Privacy Policy

1. Information We Collect

We collect financial information solely through our integration with Plaid, Inc. ("Plaid"). We do not collect personal information directly beyond what is necessary to provide our financial coaching services.

1.1 Financial Information via Plaid

When you connect your financial accounts through Plaid, we may receive the following information:

• Account information (account name, type, and balance)
• Transaction history (date, amount, merchant, and category)
• Account holder information (name associated with accounts)
• Liability information (loan balances, credit card balances, interest rates)

By using Plaid, you agree to Plaid's End User Privacy Policy, available at: https://plaid.com/legal/#end-user-privacy-policy

2. How We Use Your Information

We use your financial information exclusively to provide financial coaching services, including:

• Analyzing your debt obligations and financial situation
• Providing personalized debt repayment strategies and recommendations
• Tracking your progress toward debt reduction goals
• Generating insights and reports about your financial health

We do not sell your personal information. We do not use your information for advertising purposes.

3. How We Share Your Information

We share your information only in the following limited circumstances:

• Service Providers: We use Plaid to connect to your financial accounts. Plaid's use of your data is governed by their privacy policy.
• Legal Requirements: We may disclose information if required by law, court order, or government request.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will notify you of any such change.

4. AI Coach & OpenAI

Our AI Coach feature is powered by OpenAI's API. When you use the AI Coach, your financial data is sent to OpenAI to generate personalized responses. Important details about this data sharing:

• No Model Training: OpenAI does NOT use API data to train their AI models. Your conversations and financial data are not used to improve OpenAI's systems.
• Data Retention: OpenAI retains API data for up to 30 days solely for abuse and misuse monitoring, after which it is deleted.
• Your Data Ownership: You retain ownership of your inputs and outputs when using the AI Coach.
• Encryption: All data sent to OpenAI is encrypted in transit using TLS.

For more information, see OpenAI's API Data Usage Policy at: https://openai.com/policies/api-data-usage-policies

5. Data Security

We implement industry-standard security measures to protect your information:

• All data is encrypted in transit using TLS 1.2 or higher
• All consumer financial data is encrypted at rest
• Access to data is restricted to authorized personnel only
• Multi-factor authentication is required for account access
• Regular security assessments and vulnerability scans are performed

6. Data Retention

We retain your financial data only for as long as necessary to provide our services or as required by law. When you delete your account or request data deletion, we will securely delete your information within 30 days, except where retention is required for legal or regulatory purposes.

7. Your Rights and Choices

You have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Portability: Request your data in a portable format
• Withdraw Consent: Disconnect your financial accounts at any time through the app or by contacting us
• Opt-Out: Opt out of any non-essential data processing

To exercise any of these rights, contact us at amore@calibratedvision.com.

8. California Privacy Rights (CCPA/CPRA)

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

• Right to know what personal information we collect, use, and disclose
• Right to delete your personal information
• Right to opt-out of the sale of personal information (we do not sell your data)
• Right to non-discrimination for exercising your privacy rights
• Right to limit use of sensitive personal information

To submit a request, contact us at amore@calibratedvision.com. We will verify your identity before processing your request.

9. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

9.1 Legal Basis for Processing

We process your personal data based on your consent, which you provide when you connect your financial accounts through Plaid. You may withdraw consent at any time.

9.2 Your GDPR Rights

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to lodge a complaint with a supervisory authority

9.3 International Data Transfers

Your data may be transferred to and processed in the United States. We ensure appropriate safeguards are in place, including standard contractual clauses approved by the European Commission, to protect your data during such transfers.

9.4 Data Controller

Calibrated Vision is the data controller responsible for your personal data. For GDPR inquiries, contact: amore@calibratedvision.com

10. Children's Privacy

SnapFree is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Effective Date" above. Your continued use of SnapFree after changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us: