Privacy Policy

This Privacy Policy explains how otterfund (“otterfund,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects your information when you use the otterfund budgeting application and website at otterfund.ai(together, the “Service”). By creating an account or using the Service, you agree to the practices described here. If you do not agree, please do not use the Service.

Because otterfund handles sensitive financial information, we hold ourselves to a high standard: we collect only what we need to run the Service, we never sell your personal information, and we give you tools to export or permanently delete your data at any time.

1. Information We Collect

a. Information you provide to us

• Account information. When you register, we collect your name and email address. Your password is set and stored by our authentication provider (Supabase) in hashed form; we never see or store your plaintext password. If you sign up with Google, we receive basic profile information (name and email) from Google.
• Financial profile. Details you enter during onboarding and in settings, such as your monthly income, preferred currency, budget target, and chosen budgeting plan (for example, the 50/30/20 rule).
• Financial records you create. Accounts, transactions, categories, budgets, savings goals, goal allocations, subscriptions, bills, and investment holdings (including names, symbols, values, and cost basis) that you add manually or import.
• Uploaded documents. Bank or credit-card statements (for example, PDF files) that you choose to upload so we can extract and categorize the transactions in them.
• AI advisor conversations. The questions you ask our AI advisor and the messages exchanged, which we store so you can revisit past conversations.
• Support and communications. Information you provide when you contact us for support or otherwise communicate with us.

b. Information from your connected financial accounts (Plaid)

If you choose to connect a bank or financial account, we use Plaid Inc.to establish the connection. You enter your bank credentials directly with Plaid’s secure interface. We never see or store your bank login credentials. Through Plaid, and only with your authorization, we receive account information such as account names and types, balances, the last few digits of account numbers, institution names, and transaction history. Your use of Plaid is also governed by Plaid’s End User Privacy Policy.

c. Payment information (paid plans)

When you subscribe to a paid plan, payments are processed by our third-party payment processor, Stripe. You provide your payment-card details directly to Stripe, and we do not collect or store your full card number. We receive limited billing information from Stripe, such as your subscription status, plan, billing history, the card brand, and the last four digits of your card, to manage your subscription.

d. Information collected automatically

• Device and log data. When you use the Service, our servers and infrastructure providers automatically record technical information such as your IP address, browser type, device information, timestamps, and requested pages, for security, debugging, and reliability.
• Cookies.We use strictly necessary cookies to keep you signed in and to secure your session. See “Cookies” below.
• Usage metrics. We record aggregate usage of AI features (such as token counts and cost) for internal capacity and cost management.

2. How We Use Your Information

We use the information above to:

• Provide, operate, maintain, and improve the Service;
• Create and manage your account, and sync your connected financial accounts;
• Categorize transactions, detect recurring charges and subscriptions, generate budgeting insights, and power the AI advisor;
• Calculate your budgets, net worth, savings goals, and progress;
• Process payments and manage subscriptions (via Stripe);
• Communicate with you about your account, security, updates, and support requests;
• Protect the Service, detect and prevent fraud and abuse, and enforce our Terms of Service;
• Comply with legal obligations.

We rely on the following legal bases where applicable: performance of our contract with you (to provide the Service), your consent (for example, to connect a bank account or process a statement), our legitimate interests (to secure and improve the Service), and compliance with legal obligations.

3. AI Processing

Several features rely on artificial intelligence provided by Anthropic(the maker of Claude). To power the AI advisor, parse uploaded statements, categorize transactions, detect recurring charges, and generate insights, we send the relevant data (which may include transaction descriptions and amounts, account and budget details, the contents of statements you upload, and the messages you send to the advisor) to Anthropic’s API for processing.

• We send only the data needed to produce the requested result, and we use AI to provide features to you, not to make automated decisions that produce legal or similarly significant effects about you.
• Anthropic processes this data as our service provider under its commercial terms and does not use data submitted through its API to train its models. See Anthropic’s Privacy Policy.
• AI output can be inaccurate or incomplete and is provided for informational purposes only. It is not financial, investment, tax, or legal advice (see our Terms of Service).

4. How We Share Your Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share information only in these limited circumstances:

• Service providers (subprocessors). With trusted vendors who process data on our behalf to run the Service, under contracts that require them to protect your information and use it only for the services they provide to us. Our key subprocessors are listed below.
• At your direction. When you connect an account or otherwise instruct us to share information.
• Legal and safety. When required by law, subpoena, or legal process, or when necessary to protect the rights, property, or safety of otterfund, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, in which case we will continue to protect your information and notify you of any material change to this Policy.

Our subprocessors

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. When you delete your account, we delete your profile and associated financial data from our primary systems, and we instruct our authentication provider to delete your login. Some information may be retained for a limited period where necessary to comply with legal obligations, resolve disputes, prevent abuse, or complete transactions (for example, billing records retained by Stripe). Backups are purged on a rolling schedule. Aggregated or de-identified data that cannot reasonably identify you may be retained.

6. How We Protect Your Information

• Encryption in transit. All traffic to the Service is encrypted using TLS/HTTPS, with HSTS enforced.
• Encryption at rest. Sensitive secrets, including the access tokens used to connect your bank via Plaid, are encrypted at rest using AES-256-GCM.
• Credential protection. Passwords are hashed by our authentication provider; we never store them in plaintext. We never receive or store your bank login credentials.
• Access controls. Data is scoped to your account, and access is restricted and logged.

No method of transmission or storage is completely secure. While we work hard to protect your information, we cannot guarantee absolute security. Please use a strong, unique password and keep it confidential.

7. Your Rights and Choices

You can access and update much of your information directly in the app. In addition, you may:

• Export your data.Download a copy of your data from the app’s settings at any time.
• Delete your account. Permanently delete your account and associated data from within settings. This action is irreversible.
• Disconnect a bank. Unlink any connected financial institution at any time.
• Access, correct, or object. Request access to, correction of, or restriction of the processing of your personal information by contacting us.

Depending on where you live, you may have additional rights (see “Region-Specific Disclosures” below). To exercise any right, contact us at privacy@otterfund.ai. We will not discriminate against you for exercising your rights.

8. Data Location and International Transfers

We store data using infrastructure located in Canada and the United States. Some of our subprocessors (including Plaid, Anthropic, and Stripe) are located in the United States, so your information may be transferred to, stored in, and processed in the United States and other countries that may have data-protection laws different from those in your jurisdiction. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses) for international transfers.

9. Cookies

We use strictly necessary cookies to authenticate you and keep your session secure. These cookies are required for the Service to function and cannot be switched off through the Service. We do not use advertising or cross-site tracking cookies. You can control cookies through your browser settings, but disabling necessary cookies will prevent you from signing in.

10. Children’s Privacy (COPPA)

The Service is intended for adults and is not directed to children under 18. In particular, consistent with the U.S. Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect personal information from children under 13, and children under 13 are not permitted to use the Service. If you believe a child under 13 has provided us with personal information, or if you are a parent or guardian and become aware that your child has done so, please contact us at privacy@otterfund.ai. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly.

11. Region-Specific Disclosures

Canada (PIPEDA)

If you are in Canada, we handle your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws. You may request access to, or correction of, your personal information, and you may withdraw consent (subject to legal or contractual restrictions) by contacting us. You may also contact the Office of the Privacy Commissioner of Canada.

European Economic Area and United Kingdom (GDPR)

If you are in the EEA or the UK, otterfundis the data controller of your personal data. You have the rights to access, rectify, erase, restrict, and port your data, to object to certain processing, and to withdraw consent at any time. You may lodge a complaint with your local supervisory authority. The legal bases for our processing are described in “How We Use Your Information” above.

California (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect and how we use and disclose it, to request access to and deletion of your personal information, to correct inaccurate information, and to be free from discrimination for exercising your rights. We do not sell or share your personal information as those terms are defined under the CCPA/CPRA. To exercise your rights, contact us at privacy@otterfund.ai.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date above and, if appropriate, notify you through the Service or by email. Your continued use of the Service after an update means you accept the revised Policy.

13. Contact Us

If you have questions or requests about this Privacy Policy or your personal information, contact us at:

• Email: privacy@otterfund.ai
• otterfund
• [Registered business address]