Privacy Policy

We collect information you provide directly to us, such as when you create an account, link financial accounts, use our services, or contact us for support. **Personal Information:** - Name, email address, and phone number - Date of birth and Social Security Number (for identity verification) - Financial account credentials (encrypted and securely stored) - Transaction history and account balances **Usage Information:** - Device information and IP address - Browser type and operating system - Pages visited and features used - Time spent on the platform

We use the information we collect to: - Provide, maintain, and improve our services - Process transactions and send related information - Send you technical notices, updates, and support messages - Respond to your comments, questions, and requests - Generate personalized financial insights and recommendations - Monitor and analyze trends, usage, and activities - Detect, investigate, and prevent fraud and other illegal activities - Comply with legal obligations

We do not sell your personal information. We may share information in the following circumstances: **Service Providers:** We share data with third-party vendors who perform services on our behalf, such as Plaid for account aggregation and AWS for cloud hosting. **Legal Requirements:** We may disclose information if required by law, regulation, legal process, or governmental request. **Business Transfers:** In connection with a merger, acquisition, or sale of assets, your information may be transferred. **With Your Consent:** We may share information with your explicit consent.

We implement industry-standard security measures to protect your information: - AES-256 encryption for data at rest - TLS 1.3 encryption for data in transit - SOC 2 Type II certified infrastructure - Regular security audits and penetration testing - Multi-factor authentication options - Strict access controls and monitoring While we strive to protect your information, no method of transmission over the Internet is 100% secure.

**Access and Portability:** You can access and download your data at any time from your account settings. **Correction:** You can update your personal information through your account dashboard. **Deletion:** You can request deletion of your account and associated data. Some information may be retained for legal compliance. **Marketing Communications:** You can opt out of marketing emails at any time using the unsubscribe link. **California Residents:** Under CCPA, you have additional rights including the right to know what personal information is collected and the right to opt-out of data sales (we don't sell data). **European Residents:** Under GDPR, you have rights including data portability, the right to be forgotten, and the right to object to processing.

We use cookies and similar technologies to: - Keep you logged in - Remember your preferences - Analyze how our service is used - Improve our platform You can control cookies through your browser settings. Disabling cookies may affect functionality.

We retain your information for as long as your account is active or as needed to provide services. After account deletion: - Personal data is deleted within 30 days - Anonymized analytics data may be retained - Some data may be retained for legal compliance (up to 7 years)

Finley is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us.

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through the app. Continued use after changes constitutes acceptance of the updated policy.

If you have questions about this Privacy Policy or our data practices, please contact us: **Email:** privacy@finley.ai **Address:** Finley Inc., 100 Market Street, Suite 400, San Francisco, CA 94105 **Data Protection Officer:** dpo@finley.ai