Privacy Policy

This Privacy Policy applies to personal information collected by or on behalf of Finding Wealth through:

1. our website, web application, and any future mobile application;
2. account registration and profile features;
3. financial tools, calculators, dashboards, and linked account features;
4. customer support, emails, forms, contests, surveys, and communications;
5. AI assistant and chat-based features;
6. analytics, diagnostics, and security monitoring tools; and
7. any other interaction where this Privacy Policy is made available.

Depending on how you use the Services, we may collect the following categories of personal information:

A. Identity and Account Information

Name, email address, phone number, login credentials, profile details, account identifiers, billing identifiers, and subscription status.

B. Financial and Transaction Information

Budget information, goals, manually entered financial information, transaction details, account balances, spending categories, debt information, recurring payment information, points and rewards information, and linked financial account data made available through integrations or third-party connection providers selected by you.

C. Technical and Usage Information

IP address, device identifiers, browser type, app version, operating system, time zone, language settings, pages viewed, features used, crash logs, diagnostics, session data, clickstream data, referral sources, and approximate location derived from technical signals.

D. Communications and Support Information

Messages, support requests, feedback, survey responses, call or chat records where applicable, and communications you send to us.

E. AI Interaction Data

Prompts, chat inputs, follow-up messages, user preferences, tool usage patterns, and outputs generated in connection with AI-powered features.

F. Marketing and Preference Information

Newsletter choices, notification preferences, promotion eligibility, referral data, and other preference signals.

G. Sensitive or Higher-Risk Information

In limited circumstances, depending on the features you choose to use, financial profile information may constitute sensitive personal information under applicable law. We seek to limit collection of such information to what is reasonably necessary for the purposes described in this Privacy Policy.

We may collect personal information:

1. directly from you;
2. automatically when you use the Services;
3. from devices and browsers associated with your use;
4. from service providers acting on our behalf;
5. from third-party integrations, institutions, or data providers that you authorize us to access;
6. from payment processors in connection with subscriptions or purchases; and
7. from advertising, analytics, fraud prevention, or identity verification partners, where permitted by law.

We may collect, use, disclose, or otherwise process personal information for the following purposes:

1. to provide, operate, maintain, and improve the Services;
2. to create and administer accounts;
3. to authenticate users and secure accounts;
4. to process payments, subscriptions, renewals, refunds, and billing matters;
5. to provide financial dashboards, calculations, summaries, notifications, planning features, points features, and user-requested outputs;
6. to generate AI responses, suggestions, classifications, and educational insights;
7. to personalize content, features, interfaces, and recommendations;
8. to communicate with you regarding updates, notices, security issues, support matters, or service changes;
9. to detect, investigate, prevent, and remediate fraud, abuse, misuse, unlawful conduct, and security incidents;
10. to perform analytics, research, testing, troubleshooting, and product development;
11. to comply with legal, regulatory, contractual, audit, tax, accounting, insurance, security, and recordkeeping obligations;
12. to establish, exercise, or defend legal claims; and
13. for any other purpose disclosed to you at or before the time of collection or otherwise permitted by applicable law.

Where required by applicable law, we rely on your knowledge and consent for the collection, use, and disclosure of your personal information. In appropriate circumstances, your consent may be express or implied, depending on the sensitivity of the information and the reasonable expectations created by the context.

Where legally required, we will obtain express consent before processing sensitive personal information, enabling optional profiling or tracking functions, using certain optional cookies or analytics technologies, or using information for materially different purposes not previously disclosed.

You may withdraw consent, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may limit or prevent us from providing some or all of the Services.

We and our service providers may use cookies, software development kits, pixels, local storage, device identifiers, log files, and similar technologies to remember preferences, authenticate users, analyze usage, improve performance, detect fraud, and measure marketing effectiveness. We currently use only essential authentication cookies (Supabase session) and operational error-monitoring cookies (Sentry). We do not use advertising, retargeting, or third-party analytics cookies at this time. For a full list of the specific cookies used, see our Cookie Notice.

Where required by law, we will provide appropriate notice and obtain any required consent before deploying non-essential tracking technologies. You may also be able to adjust your device, browser, or in-app settings to limit certain types of tracking.

Where you use Horizon AI or other AI-enabled features, information you submit — including financial context, chat messages, and related data — may be processed by us and by our AI model providers (currently Anthropic, PBC) to generate educational responses, summaries, categorizations, budgeting insights, or other outputs. AI interactions may be retained for safety monitoring, quality assurance, abuse prevention, troubleshooting, and service improvement purposes, subject to applicable law and our service-provider agreements.

Horizon AI is an educational tool. AI outputs are machine-generated and may be inaccurate, incomplete, or unsuitable for your circumstances. Nothing generated by Horizon AI constitutes financial, investment, tax, legal, credit, accounting, lending, insurance, or other professional advice. We do not guarantee the correctness of AI outputs, and you remain responsible for assessing whether such outputs are appropriate for your use.

We do not use AI outputs as the sole basis for decisions that produce legal, financial, or similarly significant effects.

If we ever use personal information to make a decision based exclusively on automated processing in circumstances that trigger legal notice requirements, we will provide the notice and procedural rights required by applicable law.

We may disclose personal information to the following categories of recipients, where reasonably necessary and legally permitted:

1. affiliates and related entities;
2. cloud hosting, infrastructure, storage, authentication, analytics, error monitoring, customer support, security, communications, and other service providers;
3. data connection providers and financial data intermediaries — including Plaid Technologies, Inc., which provides bank connectivity and receives account and transaction data you authorize us to access (read-only);
4. payment processors — including Stripe, Inc. and PayPal Holdings, Inc. — which handle payment data in connection with subscriptions and purchases;
5. authentication providers — including Google LLC (Google OAuth), used where you choose to sign in with Google;
6. AI model providers — including Anthropic, PBC — which process AI prompts and context on our behalf to generate Horizon AI responses;
7. legal, accounting, audit, insurance, compliance, and professional advisors;
8. regulators, law enforcement, courts, governmental authorities, or self-regulatory organizations where required or permitted by law;
9. counterparties to a merger, acquisition, financing, reorganization, sale of assets, insolvency proceeding, or other corporate transaction; and
10. other persons or entities where you direct us to disclose information or where you otherwise consent.

We do not sell personal information in exchange for money. If applicable law treats certain targeted advertising, analytics, or data-sharing practices as a “sale” or “sharing,” we will comply with the rights and disclosures required by that law.

Certain features allow you to connect your bank accounts or financial institutions using Plaid Technologies, Inc. (“Plaid”), a third-party financial data connectivity provider. By initiating a bank connection you consent to the following:

• Credential handling: Your banking credentials are entered through Plaid Link or, where applicable, through your financial institution’s own authentication flow. Finding Wealth does not receive or store your online banking username or password.
• Read-only access: Plaid provides Finding Wealth with a token that allows us to retrieve only the account and transaction data you authorize. Finding Wealth cannot use Plaid to initiate payments, transfers, withdrawals, deposits, or other write operations on your accounts.
• Data received: With your authorization, we receive account names, balances, transaction history, and related account metadata for the accounts you select.
• Purpose: This data is used solely to operate the Service — to display balances, categorize transactions, generate budgets and insights, and support financial planning features. It is not sold, shared for advertising, or used for any purpose unrelated to the Service.
• Token storage: Access tokens are encrypted at rest using AES-256-GCM with a separate encryption key before being stored in our database.
• Revocation: You may disconnect any linked account at any time from the Live Accounts page. Disconnection revokes the access token with Plaid and removes or deactivates the connected account data in Finding Wealth, subject to limited retention where required for security, legal compliance, backup integrity, dispute resolution, fraud prevention, or other legally permitted purposes.
• Plaid’s own privacy policy governs Plaid’s handling of information: see plaid.com/legal.

Personal information may be stored, processed, accessed, or transferred outside your province, territory, or country of residence, including outside Québec, where our service providers, affiliates, infrastructure providers, or partners operate. When information is transferred across borders, it may become subject to foreign laws and lawful access requirements in those jurisdictions.

Where required by applicable law, we implement reasonable contractual, organizational, and technical measures intended to protect personal information during such transfers.

We use administrative, organizational, contractual, physical, and technical safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. These measures may include encryption, access controls, role-based permissions, logging, monitoring, vendor controls, secure development practices, and incident response procedures.

However, no method of transmission over the Internet, no mobile environment, and no electronic storage system is completely secure. Accordingly, we cannot and do not guarantee absolute security.

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to provide the Services, to meet legal, accounting, tax, audit, dispute-resolution, fraud-prevention, security, and enforcement requirements, and to protect Finding Wealth’s legitimate business interests where permitted by law.

We may delete, de-identify, anonymize, aggregate, or otherwise dispose of personal information when it is no longer reasonably required, subject to legal retention obligations.

We make reasonable efforts to ensure that personal information used by us is as accurate, complete, and up to date as necessary for the purposes for which it is to be used. You are responsible for informing us of changes to your information and for updating your account details where applicable.

Subject to applicable law and verification of identity, you may have the right to:

1. request access to personal information we hold about you;
2. request correction of inaccurate or incomplete personal information;
3. withdraw consent, where processing is based on consent;
4. request deletion or de-indexing in certain circumstances;
5. request information regarding the categories of personal information collected, used, or disclosed;
6. complain about our privacy practices; and
7. exercise any additional rights granted by applicable privacy laws.

We may require sufficient information to verify identity before processing a request. We may refuse or limit requests where permitted or required by law.

Requests for access, correction, withdrawal of consent, complaints, or other privacy inquiries must be submitted in writing to the contact listed below.

We may request additional information to verify your identity and clarify the scope of your request. We will respond within the time required by applicable law.

The person with ultimate authority over Finding Wealth is responsible for the protection of personal information, unless such function has been lawfully delegated in writing. Our designated privacy contact is:

Privacy Officer
Finding Wealth
Email: privacy@findingwealth.ca
Address: 5513 Av. de Monkland, Montréal, QC H4A 1C8, Canada

If we become aware of a confidentiality, privacy, or security incident involving personal information, we will assess the incident, take reasonable steps to reduce the risk of harm, maintain any records required by law, and provide any legally required notices to affected individuals and/or regulators.

We may amend this Privacy Policy from time to time to reflect changes in our practices, technology, legal obligations, or business operations. When we do, we may update the “Last Updated” date and provide additional notice where appropriate or legally required.

Your continued use of the Services after the effective date of the revised Privacy Policy signifies your acknowledgment of the updated Privacy Policy, to the extent permitted by law.

For privacy-related inquiries, complaints, access requests, correction requests, deletion requests, or withdrawal of consent requests, contact:

Privacy Officer
Finding Wealth
Email: privacy@findingwealth.ca
Address: 5513 Av. de Monkland, Montréal, QC H4A 1C8, Canada