Last Updated: July 28, 2025

1) Introduction

This Privacy Policy (“Policy”) explains how Path Financial, Inc., a Delaware corporation based in California doing business as Moneymap (“Moneymap,” “we,” “us,” “our”), collects, uses, discloses, and protects personal information when you use our website, web app, and related services (collectively, the “Services”). By using the Services, you agree to the data practices described here.

2) Scope

This Policy applies to personal information collected online through the Services. It does not cover information collected offline or on third‑party sites or services we do not control. Our Terms of Use govern your permitted use of the Services and your consents; this Policy governs our data practices.

3) Key Definitions

• Documents: files or images you upload (e.g., bank/credit statements, pay stubs, tax returns, credit reports, investment statements).

• Outputs: AI‑generated summaries, categorizations, and other analyses derived from your inputs and Documents.

• Personal Information: information that identifies or can reasonably be linked to an individual or household.

• Sensitive Personal Information (SPI): certain categories defined by law (e.g., SSN, driver’s license number, financial account numbers with access credentials).

4) Notice at Collection (California) — Categories, Sources, and Purposes

Identifiers (name, email, phone, account ID); Account Profile (preferences, coach assignment)

• Sources: You; account setup; communications

• Purposes: Provide and secure the Services; account administration; customer support; service communications

Financial Information (contained in Documents you upload)

• Sources: You (manual upload only; we do not request bank passwords)

• Purposes: Automated extraction (OCR), categorization, and analysis to produce Outputs; sharing with your assigned coach; troubleshooting; fraud prevention; compliance

Commercial/Transactional Information (interaction history with the Services)

• Sources: Service logs; support tickets

• Purposes: Provide and improve Services; analytics; security; fraud prevention

Internet/Network Activity (IP address, device/browser type, pages viewed, cookies)

• Sources: Your device; our analytics tooling

• Purposes: Operate core functionality; remember settings; measure usage; detect abuse

Geolocation (coarse, from IP)

• Sources: Your device/IP

• Purposes: Regional settings; security and fraud detection

Communications (chat messages, email correspondence, feedback)

• Sources: You

• Purposes: Support, quality assurance, service improvement

Inferences (basic, non‑sensitive inferences)

• Sources: Service analytics

• Purposes: Improve and develop features; quality and reliability

Sensitive Personal Information (SPI) (if you include it in Documents)

• Sources: You (optional; we ask you to redact SSNs and full account numbers before upload)

• Purposes: Provide the requested analysis and coaching workflow only; security/fraud prevention; legal compliance

We do not collect precise geolocation, biometric identifiers, or audio/visual recordings unless you choose to submit them.

5) How We Use Personal Information

We use personal information to:

• Provide, maintain, and secure the Services, including automated analysis (OCR, categorization, summarization) of Documents and generation of Outputs;

• Share Documents and Outputs with your assigned coach at your instruction;

• Communicate with you about the Services (e.g., product updates, security notices, scheduling);

• Conduct troubleshooting, quality assurance, research, and analytics;

• Detect, prevent, and respond to security incidents and abuse;

• Comply with legal obligations and enforce our Terms of Use;

• Improve and develop the Services, including using de‑identified or aggregated data.

Automated Processing: We use automated systems to extract and categorize information in Documents. Outputs are educational and may contain errors; please review before relying on them.

Model Training Stance: We do not use your Documents to train third‑party AI models without your explicit consent. We may use de‑identified data to improve Moneymap’s own models and features. You can opt out of de‑identified improvement uses by contacting us (see Section 16).

6) Cookies & Similar Technologies

We use cookies and similar technologies to operate the Services, remember preferences, and perform analytics. You can control cookies through your browser settings; disabling certain cookies may limit functionality. If we engage in cross‑context behavioral advertising in the future, we will provide appropriate opt‑outs.

7) How We Disclose Personal Information

• Service Providers / Processors: Cloud hosting, security, analytics, AI/runtime vendors, and support partners that process data on our behalf under contracts requiring confidentiality and appropriate safeguards.

• Your Coach: We share your Documents and Outputs with your assigned Moneymap coach to deliver the Services, as described in the Terms of Use.

• Corporate Transactions: Personal information may be transferred as part of a merger, acquisition, financing, or sale of assets.

• Legal & Safety: Where required by law, subpoena, or to protect the rights, safety, and security of you, us, or others.

• De‑identified/Aggregated Data: We may use and share de‑identified or aggregated data that cannot reasonably be used to identify you.

8) No “Sale” or “Sharing” of Personal Information

We do not sell personal information and do not “share” personal information for cross‑context behavioral advertising as those terms are defined under California law. If our practices change, we will update this Policy and provide required notices and opt‑outs (including honoring Global Privacy Control signals where applicable).

9) Data Security

We implement reasonable and appropriate administrative, technical, and physical safeguards designed to protect personal information in our custody. No method of transmission or storage is 100% secure.

10) Data Retention & Deletion

We retain personal information for as long as reasonably necessary to fulfill the purposes described, comply with law, resolve disputes, and enforce agreements. Default timelines for Documents align with the Terms of Use:

• Active retention: 90 days from upload;

• Archival retention: up to 12 months thereafter;

• Backups: up to 45 additional days;

• Deletion requests: removal from active systems within 15 days and from backups within 60 days, except where retention is legally required or (if Moneymap becomes an RIA) required by applicable books‑and‑records rules.
  Other categories are retained based on necessity, legal requirements, and security needs.

11) Your Privacy Rights

Depending on your location (including California), you may have rights to access, correct, delete, receive a portable copy, opt out of sales or “sharing” (not currently applicable), limit SPI use/disclosure (we restrict SPI to permitted purposes), and to non‑discrimination.

How to Exercise: Email privacy@moneymap.io or mail 490 43rd St., Suite 350, Oakland, CA 94609. Include your name, account email, request type, and supporting details. We verify identity (e.g., control of account email). You may designate an authorized agent subject to verification.

Marketing: Opt out via the unsubscribe link or privacy@moneymap.io. Transactional/service messages may still be sent.

12) Sensitive Information; Prohibited Uploads; Credit Reports

Please do not upload unredacted SSNs, full bank or card numbers, passwords, passcodes, or security answers. If you upload a credit report or similar consumer report, we process it solely to provide educational analysis to you and your coach at your instruction. Moneymap is not a consumer reporting agency; do not use Outputs for any eligibility determinations.

13) International Data Transfers

If personal information is transferred, processed, or stored outside your state or country, we take steps to ensure appropriate protections consistent with this Policy and applicable law (e.g., contractual safeguards with service providers).

14) Children’s Privacy

The Services are not intended for individuals under 18. We do not knowingly collect personal information from minors. If you believe a minor has provided personal information, please contact us and we will take appropriate steps.

15) Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy with a new “Last Updated” date. Your continued use of the Services after changes take effect constitutes acceptance.

16) Contact Us

Questions or requests regarding this Policy or our data practices:
Email: privacy@moneymap.io
Mail: Path Financial, Inc. (dba Moneymap)
490 43rd St., Suite 350, Oakland, CA 94609