Privacy Policy | Open Wallet Finance

Effective Date: June 11, 2026 · Last Updated: July 2, 2026

1. Introduction

Open Wallet Finance LLC ("we," "our," or "us") operates The Open Wallet (Open Wallet Finance™), a financial wellness and budgeting application. We are committed to protecting your privacy and handling your data in a transparent, secure, and compliant manner.

This Privacy Policy describes how we collect, use, store, and protect your information, and explains your rights under applicable law. By using The Open Wallet, you agree to the practices described in this policy. If you do not agree, please do not use our services.

This policy applies to all users of The Open Wallet, including visitors to our website at openwalletfinance.com.

The Open Wallet is offered to, and intended for, residents of the United States only. It is not directed to, or offered in, the European Economic Area or the United Kingdom.

2. Identity & Authentication

We use Clerk for secure identity management and account authentication. Clerk provides:

Secure sign-up and sign-in: Your account credentials are managed through Clerk's infrastructure and are not stored in our application databases.
Multi-Factor Authentication (MFA): We enforce Step-Up Multi-Factor Authentication (including email one-time password, or OTP) prior to sensitive actions, such as linking a bank account or generating financial data connections.
Session security: Authentication sessions are managed by Clerk using industry-standard security controls. We do not store your passwords. Password complexity, credential-stuffing protection, and account lockout policies are managed centrally by Clerk.

Clerk's privacy practices are governed by their own Privacy Policy at clerk.com/privacy.

3. Financial Data Handling

3.1 Use of Plaid Inc.

We use Plaid Inc. to securely connect your financial accounts and aggregate financial data (such as account balances and transaction history). When you choose to link a bank or financial account:

We do not collect or store your online banking username or password. Your bank credentials are entered directly into Plaid's secure Link interface and are handled exclusively by Plaid. We never have access to your raw bank login credentials.
Plaid acts as an intermediary between you and your financial institution. Plaid's practices are governed by their own privacy and security policies (see Section 8).
We receive only aggregated data that Plaid provides to us pursuant to your authorization (e.g., account identifiers, balances, and transaction data). We use this data to power budgeting, insights, and other features within The Open Wallet.
Our access to your financial accounts is read-only. We cannot initiate transactions, move money, or modify your financial accounts in any way.

3.2 What We Store

Plaid access tokens: We store secure tokens that allow us to request your financial data from Plaid on your behalf. These tokens are stored server-side only in our encrypted database, strictly bound to your user account. They are never exposed to client-side code, browser storage, or cookies.
Financial data: We sync and store your transactions, account balances, account details, and detected recurring items from Plaid in our database for the life of your account, so the application can show your history, budgets, and insights (we retain up to approximately 24 months of transaction history). This data is removed when you delete your account or disconnect the institution (see Section 6).
Budget and preference data: Budget categories, goals, and user preferences you configure within the app are stored in our database to power the Service.

4. Artificial Intelligence & Data Processing

The Service uses AI technology to power financial coaching, budget recommendations, and transaction analysis. Understanding how your data interacts with these systems is important:

4.1 What Is Sent to AI Providers

When you use AI features (including the AI advisor, auto-budgeting, and transaction categorization), relevant portions of your financial data are sent to our AI providers' APIs to generate responses. This can include: account names and current balances, individual transactions (merchant name, date, amount, and category), budget and spending figures, recurring bills and subscriptions, savings pockets, and preferences or facts you have shared with the advisor. We send what is necessary for the feature you are using — not your entire history on every request — and we never send bank credentials or access tokens (we do not have your credentials at all).

4.2 xAI (Primary AI Provider)

AI features are primarily powered by Grok, a large language model developed by xAI, Corp. When you use AI features:

Your prompts and the financial context described in Section 4.1 are processed by xAI's API.
xAI's data handling practices for API usage are governed by their Privacy Policy at x.ai/legal/privacy-policy. We do not permit our AI providers to use your content to train their models.

4.3 Anthropic (Fallback AI Provider)

In the event of a service interruption with xAI, the Service may route AI requests to Claude, a large language model developed by Anthropic, PBC, to maintain service availability. When this occurs:

The same types of financial data that would be sent to xAI may be sent to Anthropic's API instead.
Anthropic does not use API inputs or outputs to train its models. Anthropic's privacy practices are governed by their Privacy Policy at anthropic.com/privacy.

4.4 AI Advisor Memory

To make the advisor useful across conversations, we store a small set of facts and preferences you share with it (for example, "I get paid biweekly" or a stated savings goal) in our own database, linked to your account. A memory stops being used by the advisor after about 180 days from when it was last used — after that point it is no longer read or sent to our AI providers. It remains stored in our database until it is permanently deleted, along with everything else, when you delete your account.

4.5 AI Conversation History

We keep a first-party record of your AI conversations in our own database, linked to your account, so that we can operate, secure, debug, and improve the AI features. What we store is limited to the message you send and the response you receive; we do not store the system instructions or the underlying financial context that surrounds them. Before your message is sent to an AI provider it is passed through a redaction step, and it is that already-redacted version — the same content the provider receives — that we log. This posture is consistent with the rest of Section 4: we do not permit AI providers to use your content to train their models, and we log only what has already crossed the provider boundary. Your AI conversation history is retained for the life of your account and is permanently deleted when you delete your account (see Section 6).

5. Data Security

We implement technical and organizational measures to protect your data:

Encryption in transit: All data transmitted between your device, our servers, and third-party services is encrypted using TLS 1.2 or higher. Unencrypted connections are not accepted.
Encryption at rest: All persistent data is encrypted using AES-256 encryption, enforced at the infrastructure layer by Supabase (PostgreSQL). Encryption key management is handled by our infrastructure providers.
Access control: Access to production systems and user data is restricted on a need-to-know basis. Plaid access tokens and sensitive records are strictly mapped to your authenticated identity (Clerk user ID) and are never shared across accounts.
Row-level security: Our database enforces row-level security policies ensuring each user can only access their own data.
No sensitive data in client storage: We do not store sensitive financial data, access tokens, or authentication credentials in browser storage, cookies, or client-side code.

No method of transmission over the internet or electronic storage is 100% secure. While we use commercially reasonable means to protect your data, we cannot guarantee absolute security.

6. Data Retention & Deletion

6.1 Retention

We retain your data only as long as necessary to provide our services, comply with legal obligations, and resolve disputes. Transaction and account data synced from Plaid are stored in our database for the life of your account and are removed when you delete your account or disconnect the institution.

The table below shows how long each category of data is kept. Except for AI advisor memory (which stops being used after about 180 days, as described in Section 4.4), we retain these records for the life of your account and delete them when you delete your account (see Section 6.2) — we do not currently run a separate time-based purge that removes them earlier while your account is active.

| Data | Retention | | --- | --- | | Account & identity data (Clerk) | Life of your account | | Plaid-derived financial data (synced transactions, balances, recurring items) | Life of your account — retained through subscription cancellation; removed when you delete your account or disconnect the institution (see Section 6.1a) | | In-app data you create (budgets, savings pockets, goals, monthly history) | Life of your account | | AI advisor memory | Stops being used after about 180 days from last use; deleted when you delete your account (see Section 4.4) | | AI conversation history (your messages and the AI's responses, post-redaction) | Life of your account — purged on deletion | | AI usage logs (request metadata — token counts, feature, provider, timestamps) | Life of your account — purged on deletion | | Support communications | Life of your account — purged on deletion | | Server and security logs | Life of your account — purged on deletion |

All of the above are permanently deleted under the 24-hour commitment in Section 6.2 when you delete your account, except as noted there and in Section 6.3.

6.1a Subscription Cancellation (distinct from account deletion)

Cancelling your subscription is not the same as deleting your account. When your paid access ends, the application is paused, but your data is retained — including your linked financial institutions and the transactions, balances, and recurring items synced from them, along with the budgets, savings pockets, goals, and history you created — so you can resume exactly where you left off if you resubscribe. Nothing is deleted simply because you cancel. To disconnect your banks and permanently remove everything we hold, delete your account at any time from the Account page (see Section 6.2); account deletion revokes your bank connections at Plaid and erases your data.

6.2 Deletion Policy & 24-Hour Commitment

Account deletion is broader than subscription cancellation (Section 6.1a): it permanently removes everything we hold about you, including the budgets, savings pockets, goals, and history that are retained after a cancellation. Account deletion must be initiated through the application while you are signed in. We do not accept account deletion requests by email or any other unauthenticated channel.

How to request deletion: Go to the Account page, choose Delete account, and type "delete my account" to confirm.

Upon your confirmed request:

Revocation of financial access: We immediately call Plaid's /item/remove endpoint to permanently revoke the connection between The Open Wallet and your linked financial accounts.
Permanent purge of stored data: We permanently delete all associated records from our database within twenty-four (24) hours of your request.
Client-side data: All locally stored preferences are cleared from your device as part of the deletion flow.
Confirmation: Upon completion, you will receive confirmation and will be signed out.

We commit to completing the above steps within twenty-four (24) hours of your confirmed in-app deletion request. No residual user data from deleted accounts is retained in our primary (live) systems beyond this window, except where required by law and except for limited records held by the service providers described below.

Backup archives: For disaster-recovery purposes we maintain encrypted, access-controlled backups of our database. A copy of your data may persist in those backups after deletion until they are overwritten in the ordinary course of our backup-retention cycle, after which it is permanently removed. We do not access or use backup data except to restore the Service following a failure.

Payment records exception: Records held by Stripe, our payment processor (such as invoices, charge history, and billing details), are retained by Stripe in accordance with its own policies and applicable financial record-keeping laws (typically up to 7 years for tax and accounting purposes). We cannot delete these records from Stripe's systems, and limited billing metadata may persist in our accounting records as required by law.

Analytics & error-monitoring exception: Our product-analytics provider (PostHog) and error-monitoring provider (Sentry) may retain limited records after your account is deleted — specifically feature-usage events and crash/error diagnostics keyed to an internal identifier — under each provider's standard retention schedule, and solely for product-analytics and security/error-monitoring purposes. These records do not include your financial data: no bank balances, transaction details, account numbers, or other Plaid-derived information.

6.3 Legal Holds

Notwithstanding the above, we may retain certain information where required by applicable law, court order, or regulatory requirement, or where necessary to resolve disputes or enforce our agreements.

7. Your Rights & Compliance

We support your privacy rights under applicable law, including:

7.0 All U.S. Residents

Regardless of your state of residence, we extend the same core privacy rights to everyone: the right to know what personal information we hold about you, to correct it, to delete it, and to obtain a copy of it. If your state has enacted a comprehensive privacy law (including Colorado, Connecticut, Virginia, Texas, Oregon, Montana, New Mexico, and others), the rights described in this section apply to you and may be supplemented by additional rights under your state's law.

7.1 California (CCPA)

If you are a California resident, you have the right to:

Know what personal information we collect, use, and disclose
Delete your personal information, subject to certain exceptions
Correct inaccurate personal information
Opt out of the sale or sharing of personal information (we do not sell your personal information)
Non-discrimination for exercising your privacy rights

To exercise your rights, use the in-app deletion workflow or contact us at support@openwalletfinance.com.

7.2 Users Outside the United States

The Service is intended only for residents of the United States. It is not offered or directed to individuals in the European Economic Area, the United Kingdom, or other jurisdictions outside the United States, and we do not target or knowingly provide the Service to users there. If you access the Service from outside the United States, please do not use it. See also Sections 1 and 11.

7.3 Minors' Privacy

The Service is intended only for adults 18 and older and is not directed to minors. You must be at least 18 to create an account, and we do not knowingly collect, use, or disclose personal information from anyone under 18. If we discover that we have collected information from someone under 18, we will delete it and terminate the associated account. If you believe someone under 18 has provided us with personal information, contact us at support@openwalletfinance.com. We comply with the Children's Online Privacy Protection Act (COPPA), which protects children under 13.

7.4 How to Exercise Your Rights

Account deletion: Settings > Close Account > type "delete my account" to confirm. We do not process deletion requests by email.
Other requests: Contact us at support@openwalletfinance.com with the subject line "Privacy Request."
Response time: We will respond to verifiable requests within 45 days, or as otherwise required by applicable law.

8. Data We Collect & How We Use It

8.1 Account & Identity Data

Managed by Clerk (e.g., email address, name, profile information). Used to create and secure your account, enforce MFA, communicate with you about the Service, and — with an opt-out — send the marketing communications described in Section 8.7.

8.1a Age Verification (Date of Birth)

We collect your date of birth to verify that you are at least 18 years old, as the Service is intended only for adults (see Section 7.3), and to power age-based features such as your Financial Age Score. Your date of birth is stored in your profile in our database and is deleted with your account.

8.2 Financial Data

Obtained via Plaid with your explicit consent. Used to provide budgeting, transaction history, financial age scoring, rewards optimization, savings pockets, recurring-bill detection, and related features. Not sold to third parties.

8.2a Derived & Generated Data

To power features, we generate and store data derived from your financial data, including: transaction categorizations and the rules learned from your corrections, detected recurring bills and subscriptions, monthly budget and net-worth history, your Financial Age Score, savings pockets and their activity, AI advisor memories (Section 4.4), and a money-personality profile inferred from your spending patterns that the advisor uses to tailor its tone and suggestions. Derived data is treated as your personal information and is deleted with your account.

8.3 Usage & Technical Data

We may collect usage and technical data (e.g., device type, browser type, IP address — which may constitute personal data under applicable law — pages visited, and features used) to operate, secure, improve, and analyze our services. This data is collected through standard server logs and may be processed by our hosting provider, Vercel. We also use PostHog for product analytics (which features are used, in aggregate) and Sentry for error monitoring (crash and error reports, which may include technical context about your session but are configured to exclude your financial data). We have disabled IP-based location enrichment in our analytics, so we do not derive or store your approximate location (such as city, region, or postal code) from your IP address, and we do not use your location for advertising.

8.4 Payment Data

Payment information (credit card numbers, billing addresses) is collected and processed exclusively by Stripe, Inc. We do not store your full payment card information on our servers. We receive only limited transaction metadata from Stripe (e.g., subscription status, last four digits of card, billing email).

8.5 Communications

Contacting support. If you contact us by email, or submit a request through the in-app or website support form, we retain the content of your communication to respond to your inquiry and improve our support. When you use the support form, we store the email address you provide, the message you write, an optional category, a support case number, the user id associated with your session if you are signed in, and your browser's user-agent string (to help us reproduce technical issues). We send a confirmation of your request back to the email address you provided. Support communications are retained for the life of your account (see Section 6.1) and are permanently deleted with your account.

How we send email. Service and support emails — such as your support confirmation, welcome and account emails, trial and billing notices (including payment-failure notices), and subscription confirmations — are delivered on our behalf by our email provider, Resend (see Section 10). We provide Resend only the recipient address and message content needed to deliver the email; we do not share your financial data with it.

8.6 What We Do Not Do

We do not sell your personal information to third parties
We do not rent your personal information for marketing purposes
We do not use your financial data for advertising purposes
We do not share your data with third parties except as necessary to operate the Service or as required by law

8.7 Marketing & Promotional Communications

With your account, we may send you promotional and marketing communications by email — for example, product news and feature announcements (our newsletter), tips for getting more from the Service, and offers such as invitations to resume a cancelled subscription or to complete a sign-up you started. These are separate from the transactional and service messages we send to operate the Service (such as security alerts, billing and trial notices, and legal updates), which are not promotional.

You can opt out of promotional email at any time by clicking the unsubscribe link in any such message, or by contacting us at support@openwalletfinance.com; we honor opt-out requests promptly. Opting out of promotional email does not stop transactional or service messages, which you will continue to receive while your account is active. We send these communications only to our own users and contacts — we do not sell or rent your email address, or share it with third parties for their own marketing (see Section 8.6).

9. Cookies & Tracking Technologies

We use essential cookies and similar technologies necessary to operate the Service, including authentication session cookies managed by Clerk, plus first-party analytics (PostHog) and error monitoring (Sentry) as described in Section 8.3. We do not use third-party advertising cookies or behavioral tracking cookies.

Global Privacy Control (GPC): Because we do not sell or share your personal information for targeted advertising, there is no sale or sharing to opt out of; we nonetheless honor browser-level opt-out preference signals such as Global Privacy Control to the extent they apply to our processing.

You may configure your browser to refuse cookies, but doing so may impair your ability to use certain features of the Service, including staying signed in.

California residents: We do not engage in "cross-context behavioral advertising" as defined under the CCPA. We do not sell or share your personal information for targeted advertising.

10. Third-Party Services

Our application relies on the following third-party services. Their privacy practices govern the data they independently collect and process. We encourage you to review their policies.

| Service | Purpose | Privacy Policy | | --- | --- | --- | | Clerk | Identity, authentication, and MFA | clerk.com/privacy | | Plaid Inc. | Financial account linking and data aggregation | plaid.com/privacy | | xAI, Corp. | Primary AI provider — powers AI financial advisor and coaching features | x.ai/legal/privacy-policy | | Anthropic, PBC | Fallback AI provider — used if xAI is unavailable | anthropic.com/privacy | | Supabase | Database and backend infrastructure | supabase.com/privacy | | Vercel | Application hosting and deployment | vercel.com/legal/privacy-policy | | Stripe, Inc. | Payment processing and subscription billing | stripe.com/privacy | | Resend | Transactional and service email delivery | resend.com/legal/privacy-policy | | PostHog | Product analytics | posthog.com/privacy | | Sentry | Error and crash monitoring | sentry.io/privacy |

We are not responsible for the privacy practices of these third-party services beyond our contractual obligations with them.

11. Where We Process Your Data

Open Wallet Finance LLC is based in the United States, and we store and process your information in the United States. Some service providers we use may process limited data in other countries, in each case subject to this Privacy Policy. The Service is intended only for residents of the United States (see Sections 1 and 7.2).

12. Security Incident Response

In the event of a data breach or security incident that affects your personal information, we will:

Investigate and contain the incident promptly
Notify affected users without unreasonable delay and within the timeframes required by applicable U.S. state breach-notification laws
Notify relevant regulatory authorities as required by applicable law
Take reasonable steps to mitigate harm and prevent recurrence

To report a security concern or potential vulnerability, contact us at support@openwalletfinance.com with the subject line "Security Report."

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the revised policy with an updated "Last Updated" date. For material changes, we will provide additional notice by email or prominent in-app notification where required by law. Your continued use of The Open Wallet after the effective date of changes constitutes acceptance of the updated policy.

14. Contact Information

For privacy-related questions, requests, or complaints, contact us at:

Open Wallet Finance LLC
1209 Mountain Road Pl NE Ste N, Albuquerque, NM 87110
Email: support@openwalletfinance.com
Subject line for privacy matters: "Privacy Request"

For account deletion requests, use the in-app process at Settings > Close Account. We do not process deletion requests by email.

We will respond to all verifiable privacy requests within 45 days, or as otherwise required by applicable law.

This Privacy Policy is maintained by Open Wallet Finance™ and is designed to align with our technical architecture and applicable U.S. federal and state privacy law, including the CCPA.