Privacy Policy

Introduction

Accountible ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App") and related services (collectively, the "Services").

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the App.

Information We Collect

1. Personal Information You Provide

Account Information:

• Email address
• Password (encrypted and hashed)
• Name (optional)
• Phone number (optional)

Financial Profile:

• Household income information
• Financial goals you set
• Purchase queue items you create
• Transaction categorizations you make

Household Information:

• Names of household members (if you add them)
• Email addresses of household members

2. Information Collected Automatically

Device Information:

• Device type and model
• Operating system and version
• Unique device identifiers
• Mobile network information

Usage Information:

• App features you use
• Time and frequency of use
• Navigation paths within the App
• Crash reports and performance data

Location Information:

• Approximate location based on IP address (not precise GPS)
• Used only for security and fraud prevention

3. Financial Information via Teller

4. Biometric Information

If you enable biometric authentication (Face ID, Touch ID, fingerprint):

• Biometric data is stored ONLY on your device
• We never receive or store your biometric information
• Used solely for local device authentication
• Managed by your device's operating system

How We Use Your Information

We use the information we collect to:

1. Provide Core Services

• Calculate your safe-to-spend amount
• Generate cash flow forecasts
• Provide purchase decision guidance
• Categorize transactions
• Sync data across your household
• Display account balances and transaction history

2. Improve and Personalize Services

• Understand how you use the App
• Improve our algorithms and features
• Personalize your experience
• Develop new features
• Test and optimize performance

3. Communication

• Send transactional emails (account verification, password reset)
• Send optional notifications about purchases, bills, forecasts
• Respond to your support requests
• Send important service updates

4. Security and Fraud Prevention

• Detect and prevent fraudulent activity
• Monitor for security threats
• Verify your identity
• Protect against unauthorized access

5. Legal Compliance

• Comply with legal obligations
• Enforce our Terms of Service
• Resolve disputes
• Protect our legal rights

How We Share Your Information

1. With Your Consent

• When you explicitly authorize us to share information
• With household members you invite to your account

2. Service Providers

We share information with third-party service providers who perform services on our behalf:

Teller

• Purpose: Secure bank account connections
• Data Shared: Financial account information
• Privacy Policy: https://teller.io/privacy-policy

Cloud Infrastructure (AWS)

• Purpose: Data storage and hosting
• Data Shared: All app data (encrypted at rest)
• Security: SOC 2 Type II certified

Analytics Services (Optional)

• Purpose: App performance and usage analytics
• Data Shared: Anonymized usage data only
• Opt-out: Available in Settings

Customer Support Tools

• Purpose: Respond to support requests
• Data Shared: Information you provide in support requests

3. Legal Requirements

We may disclose information if required by law or if we believe it's necessary to:

• Comply with legal process (subpoena, court order)
• Enforce our Terms of Service
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Prevent fraud or security threats

4. Business Transfers

If Accountible is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you via email and/or prominent notice in the App before your information is transferred and becomes subject to a different privacy policy.

Data Security

Encryption

• In Transit: All data transmitted using TLS 1.3 encryption
• At Rest: All stored data encrypted using AES-256 encryption
• Passwords: Hashed using bcrypt with salt
• Financial Data: Additional encryption layer for bank information

Access Controls

• Multi-factor authentication for internal systems
• Role-based access controls
• Regular security audits
• Penetration testing
• Employee background checks and NDAs

Teller Security

• Bank-level 256-bit encryption
• SOC 2 Type II certified
• Regular third-party security audits
• Real-time security monitoring

Your Responsibility

• Choose a strong, unique password
• Enable biometric authentication
• Keep your device secure
• Don't share your login credentials
• Log out on shared devices

Your Privacy Rights

1. Access and Portability

You have the right to:

• Access your personal information
• Request a copy of your data in a portable format
• Review what information we have about you

How: Email privacy@accountible.app or use in-app data export

2. Correction and Updates

You have the right to:

• Correct inaccurate information
• Update your profile information
• Modify your financial goals and settings

How: Use in-app Settings or email support@accountible.app

3. Deletion

You have the right to:

• Delete your account and associated data
• Request removal of specific information
• Revoke bank connections via Teller

How: Settings > Account > Delete Account or email privacy@accountible.app

Note: Some information may be retained for legal compliance (e.g., transaction records for tax purposes) as required by law.

4. Opt-Out Rights

You have the right to opt out of:

• Marketing communications (Settings > Notifications)
• Push notifications (Device settings)
• Analytics collection (Settings > Privacy)
• Household data sharing (Leave household)

5. Data Portability

You can export your data in JSON or CSV format from Settings > Privacy > Export Data

6. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of sale of personal information (we do NOT sell)
• Right to non-discrimination for exercising privacy rights

7. European Privacy Rights (GDPR)

If you are in the European Economic Area, you have additional rights:

• Right to object to processing
• Right to restrict processing
• Right to lodge a complaint with supervisory authority
• Right to withdraw consent

Data Retention

Active Accounts

• We retain your data as long as your account is active
• Transaction history: Retained for the life of your account
• Cash flow forecasts: Rolling 6-month retention

Deleted Accounts

• Most data deleted within 30 days of account deletion
• Some data retained for legal compliance:
  • Transaction records: 7 years (tax law requirements)
  • Account creation/deletion logs: 7 years (financial regulations)
• Backups: Deleted within 90 days

Household Data

• If you leave a household, your personal data is removed
• Shared transaction data remains for other household members
• You can request full deletion via privacy@accountible.app

Children's Privacy

Accountible is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

If you believe we have inadvertently collected information from a child under 13, please contact us immediately at privacy@accountible.app and we will delete such information.

Third-Party Links and Services

The App may contain links to third-party websites, services, or advertisements that are not operated by us. This Privacy Policy does not apply to third-party websites or services.

We are not responsible for the privacy practices of:

• Third-party websites you visit from our App
• Social media platforms
• Payment processors
• External financial institutions

We encourage you to review the privacy policies of any third-party services you use.

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

For European Users:

• We comply with GDPR requirements
• Data transfers are protected by Standard Contractual Clauses
• Adequate safeguards are in place for all transfers

For All Users:

• We ensure appropriate safeguards are in place
• Third-party processors comply with applicable privacy laws
• Your data receives the same level of protection regardless of location

Cookies and Tracking Technologies

The App uses limited tracking technologies:

Essential Technologies

• Session tokens for authentication
• Local storage for app preferences
• Cache for performance optimization

Optional Analytics

• Usage analytics (opt-out available)
• Crash reporting (opt-out available)
• Performance monitoring (opt-out available)

Push Notifications

You can opt-in to receive push notifications for:

• Purchase approvals/rejections
• Upcoming bills
• Low balance alerts
• Cash flow warnings
• Goal milestones

Control: Settings > Notifications or device settings

Note: We never send marketing push notifications

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the new Privacy Policy in the App
• Sending you an email notification
• Displaying a prominent notice in the App
• Updating the "Last Updated" date

Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

Review Frequency: We recommend reviewing this policy periodically.

Specific Provisions by Region

California Residents (CCPA)

• We do not sell personal information
• We do not discriminate for exercising privacy rights
• Contact privacy@accountible.app for CCPA requests

European Residents (GDPR)

• Legal basis for processing: Consent, contract performance, legitimate interests
• Data Protection Officer: dpo@accountible.app
• Right to lodge complaint with supervisory authority

Nevada Residents

• We do not sell personal information
• You may opt-out of future sales (though we don't sell)

Legal Disclosures

Company Name: Accountible, Inc.

Data Controller: Accountible, Inc.

Document Version: 1.0

Last Reviewed: October 27, 2025