional Codes and Free Trials). Promotional codes and free-trial periods were already offered and used, and the Terms did not mention them at all. 5.1a states how a code is applied, that a code may grant a discount or a free trial, that on an annual plan you receive the LARGER of the promotional rate and the standard annual discount and never both, that a payment method is collected before a trial begins and billing starts automatically when the trial ends unless you cancel, and that a free trial is limited to one per person (enforced through a one-way hash of the e-mail address, consistent with the identifier retention already described in Section 5.11), with an appeal route. No change to subscription pricing, renewal terms, refunds, WelX credit allocations, data retention, or acceptable use.

Version 4.0 changes (2026-09-05): Section 5.8 restated to match the shipped credit-based WelX usage model. "Messages" is renamed to credits throughout §5.8 to reflect that a single WelX interaction often consumes multiple units depending on complexity. Monthly included allocations updated to the current values: Individual 200, Couple 300, Business Owner 600, Dependent 75. Top-off packs updated to the current offerings: 60 credits for $2.99 and 125 credits for $5.99. The token-based counting formula (1 credit ≈ 3,000 AI tokens) is unchanged. No change to subscription pricing, renewal terms, refund policy, acceptable use, or any other user right.

Version 3.9 changes (2026-07-15): Removed all references to Teller.io as a data-aggregation provider. Plaid is now our sole account-aggregation partner. No change to service terms, data handling, user rights, or the aggregation flow itself — only the identity of the upstream provider is being narrowed.

Version 3.8 changes (2026-07-14): Pricing catalog updated to v7 — Individual $29.99/mo, Couple $39.99/mo, Business Owner $99.99/mo. Annual pricing is 20% off across all three tiers ($287.88 / $383.88 / $959.88 per year). Existing subscriptions are unchanged and remain at the price they were purchased at, per Section 5.1. No changes to service terms, data handling, or acceptable use.

Version 3.7 changes (2026-06-20): Rebrand of the AI assistant from "GroX" to WelX — Fingro's AI-powered financial assistant ("Financial wellness, compounded."). Section 5.8 ("WelX Intelligence Usage and Message Allocation") and all other references updated. No change to subscription terms, pricing, message allocations, acceptable use, or user rights.

Version 3.6 changes (2026-06-11): Launch pricing v7 — three retail tiers (Individual / Couple / Business Owner), a flat 20% annual discount on all three, and Business Owner now includes up to three business entities (was: one), with each additional entity at $24.99/mo. No change to subscription terms, renewal mechanics, refund policy, or the household freeze and sponsorship lifecycle clauses introduced in v3.5. Section 5.4 updated to reflect the 3-entity inclusion. The canonical price list remains the Pricing Page at fingro.ai/pricing.

Version 3.5 changes (2026-06-07): Revenue Leakage Guardrails (RLG) rollout. (a) Section 5.6 rewritten to define the 30-day Grace / 90-day Suspended / Day 121 Deletion lifecycle that applies when an employer sponsorship ends, including the household-composition freeze during non-active states. (b) New Section 5.11 (Anti-Abuse and Pattern Detection) discloses the post-deletion hashed-identifier registry, the 7-year fraud-prevention retention, the one-time-warning policy, annual-prepayment requirement on second occurrence, tax-tourist override, and the appeal path. No change to pricing, plan features, or your existing data-portability rights — additions are limited to the post-sponsorship lifecycle and abuse-pattern detection.

Version 3.4 changes (2026-05-23): (a) Pricing tables moved out of the Terms body and replaced with a reference to fingro.ai/pricing — the renewal-notice, rate-change, and affirmative-consent protections in Section 5 continue to apply unchanged. (b) Added Section 1.2 (Electronic Communications consent under the U.S. E-SIGN Act), Section 4.4 (No Professional Relationship), Section 4.5 (Right to Modify the Services), Section 5.1 (Affirmative consent required before any subscription price increase), and Section 5.7 (Authorization to Connect Financial Accounts). (c) Force-majeure list expanded consistent with industry practice. No reduction of any prior commitment.

Version 3.3 changes (2026-05-22): Legal entity name updated to Fingro AI, Inc. (previously "Fingro, Inc."). No change to your rights or our obligations — only the formal name of the contracting entity.

Version 3.2 changes (2026-05-19): Removed pricing claims for features not yet available — the active/dormant entity split ($14.99/$5.99) is now a single $14.99 rate with a roadmap note, and the Property Intelligence, Estate Planning, and Market Pulse add-ons (which were never built as standalone SKUs) are removed from Section 5.5. They will be re-listed only after they ship.

Version 3.1 changes (2026-05-19): Expanded Section 5 to disclose (a) automatic monthly renewal and how to cancel, (b) mid-cycle charges that can occur when you add a spouse, dependent, or business entity, (c) Usage Limits and Plan Guardrails (the in-product upgrade prompt that appears when a tier limit is reached), and (d) Employer Sponsorship and Coverage Policy (when an employer pays for your plan and who pays when household events grow it). Vault storage allocations corrected to 10 GB / 25 GB / 50 GB.

Version 3.0 changes (2026-04-30): Subscription plans simplified to three tiers — Individual ($19.99/mo), Couple ($29.99/mo), and Business Owner ($49.99/mo) — with optional $9.99/mo Dependent add-ons and a-la-carte entity tracking. Annual billing is also available; the applicable discount, if any, is shown at Checkout. The prior Essential and Premier plans are no longer offered.

1. Agreement to Terms

These Terms of Service ("Terms") govern your access to and use of the Fingro.ai platform, website, and related services (collectively, the "Services") operated by Fingro AI, Inc. By creating an account, accessing, or using our Services, you agree to be bound by these Terms.

If you are using the Services on behalf of an organization, you represent and warrant that you have the authority to bind that organization to these Terms.

If you do not agree to these Terms, do not use our Services.

1.2 Electronic Communications

By creating an account or using the Services, you consent to receive communications from Fingro electronically — including notices, disclosures, agreements, billing communications, security alerts, legal updates, and other records that may be required by law to be in writing. You agree that any electronic notice or disclosure provided through the Platform, by email to the address associated with your account, or by in-product banner satisfies any legal requirement that such notice or disclosure be in writing, in accordance with the U.S. Electronic Signatures in Global and National Commerce Act (15 U.S.C. § 7001 et seq.) and analogous state laws.

You are responsible for maintaining a current and valid email address associated with your account so that you can receive these communications. You may withdraw consent for electronic communications only by closing your account; the Services cannot be operated under paper-based delivery.

2. Eligibility

To use our Services, you must:

• Be at least 18 years of age
• Be a legal resident of the United States (including the District of Columbia and U.S. territories) or of Canada
• Have the legal capacity to enter into a binding agreement
• Not be prohibited from using the Services under applicable law

Fingro is offered only in the United States and Canada. We do not offer or market the Services to individuals located in the European Economic Area, the United Kingdom, or Switzerland, we do not monitor the behavior of individuals in those regions, and we refuse account registration from outside the United States and Canada at signup.

The Services are priced and billed in U.S. dollars. Where you are resident in Canada, balances and totals are displayed in Canadian dollars, converted from the currency each account or asset is held in using a published daily reference rate; converted figures are indicative and are not a quotation or an offer to exchange currency.

Our tax intelligence is built for U.S. federal and state tax law only. It is not suitable for, and must not be relied on for, Canadian federal or provincial tax obligations, or those of any other country. Canadian residents should treat Fingro as a wealth-tracking service and consult a Canadian tax professional for anything concerning the Canada Revenue Agency or a provincial tax authority.

3. Account Registration and Security

3.1 Account Creation

You may create an account directly or through an invitation from a CPA, financial advisor, or employer wellness program. You agree to:

• Provide accurate, current, and complete information during registration
• Maintain and promptly update your account information
• Keep your password confidential and not share your account credentials
• Notify us immediately of any unauthorized access to your account

3.2 Account Security

You are responsible for all activity that occurs under your account. We implement multi-factor authentication (MFA), encrypted sessions, and other security measures, but you acknowledge that no security system is impenetrable. We are not liable for losses resulting from unauthorized access caused by your failure to safeguard your credentials.

3.3 One Account Per Person

Each individual may maintain only one Fingro account. Creating multiple accounts to circumvent usage limits, pricing tiers, or these Terms is prohibited.

4. Description of Services

4.1 What Fingro Provides

Fingro is a personal financial intelligence platform that provides:

• Financial aggregation: Connect and view your bank, investment, credit, and loan accounts in one place
• AI-powered insights: WelX, our AI assistant, analyzes your financial data to provide spending analysis, cash flow forecasts, net worth tracking, and wealth intelligence
• Document Vault: Secure storage and organization for financial documents
• Transaction management: Automatic categorization, search, and analysis of transactions
• Proactive monitoring: Alerts about account changes, unusual transactions, and financial opportunities
• Actions and planning: AI-generated action items and financial planning tools

4.2 What Fingro Is NOT

Fingro is not a financial advisor, broker-dealer, investment advisor, tax preparer, accountant, bank, or insurance provider.

• Not financial advice: Insights, projections, and recommendations provided by WelX and the Platform are for informational and educational purposes only. They do not constitute financial, investment, tax, or legal advice. Fingro uses AI models from Anthropic, Perplexity, and other providers — none of which are licensed financial advisors.
• Not investment recommendations: Any mention of securities, asset allocation, or investment strategies is informational only and should not be construed as a recommendation to buy, sell, or hold any security.
• Not tax advice: Tax-related insights, optimization suggestions, and document analysis are informational tools — not a substitute for professional tax preparation or advice from a licensed CPA or tax attorney.
• Not a fiduciary: Fingro does not act as a fiduciary to any user. We do not owe you a fiduciary duty.
• Not a bank: We do not hold deposits, issue credit, or facilitate fund transfers. We connect to your existing accounts through a licensed third-party provider (Plaid).

You should consult qualified professionals before making financial, investment, or tax decisions.

4.3 Third-Party Financial Connections

When you connect financial accounts, you authorize Plaid, Inc. (our licensed data aggregation partner) to access your account information on your behalf. Your use of this service is also governed by:

• Plaid End User Privacy Policy

We are not responsible for the availability or accuracy of data provided by your financial institutions through these partners. Financial institutions and third-party providers may modify, restrict, interrupt, or discontinue data connectivity at any time, and Fingro does not guarantee uninterrupted access to linked financial accounts or third-party integrations.

Authorization to connect. You represent and warrant that, for each financial account you connect to the Services (whether through Plaid, manual entry, or any future connectivity provider), you (i) are an authorized owner, joint owner, or fiduciary of the account, or (ii) hold a valid written authorization from the owner that permits you to connect that account to a third-party financial-aggregation service such as Fingro. You are responsible for promptly disconnecting any account for which your authorization ends.

4.4 No Professional Relationship

Use of the Services does not create an attorney-client, accountant-client, broker-customer, investment-adviser, tax-preparer, fiduciary, or other professional relationship between you and Fingro. Nothing in the Services should be construed as the rendering of professional advice for which a license, registration, or similar credential is required, and you should consult qualified, licensed professionals before making material financial, tax, legal, investment, or insurance decisions.

4.5 Right to Modify the Services

Fingro reserves the right, at any time and from time to time, to modify, suspend, discontinue, or remove any aspect of the Services — including integrations, AI models, third-party data providers, features, and user-facing functionality — for any reason, including to improve security, quality, performance, compliance, or commercial viability. We will provide reasonable advance notice of changes that materially reduce functionality during an active paid subscription term and will not retroactively change the price you owe for the then-current paid term except as provided in Section 5.2.

5. Subscription and Payment

5.1 Subscription Plans and Pricing

Fingro offers tiered subscriptions designed for individuals, couples, dependents within a household, and business owners. The current list of plans, applicable monthly and annual prices, included features, and any active promotions is published at fingro.ai/pricing (collectively, the "Pricing Page"). The Pricing Page is incorporated into these Terms by reference. The price you pay for any active subscription is the price displayed on the Pricing Page at the time you purchased or last renewed that subscription, except as modified for a Renewal Term in accordance with Section 5.2.

Fingro will not increase the price of any active subscription during its then-current paid term, and will not increase the price for a Renewal Term except as described in Section 5.2. Any optional add-ons you accept in-product are billed at the rates shown in the in-product disclosure at the time of acceptance and require your affirmative confirmation before any charge is applied (see Section 5.3).

5.1a Promotional Codes and Free Trials

From time to time we offer promotional codes, including at conferences and through partners. A code is entered at signup and, where it applies, is reflected in the price shown to you before you enter payment details.

• What a code can do. A promotional code may reduce the subscription price, or may grant a free trial period, or both. What a specific code does is shown on the signup screen before you pay.
• Annual plans — the larger discount, never both. Annual pricing is already discounted relative to paying monthly (see the Pricing Page). If you apply a promotional code to an annual plan, you receive whichever single discount is larger — the promotional rate or the standard annual discount — applied to the full undiscounted yearly amount. The two are never combined. If the standard annual discount is the better of the two, it is applied and the code has no additional effect; the signup screen says so.
• Free trials require a payment method. Where a code grants a free trial, a valid payment method is collected before the trial begins. You are not charged during the trial. When the trial ends, billing begins automatically at the applicable price for your plan unless you cancel before the trial's final day. You can cancel at any time during the trial from Settings > Plan & Payment and you will not be charged.
• One free trial per person. A free trial is available once per person, not once per account. To enforce this, and only for this purpose, we store a one-way (irreversible) hash of the e-mail address used to obtain a trial. The hash cannot be reversed to recover the address, is not linked to your account record, and is retained after an account is closed precisely so that the limit survives closing and reopening an account. If you believe a trial has been declined in error — for example, a shared household address — contact support@fingro.ai and we will review it.
• Expiry and withdrawal. A promotional code may carry an expiry date or a limit on total redemptions, and is only honored while valid. We may withdraw an unredeemed code at any time. A code already applied to an active subscription continues to apply on the terms shown when you purchased, per Section 5.1.

5.2 Billing and Automatic Renewal

• Subscriptions are billed monthly (or annually, if elected) in advance on the anniversary of your subscription start date.
• All prices are in U.S. dollars and exclude applicable taxes, which are calculated by Stripe based on your billing address.
• Payment is processed through our third-party payment processor (Stripe).
• Authorization. By starting a subscription, you authorize Fingro to charge your saved payment method, on each agreed-upon periodic renewal date, for: (a) the then-current subscription fee for your plan, (b) any add-ons you have purchased or accepted in-product, (c) any plan upgrades or coverage changes you confirm during the term (see Section 5.3), and (d) applicable taxes — until you cancel.
• Automatic renewal. Your subscription automatically renews at the end of each Initial Term and each Renewal Term at the then-current price for your plan and any active add-ons. To avoid renewal and the associated charge, cancel your subscription at least 24 hours before the last day of the current term from Settings > Plan & Payment. Cancellation takes effect at the end of the current paid period; you retain access until that date and are not entitled to a prorated refund of any portion of the fee already paid.
• Price changes. We may change subscription fees from time to time. We will not change the fee for your current paid term; a new price applies only to the next Renewal Term and only after we provide at least 30 days' advance notice by email.
• Failed payments. If your payment method is declined, we will retry the charge for up to 14 days. If payment remains unsuccessful, your subscription will move to a paused or expired state and access to paid features may be restricted until payment is updated.

5.3 Plan Upgrades and Mid-Cycle Charges

Your plan may change during a billing cycle when your household composition or business activity changes. Some changes you initiate directly (adding a spouse or dependent in Settings); others are detected from documents you upload or accounts you connect. Every charge that increases what you pay requires your explicit, in-product confirmation before it is applied to your card.

When a triggering event is detected, Fingro displays an upgrade prompt that shows: (a) the change being made, (b) the new monthly amount, (c) the prorated amount that will be charged today, if any, and (d) who pays — you or your sponsoring employer (see Section 5.6). You may decline; declining preserves your current plan and does not apply the change.

The most common upgrade triggers are:

• Add a spouse → Individual plan moves to Couple. Confirming this prompt authorizes a recurring increase of $10.00/month (the difference between Individual and Couple) effective immediately, prorated for the remainder of the current billing period.
• Add a dependent (non-spouse). Confirming this prompt authorizes a $9.99/month add-on per dependent, effective immediately, prorated for the remainder of the current billing period.
• Add a business entity → Business Owner plan or entity add-on. Confirming this prompt authorizes the applicable monthly fee for the entity (see Section 5.4).

Lateral or downward changes (e.g., a spouse leaves the household via a tax-filing-status update) do not require a confirmation prompt and are applied automatically; if they reduce your bill, the reduction takes effect at the next billing cycle (we do not issue prorated refunds for mid-cycle reductions).

5.4 Business Entity Detection and Tracking

When you upload business tax documents (1065, 1120, Schedule C) or connect business bank accounts, we automatically detect and identify your business entities. This detection is based on authoritative IRS documents and financial institution data.

Entity detection is automatic; entity billing requires your explicit acceptance.

For each detected entity, you will be presented with a tracking acceptance prompt that includes:

• The entity name and type (LLC, S-Corp, C-Corp, etc.)
• The entity status (active or dormant, based on filing recency)
• The monthly tracking fee
• A description of the intelligence services included

You must affirmatively accept tracking for each entity before billing begins. You may decline tracking — your entity record will be preserved but active intelligence (P&L analysis, compliance alerts, tax optimization) will not be available for that entity.

Current per-entity tracking pricing is published on the Pricing Page. Up to three (3) entities are included in the Business Owner plan at no extra cost; each additional entity beyond three is billed at the per-entity rate disclosed in the in-product acceptance prompt before tracking begins. A reduced-fee dormant-entity tier (for entities with no recent filing or transaction activity) is on our roadmap but is not currently available; until it ships, all tracked entities beyond the included three are billed at the standard per-entity rate.

5.5 Add-Ons

Optional add-ons (such as dependent seats and additional business entities) are available at the per-add-on rates published on the Pricing Page and displayed in the in-product acceptance prompt before any add-on is activated. Your active add-ons and their current rates are visible in Settings > Plan & Payment. We may introduce additional optional add-ons over time; any new add-on will be available only after it is built and listed on the Pricing Page with its rate and included features.

5.6 Employer Sponsorship and Coverage Policy

If you joined Fingro through an employer-sponsored wellness program, your employer pays the subscription fee for the plan tier they have purchased on your behalf (your "Covered Tier"). Your employer's payment continues until either (a) your employer cancels the sponsorship from their admin console, or (b) the employer subscription term ends and is not renewed.

Coverage Policy. Your employer configures, in their admin console, a Coverage Policy that determines who pays when household events grow your plan beyond your Covered Tier. The policy has three independent settings, each of which is either "Employer Pays" or "Employee Pays":

• Spouse coverage — applied when adding a spouse moves you from Individual to Couple.
• Dependent coverage — applied when you add a non-spouse dependent (the $9.99/month add-on).
• Business entity coverage — applied when you add a business entity (typically Employee Pays; business entities are personal assets).

When you confirm a Section 5.3 upgrade prompt, the message in the prompt is determined by the current Coverage Policy:

• If the policy is Employer Pays for that category, the prompt shows "[Employer name] covers this — no charge to you." The change is recorded, your Covered Tier grows, and the prorated delta is added to your employer's next annual renewal invoice. Your card is not charged.
• If the policy is Employee Pays, the prompt shows the amount that will be charged to your saved payment method, and the charge proceeds only if you confirm.

When sponsorship ends. If your employer cancels your sponsorship (or you leave your employer), your account is preserved and your data is unaffected. Your subscription converts to a personal subscription at the same tier you were on, billed to a payment method you provide. The transition follows a 121-day lifecycle (the "Revenue Leakage Guardrails" or "RLG" lifecycle):

• Grace Period (Days 1–30). Your account remains fully accessible. You may add a personal payment method at any time to keep continuous service at the same tier. During this window, your employer may also Reactivate your seat from their admin console, which restores the original sponsorship with no charge to you.
• Suspended (Days 31–120). If no payment method is added during the Grace Period, your account moves to a read-only Suspended state. Your data, household configuration, transactions, documents, and AI memory are preserved without alteration. You may not access or modify them until you reactivate. To reactivate, you must pay (a) back-dues for each month you were Suspended (rounded up to whole months at your tier's monthly rate), plus (b) the first month of forward service. Reactivation is processed via a single Stripe checkout. Your employer cannot Reactivate your seat once you are in Suspended state; only you can reactivate, via personal payment.
• Day 121 — Deletion. If you do not reactivate by Day 121, your account is permanently deleted. We retain hashed (one-way, non-reversible) identifiers in a fraud-prevention registry for seven (7) years as described in our Privacy Policy (Section 6); no plaintext personal data is retained.

Household composition is frozen during the Grace Period and Suspended state. You may not add a spouse or dependent until the account returns to Active state.

What the employer can and cannot see is described in our Privacy Policy (Section 4.4) and Data Processing Agreement.

5.7 Spouse Inclusion

Spouse is included at no additional cost on the Couple, Business Owner, and any higher plan when validated by tax return filing status (Married Filing Jointly or Married Filing Separately) or when added as a family member with a spouse relationship. Adding a spouse while on the Individual plan triggers the upgrade prompt described in Section 5.3.

5.8 WelX Intelligence Usage and Credit Allocation

Each subscription plan includes a monthly allocation of WelX credits:

How credits are counted: Each interaction with WelX consumes one or more credits based on computational complexity. A simple question (e.g., "What's my net worth?") typically consumes 1 credit. A complex financial analysis involving multiple data sources, calculations, and tool operations (e.g., "Analyze my retirement trajectory with Social Security optimization") may consume several credits, reflecting the additional AI processing required.

The approximate credit cost of each interaction is determined by the following formula: one credit per 3,000 AI tokens processed, rounded up to the nearest whole credit, with a minimum of 1 credit per interaction. This formula is fixed for the duration of your subscription term and will not change without 30 days' prior notice.

Visibility: Your current credit usage and remaining allocation are displayed in Settings > Plan & Payment at all times. You may check your usage before and after any WelX interaction.

At 90% usage: WelX continues to function but may provide shorter responses using our most efficient AI model.

At 100% usage: WelX will notify you that your monthly allocation has been reached. You may purchase additional credits at any time:

• 60 credits: $2.99 (one-time, non-recurring)
• 125 credits: $5.99 (one-time, non-recurring)

Purchased credit packs are applied immediately, restore full AI capability, and expire at the end of the current billing period. Unused credits (included or purchased) do not roll over to the next billing period.

Excluded from credit count: Automated system functions (morning briefs, proactive alerts, background enrichment) do not count against your credit allocation. Only user-initiated WelX conversations are counted.

5.9 Cancellation and Refunds

• You may cancel your subscription at any time from Settings > Plan & Payment.
• Cancellation takes effect at the end of your current billing period; auto-renewal is disabled at the moment you cancel.
• You retain access to the Services until the end of your paid period.
• We do not provide prorated refunds for partial billing periods.
• After cancellation, you may export your data for 30 days before account deletion. A $9.99/month Vault Preservation option is offered before deletion if you wish to retain access to your stored documents without an active subscription.
• Entity tracking acceptances are terminated upon cancellation.

5.10 Usage Limits and Plan Guardrails

Each subscription tier includes specific limits on what you can do without upgrading. The current limits are:

How a limit is reached. When an action would exceed a limit (uploading a document past the storage quota, adding a dependent past the included count, adding a business entity not covered by your tier), the Platform displays an upgrade prompt that shows the limit hit, the option that would resolve it (upgrade, add a slot, or remove an item), and the price. The action that would have exceeded the limit is held until you confirm the upgrade, add the slot, or remove the conflicting item. We may refuse to complete the action if you decline.

Plan-wide guardrails. We may, in addition, apply rate limits, throttle, or temporarily restrict access to features in cases of suspected abuse, unusual automation, or extraordinary load. We will use commercially reasonable efforts to notify you before applying a restriction in the absence of suspected abuse.

5.11 Anti-Abuse and Pattern Detection ("Revenue Leakage Guardrails")

Fingro is designed for continuous, year-round financial intelligence. To prevent patterns of use that conflict with this purpose (including but not limited to repeated short-cycle signup-and-cancel patterns that align with tax-season needs), we operate the following anti-abuse layer:

• Hashed identifier retention. When an account is deleted (whether at your request, or via the Day 121 endpoint of the Section 5.6 lifecycle), we retain one-way, salted SHA-256 hashes of certain identifiers — email, phone, payment instrument fingerprint, Social Security Number (if previously provided through a tax form), Employer Identification Number (if applicable), and a name/date-of-birth composite — for fraud-prevention purposes only. No plaintext personal data is retained beyond the routine deletion process described in Section 6 of our Privacy Policy. Hashes are retained for seven (7) years, consistent with IRS tax-record retention standards, and may be re-derived only against identifiers re-presented at signup to detect repeat sign-ups.
• Pattern detection at signup. If a new signup matches an entry in the hashed-identifier registry, we may apply one or more of the following:
  • A written notice (one-time warning), informing you that we detected a prior account and explaining the policy.
  • Annual prepayment requirement. If a second match occurs after a prior warning, or if a single match aligns with a tax-tourist pattern (account previously cancelled between May and December and the new signup occurs between January and April), we may require prepayment for one (1) full year before completing your signup.
  • Reactivation back-dues. If you were previously deleted via the Section 5.6 Day 121 endpoint after lapsed sponsorship and reactivate within the 7-year hashed-identifier window, we may charge back-dues for the period since your prior deletion, at the tier you were previously on, capped at twelve (12) months.
• User-requested deletions. If your prior account was deleted at your express request (a privacy-rights deletion under Section 7), no back-dues will be charged on re-signup; you will be treated as a new user.
• Appeal. If you believe a pattern flag is incorrect (for example, a household member sharing identifiers, or identity theft), you may appeal to support@fingro.ai, and we will review and unblock signup where appropriate.

We disclose this policy explicitly so that you understand both how we retain hashed data after deletion and what behaviors will trigger it. The policy applies only to repeat use patterns; no enforcement is applied to first-time signups.

6. Acceptable Use

6.1 You Agree Not To:

• Use the Services for any illegal purpose or in violation of any applicable law
• Access or attempt to access another user's account
• Circumvent, disable, or interfere with security features of the Services
• Use automated scripts, bots, or scrapers to access the Services (except through our documented APIs)
• Reverse engineer, decompile, or disassemble any part of the Services
• Upload malicious files, viruses, or harmful code to the Vault
• Use WelX to generate content that is illegal, harmful, or deceptive
• Resell, sublicense, or redistribute access to the Services
• Impersonate any person or entity
• Interfere with or disrupt the integrity or performance of the Services
• Attempt to gain unauthorized access to our systems or networks

6.2 Content You May Not Store

The Vault is for your financial life — documents, statements, records, and the photographs of them. It is not general-purpose file storage, and the following may not be uploaded to it or stored in it:

• Child sexual abuse material. Any depiction of the sexual exploitation or abuse of a minor. There is no exception to this and no context in which it is permitted.
• Sexually explicit material. Pornography and sexually explicit images or video, whether or not they involve you and whether or not everyone depicted consented.
• Content that is unlawful to possess or distribute, or that infringes someone else's copyright, trademark, or other rights.
• Content intended to harass, threaten, or defame another person.
• Malware, or files designed to compromise a system.

This list is about what may be stored. Nothing here restricts the financial records you keep: a bar tab, a casino win/loss statement, a dispensary invoice, a firearm purchase record and a medical bill are all ordinary financial documents, and all of them are welcome.

6.3 Screening, and What We Do and Do Not Promise

We use automated tools to screen images uploaded to the Vault for sexually explicit content. An image identified as such is refused at upload and is not stored. These tools run inside Fingro's own cloud environment; the sub-processors involved are listed in our published sub-processor register, referenced by our Privacy Policy.

We have the right to screen, review, refuse, and remove content, but we are under no obligation to monitor it. No automated screen is perfect. Screening may miss prohibited content, and it may occasionally refuse something legitimate — if that happens to you, write to support@fingro.ai and a person will look at it. Our not having detected something is not permission to store it, and nothing in this section makes us responsible for content a user uploads.

If you believe content stored through Fingro violates this Section, report it to support@fingro.ai with "Content report" in the subject line. How we respond to lawful requests for your information is described in our Privacy Policy.

6.4 Enforcement

We may remove or refuse content, and suspend or terminate an account, for a violation of this Section. For the content in 6.2 we will generally act without prior notice, and for child sexual abuse material we will terminate the account. Where we remove content for a reason that may have been a mistake, we will tell you what was removed and how to contest it.

6.5 Usage Limits

• API rate limits apply as described in our documentation.
• Vault storage and other plan-specific limits are described in Section 5.10. Exceeding a limit triggers an in-product upgrade prompt as described there.
• WelX credit allocations are described in Section 5.8.

We reserve the right to suspend or terminate accounts that violate these usage policies.

7. Intellectual Property

7.1 Our Intellectual Property

The Services, including all software, algorithms, AI models, user interface designs, logos, trademarks, and documentation, are owned by Fingro AI, Inc. and protected by intellectual property laws. You are granted a limited, non-exclusive, non-transferable, revocable license to use the Services for your personal, non-commercial financial management purposes.

7.2 Your Content

You retain ownership of all data, documents, and content you provide to the Services ("Your Content"). By using the Services, you grant us a limited license to use, process, and store Your Content solely to provide and improve the Services.

Document deletion vs. derived intelligence: When you delete a document from your Vault, it is removed from your Vault's folders, your search results and WelX immediately, and anyone you had shared it with loses access. The document then sits in your Recycle Bin for 30 days, where you can see it and restore it yourself if the deletion was a mistake. On the 31st day the document and the encrypted bytes behind it are permanently destroyed and cannot be recovered by you or by us. Our Privacy Policy (Section 6) describes this in full. However, factual information previously extracted from that document (such as business entity names, financial figures, filing dates, and profile attributes) is retained in your financial profile as "Derived Intelligence." This Derived Intelligence is necessary to maintain the accuracy of your financial history, net worth snapshots, and AI-generated insights.

To fully remove all Derived Intelligence associated with a document, you may submit a data deletion request under Section 8 (Privacy), which will remove both source documents and all derived data.

This license terminates when you close your account and your data retention period expires.

7.3 AI-Generated Content

Insights, recommendations, summaries, and other content generated by WelX ("AI Output") are provided as part of the Services. You may use AI Output for your personal financial planning. AI Output is generated based on your data and general financial knowledge — it is not guaranteed to be accurate, complete, or suitable for your specific situation.

7.4 Feedback

If you provide feedback, suggestions, or ideas about the Services, you grant us an unrestricted, perpetual, irrevocable license to use such feedback for any purpose without compensation.

8. Disclaimers

8.1 "As Is" and "As Available"

THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR ACCURACY.

8.2 Financial Data Accuracy

We strive to display accurate financial data, but we depend on third-party data sources (your financial institutions, Plaid, Finnhub). We do not guarantee that:

• Account balances are real-time or fully accurate
• Transaction data is complete or correctly categorized
• Investment valuations reflect current market prices
• AI-generated insights are accurate or appropriate for your situation

Always verify important financial information directly with your financial institutions.

8.3 AI Limitations

WelX is an artificial intelligence assistant. AI-generated content:

• May contain errors, inaccuracies, or outdated information
• Is not a substitute for professional financial, legal, or tax advice
• Should be independently verified before making financial decisions
• May not account for all relevant factors in your unique situation

8.4 Service Availability

We target high availability but do not guarantee uninterrupted access. The Services may be temporarily unavailable due to:

• Scheduled maintenance (we will provide advance notice when possible)
• Unplanned outages or technical issues
• Third-party service disruptions (Plaid, financial institutions, AI providers, payment processors)
• Force-majeure events, including acts of God, natural disasters, war, terrorism, civil unrest, labor disputes, pandemics, governmental action, regulatory orders, telecommunications failures, internet-service-provider failures, denial-of-service attacks, and failures of upstream services or infrastructure that are outside Fingro's reasonable control

From time to time, Fingro may offer beta, preview, pilot, or experimental features ("Beta Features"). Beta Features are provided "AS IS," may contain errors or interruptions, may be modified or discontinued at any time, and are excluded from the service-level commitments and warranties that apply to generally available features.

9. Limitation of Liability

9.1 Exclusion of Damages

TO THE MAXIMUM EXTENT PERMITTED BY LAW, FINGRO, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AND AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO:

• LOSS OF PROFITS, REVENUE, OR DATA
• FINANCIAL LOSSES RESULTING FROM RELIANCE ON AI-GENERATED INSIGHTS
• LOSSES RESULTING FROM UNAUTHORIZED ACCESS TO YOUR ACCOUNT
• LOSSES ARISING FROM THIRD-PARTY SERVICE DISRUPTIONS
• LOSSES ARISING FROM INACCURATE FINANCIAL DATA

9.2 Cap on Liability

OUR TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICES SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNTS YOU PAID TO US IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED DOLLARS ($100).

9.3 Basis of the Bargain

THE DISCLAIMERS AND LIMITATIONS IN SECTIONS 8 AND 9 REFLECT A REASONABLE ALLOCATION OF RISK AND ARE A FUNDAMENTAL PART OF THE BASIS OF THE BARGAIN BETWEEN YOU AND FINGRO. THE SERVICES WOULD NOT BE PROVIDED WITHOUT THESE LIMITATIONS.

10. Indemnification

You agree to indemnify, defend, and hold harmless Fingro and its officers, directors, employees, agents, and affiliates from and against any claims, liabilities, damages, losses, and expenses (including reasonable attorneys' fees) arising out of or in any way connected with:

• Your use of the Services
• Your violation of these Terms
• Your violation of any applicable law or regulation
• Your Content or data that you provide to the Services
• Any financial decisions you make based on information provided by the Services

11. Dispute Resolution

11.1 Informal Resolution

Before filing any formal dispute, you agree to contact us at legal@fingro.ai and attempt to resolve the dispute informally for at least 30 days.

11.2 Binding Arbitration

If informal resolution fails, any dispute arising out of or relating to these Terms or the Services shall be resolved by binding arbitration administered by the American Arbitration Association ("AAA") under its Consumer Arbitration Rules. The arbitration shall be conducted in English, and the seat of arbitration shall be [State].

11.3 Class Action Waiver

YOU AND FINGRO AGREE THAT EACH PARTY MAY ONLY BRING CLAIMS AGAINST THE OTHER IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, OR REPRESENTATIVE PROCEEDING.

11.4 Exceptions

This arbitration agreement does not prevent either party from seeking injunctive or equitable relief in court for intellectual property disputes or unauthorized access to the Services.

11.5 Opt-Out

You may opt out of this arbitration agreement by sending written notice to legal@fingro.ai within 30 days of creating your account. The notice must include your name, email address, and a clear statement that you wish to opt out of arbitration.

12. Termination

12.1 By You

You may terminate your account at any time through Administration > Account > Delete Account. Upon termination:

• Your subscription will be cancelled
• You will have 30 days to export your data
• After 30 days, your personal data will be permanently deleted
• Anonymized, aggregated data may be retained for service improvement

12.2 By Us

We may suspend or terminate your account if:

• You violate these Terms
• You engage in fraudulent or illegal activity
• Your payment method fails and is not updated within 14 days
• You have been inactive for 12 or more consecutive months
• We are required to do so by law

We will provide reasonable notice before termination (except in cases of fraud or legal requirement) and allow you to export your data.

12.3 Survival

Sections 7 (Intellectual Property), 8 (Disclaimers), 9 (Limitation of Liability), 10 (Indemnification), 11 (Dispute Resolution), and this Section 12.3 survive termination of these Terms.

13. CPA and Financial Advisor Access

13.1 Granting Access

You may grant your CPA or financial advisor access to your Fingro data. When you do:

• You control the scope of access (read-only dashboard, documents, AI insights)
• Your CPA/advisor must accept our Professional Terms of Use
• All CPA/advisor access is logged and visible to you in your audit trail

13.2 Revoking Access

You may revoke CPA/advisor access at any time from Administration > Privacy & Security. Revocation takes effect immediately.

13.3 CPA/Advisor Responsibility

Your CPA or financial advisor's use of your data is governed by their professional obligations and their independent relationship with you. Fingro is not responsible for advice or services provided by your CPA or financial advisor.

14. Changes to These Terms

We may modify these Terms at any time.

Material changes take effect after 30 days' notice. A material change is one that reduces a right you have, increases an obligation you owe, or changes what you pay. We notify you of these by:

• Email notification at least 30 days before the change takes effect
• Prominent notice on the Platform

Some changes take effect when we publish them. A change takes effect immediately where it is required by law, where it addresses safety, security, or abuse of the Services, or where it does not reduce a right you already have. Waiting thirty days on a change of that kind leaves people exposed for thirty days, which is the opposite of what a notice period is for. We still tell you — by the same email and the same notice on the Platform — but the notice accompanies the change rather than preceding it.

Your continued use of the Services after the effective date of modified Terms constitutes acceptance. If you do not agree to modified Terms, you must stop using the Services and close your account.

15. General Provisions

15.1 Governing Law

These Terms are governed by the laws of the State of Delaware, without regard to conflict of law principles.

15.2 Entire Agreement

These Terms, together with our Privacy Policy, AI Disclosure, and any applicable Data Processing Agreement, constitute the entire agreement between you and Fingro regarding the Services.

15.3 Severability

If any provision of these Terms is found unenforceable, the remaining provisions remain in full force and effect.

15.4 Waiver

Our failure to enforce any provision of these Terms does not constitute a waiver of that provision.

15.5 Assignment

You may not assign these Terms without our written consent. We may assign these Terms in connection with a merger, acquisition, or sale of assets.

15.6 Force Majeure

We are not liable for any failure or delay in performing our obligations due to circumstances beyond our reasonable control, including natural disasters, war, terrorism, pandemics, government actions, power outages, or internet disruptions.

16. Contact Us

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

• Legal inquiries: legal@fingro.ai
• Privacy: privacy@fingro.ai
• Security incidents: security@fingro.ai
• Support: support@fingro.ai

By using Fingro, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service.