At Promi, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and disclose your information as described in this Privacy Policy.

Remember that your use of Promi's Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

If you have a disability, you may access this Privacy Policy in an alternative format by contacting support@promifinance.com.

Summary of Our Privacy Policy

We know Privacy Policies are no fun. At Promi, our goal is to help you understand where you stand financially. In the course of providing our Services, we collect certain information about you which is necessary for us to best achieve that goal. Our intent is to only collect the information we need to best serve you. We will never sell your financial data. We do not use advertising cookies or tracking pixels. We do not show you third-party advertisements.

Privacy Policy Table of Contents

Personal Data
Categories of Sources of Personal Data
Our Business Purposes for Collecting Personal Data
How We May Disclose Your Personal Data
Tracking Tools and Cookies
Data Security
Data Retention
Personal Data of Children
U.S. State Privacy Rights
Exercising Your Rights
Do Not Sell or Share My Personal Information
International Data Transfers
Changes to This Privacy Policy
Contact Information

What This Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we may collect and may have collected over the past 12 months:

Category of Personal Data	Business Purpose(s) for Collection	Categories of Third Parties We Disclose To
Account Data — login credentials, including third-party OAuth credentials (e.g., Google Sign-In)	Providing, Customizing and Improving the Services. Corresponding with You.	Service Providers. Parties You Authorize.
Profile Data — name, email address, user ID	Providing, Customizing and Improving the Services. Corresponding with You.	Service Providers. Parties You Authorize.
Payment Data — payment card type, last 4 digits, expiration date, billing address, email	Providing, Customizing and Improving the Services. Corresponding with You.	Service Providers (Stripe, Inc.).
Financial Account Data — account balances, transaction history, investment holdings (stocks, ETFs, mutual funds), cost basis, gain/loss, account types (checking, savings, 401(k), IRA, brokerage)	Providing, Customizing and Improving the Services. Corresponding with You.	Service Providers. Parties You Authorize.
Household Data — annual income, household size, dependents, relationship status, tax filing status, age, ZIP code	Providing, Customizing and Improving the Services (including peer comparison and FIRE analysis). Corresponding with You.	Service Providers. Parties You Authorize.
Device/IP Data — IP address, device ID, browser type, operating system	Providing, Customizing and Improving the Services. Security. Corresponding with You.	Service Providers.
Web Analytics — page interactions, referring URL, non-identifiable request IDs, feature usage statistics	Providing, Customizing and Improving the Services.	Service Providers.
Consumer Demographic Data — age/date of birth, ZIP code, city, state	Providing, Customizing and Improving the Services (including peer comparison benchmarks).	Service Providers. Parties You Authorize.
Inferences — drawn from other Personal Data collected, specifically in relation to your use of our Services (e.g., spending category patterns, net worth trends)	Providing, Customizing and Improving the Services.	Service Providers. Parties You Authorize.
Other Identifying Information — emails, support messages, feedback, or other communications you send us	Providing, Customizing and Improving the Services. Corresponding with You.	Service Providers. Parties You Authorize.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us:
- When you create an account or use our interactive tools and Services
- When you voluntarily provide information in free-form text boxes through the Services or through responses to questionnaires (e.g., household profile, FIRE planning inputs, manual account entries)
- When you send us an email or otherwise contact us
When you use the Services and such information is collected automatically:
- Through Cookies (defined in the "Tracking Tools and Cookies" section below)
- We may collect information on your use of our website and Services, such as pages visited, features used, and non-sensitive interactions, as well as information more commonly collected such as the referring URL, browser, operating system, and IP address

When You Connect Your Financial Accounts

When you connect your financial accounts to our Services via Plaid, we receive transaction and balance information, investment holdings, and account details from such accounts
You can find Plaid's privacy policy here. At no point will we receive your login credentials to any of your financial accounts

Third Parties

Vendors: We may use error tracking providers (Sentry) to monitor service stability, email providers (Resend) to send transactional communications, and AI platforms (Anthropic) to power portions of the Services, including AI-generated financial insights
Public Data Sources: We use data from the Federal Reserve Survey of Consumer Finances (SCF), FRED API, U.S. Census Bureau, and Bureau of Labor Statistics to power peer comparison benchmarks and economic data features. This is public statistical data, not Personal Data about you
Market Data: We use Yahoo Finance for historical securities pricing to calculate investment performance. This is public market data, not Personal Data about you

Third-Party Credentials

If you sign in using Google OAuth or Apple Sign-In, certain profile information (name, email, profile photo) may be transmitted into your account with us

Household Members

If you have granted access to Household Members to access your account, we may receive Personal Data about you from such Household Members

Our Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

Creating and managing your account
Processing subscription payments and billing
Providing you with the products, services, or information you request
Syncing your financial accounts and displaying transaction, balance, and investment data
Generating peer comparison benchmarks using anonymized, aggregated household data matched against Federal Reserve SCF datasets
Powering AI-generated financial insights, FIRE analysis, retirement projections, cash flow analysis, and other analytical features
Providing support and assistance for the Services
Improving the Services, including testing, research, internal analytics, and product development
Personalizing the Services and communications based on your preferences
Fraud protection, security, rate limiting, and debugging
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA"), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the Oregon Consumer Privacy Act, the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the New Hampshire Privacy Act, the New Jersey Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act (collectively, the "U.S. State Privacy Laws")

Corresponding with You

Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Promi or the Services
Sending transactional emails (account verification, password resets, subscription receipts) and other communications according to your preferences

Other Permitted Purposes

In addition, each of the above-referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms, including: fulfilling our legal obligations under applicable law, regulation, court order, or other legal process; preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property, or safety of you, Promi, or another party; enforcing any agreements with you; responding to claims that any content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice or, where applicable, obtaining your consent.

How We May Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. Promi does not sell your Personal Data. Promi does not use advertising partners or share data for targeted advertising.

Service Providers

These parties help us provide the Services or perform business functions on our behalf. They include:

Plaid Technologies, Inc. — bank account connections, transaction and balance retrieval, investment data sync
Supabase (hosted on AWS) — database hosting, authentication, and file storage
Stripe, Inc. — payment processing for Premium subscriptions. Stripe collects your voluntarily-provided payment card information necessary to process your payment. Please see Stripe's privacy policy for information on its use and storage of your Personal Data
Anthropic, PBC — AI-powered financial insights and analysis (data sent to Anthropic is anonymized and not used to train their models per our agreement)
OpenAI, Inc. — supplementary AI capabilities (data sent is anonymized)
Sentry (Functional Software, Inc.) — error tracking, performance monitoring, and masked session replay for debugging. Sensitive data (auth tokens, cookies) is automatically redacted
Resend — transactional email delivery (password resets, account verification, subscription receipts)
Vercel, Inc. — application hosting and deployment
Cloudflare, Inc. — bot protection via Turnstile (invisible CAPTCHA) on authentication endpoints
Upstash — distributed rate limiting to protect against abuse
Google (OAuth) — if you choose to sign in with Google, Google processes your authentication. Please see Google's privacy policy
Apple (Sign in with Apple) — if you choose to sign in with Apple, Apple processes your authentication. Apple may provide a private relay email address to protect your personal email. Please see Apple's privacy policy

Household Members

If you are the household admin and have added other members of your household (each, a "Household Member"), such Household Members will have access to your account and your Personal Data, regardless of any privacy or similar settings within the account. You acknowledge and agree that by adding a Household Member, you are authorizing Promi to disclose the Personal Data in your account to such Household Member, and such Household Member may be able to access, modify, or delete Personal Data and other data in the account.

If you are added to an account as a Household Member, you acknowledge and agree that all other Household Members added to the account will have access to, and may be able to modify or delete, your Personal Data, and that you may be restricted from accessing, modifying, or deleting certain data in the account and from changing certain settings.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the business purposes sections above, including: fulfilling our legal obligations under applicable law, regulation, court order, or other legal process; preventing, detecting, and investigating security incidents and potentially illegal activities; protecting the rights, property, or safety of you, Promi, or another party; and resolving disputes.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). We will use reasonable efforts to notify you via email before or promptly after any such transfer, and the acquiring party will be subject to the obligations of this Privacy Policy.

Data That Is Not Personal Data

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you. This includes, for example, creating anonymized peer comparison benchmarks.

Tracking Tools and Cookies

The Services use cookies and similar technologies (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, and operate and improve our Services. Cookies are small pieces of data placed on your device when you use that device to access our Services.

We use the following types of Cookies:

Essential Cookies: Required for providing you with features or services that you have requested. This includes authentication cookies (Supabase session tokens) that keep you logged in. Disabling these Cookies may make the Services unavailable.
Functional Cookies: Used to record your choices and settings, such as your preferred visual theme (light/dark mode). These Cookies help us personalize the Services for you and remember your preferences.
Performance/Analytical Cookies: Used by Sentry to monitor application performance and detect errors. These help us understand and resolve issues that affect your experience. Sentry's session replay feature is configured to mask all user input and block media to protect your privacy.

Cookies we do NOT use:

Third-party advertising or retargeting cookies
Social media tracking pixels (Facebook Pixel, LinkedIn Insight Tag, etc.)
Cross-site behavioral tracking

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

Do Not Track

Some browsers transmit "Do Not Track" (DNT) signals to websites. Because there is no common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. However, we do not engage in cross-site tracking, behavioral advertising, or selling your Personal Data, so our actual practices already align with the intent of DNT.

Specific Cookies Used

Cookie Name	Purpose	Type
Supabase auth token	Authentication session (httpOnly JWT)	Essential
Theme preference	Stores your selected visual theme	Functional

Data Security

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. Our security measures include:

256-bit AES Encryption: Data is encrypted at rest and in transit (TLS 1.2+)
SOC 2 Type II Compliance: Our database provider (Supabase) is SOC 2 Type II certified and hosted on AWS
Read-Only Financial Access: We cannot move money, initiate transfers, or change your financial account settings
Access Controls: Only authorized personnel can access user data, and only for support or debugging purposes. Auth tokens and cookies are automatically redacted in error tracking
Bot Protection: Authentication endpoints are protected by Cloudflare Turnstile (invisible CAPTCHA)
Rate Limiting: Distributed rate limiting on all sensitive endpoints to prevent abuse
PII Redaction: Our logging infrastructure automatically redacts personally identifiable information
Regular Audits: We conduct periodic security reviews and penetration testing

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism, limiting access to your computer or device and browser, and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. In the event of a data breach that affects your Personal Data, we will notify affected users without unreasonable delay, as required by applicable law.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Specific retention periods:

Account and profile data: Retained while your account is active, then deleted within 30 days of account deletion
Financial transaction data: Retained while your account is active, then deleted within 30 days of account deletion
Billing records: 7 years after your last transaction (for tax and legal compliance requirements)
Error logs and performance data: Automatically expired per Sentry's retention policies (typically 90 days)

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at support@promifinance.com.

U.S. State Privacy Rights

If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the "Exercising Your Rights" section below for instructions regarding how to exercise these rights. Please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@promifinance.com.

Access. You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data.
Deletion. You may have the right to request that we delete Personal Data that we have collected about you.
Correction. You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
Portability. You may have the right to request a copy of your Personal Data in a machine-readable format (JSON or CSV), to the extent technically feasible.

"Selling" and "Sharing"

Promi does not sell your Personal Data for monetary or other valuable consideration. We do not use advertising partners, retargeting cookies, or behavioral tracking. Because we do not engage in these activities, the "selling" and "sharing" provisions of the CCPA and other U.S. State Privacy Laws do not apply to our data practices.

Processing of Sensitive Personal Data

As part of the Services, you have the option to connect financial accounts or provide household financial information that may be deemed "sensitive" under certain U.S. State Privacy Laws ("Sensitive Personal Data"). We use this data solely to provide the Services (financial tracking, peer comparison, retirement planning) and not for the purpose of inferring characteristics about you.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable U.S. State Privacy Laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable law with varying prices, rates, or levels of quality related to the value of Personal Data that we receive from you.

Other State-Specific Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at privacy@promifinance.com.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (if applicable) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request."

We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded.

You may submit a Valid Request using the following methods:

Export your data in JSON or CSV format via Settings → Account → Export Data
Delete your account within your account settings (Settings → Account → Delete Account)
Email us at privacy@promifinance.com

If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, or Texas resident, you may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a Valid Request on your behalf.

Appealing a Denial

If you are a Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia resident and we refuse to take action on your Valid Request within a reasonable period of time after receipt in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original Valid Request pertains and to identify the original Valid Request, and (2) provide a description of the basis of your appeal.

You can submit an appeal by the following methods:

Email us at privacy@promifinance.com (subject line must include "[STATE OF RESIDENCE] Appeal")

If we deny your appeal, you have the right to contact the Attorney General of your state.

Do Not Sell or Share My Personal Information

Promi does not sell your Personal Data. We do not sell, rent, or trade your Personal Data to third parties for monetary or other valuable consideration. We do not share your Personal Data with third parties for cross-context behavioral advertising or targeted advertising purposes.

Because we do not engage in these activities, there is no need to opt out. However, if you have concerns about your data or wish to exercise any privacy right, you may:

Email us at privacy@promifinance.com with the subject line "Do Not Sell Request"
Export or delete your data at any time via Settings → Account

We will respond to your request within 15 business days. California residents: this section satisfies the requirements of CCPA §1798.120 (Right to Opt-Out of Sale). For more details, see the U.S. State Privacy Rights section above.

International Data Transfers

Promi is based in the United States. If you are located outside the US, your data will be transferred to and processed in the United States. By using the Services, you consent to this transfer. We process data in compliance with applicable data protection laws, including the GDPR and CCPA, as applicable to international data transfers.

Changes to This Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you of material changes by placing a notice on the promifinance.com website, by sending you an email, and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Privacy inquiries: privacy@promifinance.com
General support: support@promifinance.com
Website: https://app.promifinance.com
Address: Promi Technologies, Inc., 131 Continental Dr, Suite 305, Newark, DE 19713

Effective Date: March 9, 2026