Privacy Policy and Terms of Use

Privacy Policy

1. Scope

This Privacy Policy explains how Mossy Financial Technologies ("Mossy", "we", "our", or "us") collects, uses, shares, and protects personal data when you use our websites, mobile products, APIs, integrations, customer support channels, and related services (collectively, the "Service").

1A. Company Identity

Controller/Operator: Mossy Financial Technologies, a Canadian company. For formal legal notices, regulatory questions, and data rights requests, use the contact details in the Contact section below.

2. Information We Collect

We may collect the following categories of information:

• Account data: name, email address, profile details, login credentials, and preferences.
• Financial connection data: account metadata, balances, transaction details, and institution identifiers provided through authorized financial integrations.
• Usage data: device type, browser, operating system, app events, pages viewed, crash logs, and diagnostics.
• Communication data: support requests, feedback, and survey responses.
• Advisor+ session data: session audio, transcripts, speaker and timing information, consent records, and concerns or reports submitted about a session.
• AI interaction data: prompts, responses, and context submitted for AI-powered features.
• Referral data: your referral code, the codes you redeem, referral status and qualification events, rewards earned, and limited information about referred users needed to administer the Referral Program and prevent abuse.

3. How We Use Information

• Provide and operate the Service, including account setup, financial insights, and household features.
• Personalize recommendations, budgeting signals, and product improvements.
• Protect security, prevent fraud, enforce terms, and debug system issues.
• Communicate product notices, service updates, and support responses.
• Record and transcribe Advisor+ sessions, with express consent, so we can investigate safety or service concerns raised about a session.
• Meet legal and regulatory obligations and respond to lawful requests.

4. Legal Bases for Processing (Where Applicable)

Depending on your location, we process personal data based on one or more of the following: consent, contract performance, legitimate interests, and legal obligations.

5. Service Providers and Data Sharing

We use a limited number of service providers to operate Mossy. We disclose personal data to them only when needed to provide a feature you request, maintain and secure the Service, communicate with you, or meet legal obligations. Depending on the feature, these providers may support:

• Financial account connectivity and the retrieval of account and transaction data you authorize.
• AI-assisted features, including financial insights, summaries, categorization, receipt processing, and transcription.
• Cloud hosting, data storage, authentication, communications, analytics, fraud prevention, security, and customer support.
• Audio and video communications, recording, and related safety features for Advisor+ sessions.

Providers receive only the information reasonably necessary for their role and are subject to contractual, confidentiality, privacy, and security requirements. They may not sell personal data we disclose to them or use it for their own unrelated advertising. Some providers may process information outside your province or Canada, where it may be subject to the laws of those locations.

Financial connections

When you connect a financial institution, the financial connectivity provider retrieves the account and transaction data you authorize. The provider may also process information under disclosures presented during the connection flow and under its own privacy terms. We use connected financial data only to provide and improve the Mossy features you request.

AI-assisted features

Before financial context is sent to an AI processing provider, we remove direct identifiers such as your name, email address, and internal account and transaction identifiers, and replace account, merchant, and goal names with neutral placeholders where the feature allows. The original labels are restored within Mossy after the provider returns its output.

Information you intentionally submit for processing—such as a free-text prompt, receipt image, or Advisor+ session audio—may need to be sent as provided for the feature to work. Our AI processing providers process that information to return the requested output. We do not permit them to sell it or use it to train general-purpose AI models. Avoid including highly sensitive personal information in free-text prompts unless it is necessary.

Connected services

If you choose to connect another service, we access and use its data only for the user-facing functionality you authorize and describe during consent. We do not sell connected-service data or use it for unrelated advertising. Our use and transfer of data received through third-party APIs is subject to applicable provider policies, including any limited-use requirements.

6. Cookies and Similar Technologies

We and our partners may use cookies, local storage, and similar technologies to keep sessions active, remember preferences, and measure product performance.

7. Data Retention

We retain personal data for as long as necessary to provide the Service, resolve disputes, enforce agreements, and comply with legal obligations. Retention periods vary by data type and legal requirement.

• Account and profile data: retained while account is active and for a reasonable period after closure for legal/compliance purposes.
• Financial connection data: retained according to user authorization status, service requirements, and legal obligations.
• Support and security logs: retained for fraud prevention, troubleshooting, and audit requirements.
• Advisor+ session audio: scheduled for deletion after 90 days.
• Advisor+ transcripts: scheduled for deletion after one year.
• Recording-consent records: retained with the related booking or compliance record so Mossy can demonstrate what each participant agreed to and when.
• Where deletion is requested and legally permitted, we delete or de-identify data within a commercially reasonable timeframe.

8. Data Security

We use administrative, technical, and physical safeguards designed to protect personal data. No security measure is perfect, and we cannot guarantee absolute security.

• Data is protected using access controls, least-privilege principles, and environment separation.
• We implement encryption in transit and, where applicable, encryption at rest.
• We monitor systems for abuse, unauthorized access, and operational anomalies.
• Advisor+ recordings and transcripts are protected using restricted access, authenticated service requests, encryption in transit, and storage access controls.

8A. Security Incidents

If a security incident affecting personal data is confirmed, we will investigate, mitigate, and provide notices consistent with applicable laws and contractual requirements.

9. International Transfers

Data may be processed in countries other than your residence. Where required, we implement transfer safeguards consistent with applicable law.

10. Your Rights and Choices

Depending on your jurisdiction, you may have rights to:

• Access, correct, delete, or export your personal data.
• Withdraw consent where processing is consent-based.
• Object to or restrict certain processing activities.
• Appeal decisions related to privacy requests, where applicable.
• For Canadian users, request access to and correction of personal information and withdraw consent, subject to legal and contractual limits.
• Ask for access to an Advisor+ recording or transcript associated with you, or request correction of inaccurate transcript information.
• Withdraw recording consent for future Advisor+ sessions before booking. Because recording is a safety condition of Advisor+ sessions, withdrawing consent means you cannot book or provide a recorded session unless another arrangement is offered.
• For EEA/UK users, lodge a complaint with your local data protection authority.

To exercise these rights, including access, correction, or withdrawal of Advisor+ recording consent, email legal@mossyapp.com. We may verify your identity before completing a request. Deletion or withdrawal requests may be limited where retention is required for an active report, legal obligation, fraud prevention, or the establishment or defence of legal claims.

10A. Account Deletion Requests

If you request account deletion, we will begin our deletion workflow and permanently delete your personal information within 30 days, except where retention is required by law, security, fraud prevention, dispute resolution, or other legitimate compliance obligations.

11. Children

The Service is not directed to children under 13 (or higher age where required by law). If we learn we have collected data from a child unlawfully, we will take appropriate deletion steps.

12. Changes to this Privacy Policy

We may update this policy from time to time. Material changes may be communicated by notice in-app, by email, or by publishing an updated effective date on this page.

Terms of Use

1. Acceptance of Terms

By accessing or using the Service, you agree to these Terms of Use. If you do not agree, do not use the Service.

2. Eligibility and Account Responsibilities

• You must have legal capacity to enter into a binding agreement.
• You are responsible for maintaining account security and confidentiality.
• You must provide accurate information and keep it updated.

3. Description of Service

Mossy provides personal finance tools, household financial organization features, integrations, and AI-assisted insights. Features may change, be modified, or be discontinued.

3A. Financial Services Status

Unless explicitly stated otherwise, Mossy is a software platform and not a bank, credit union, broker-dealer, investment adviser, tax adviser, or insurer. Funds are not held by Mossy.

4. Financial and AI Disclaimer

• The Service is for informational purposes and does not constitute financial, legal, tax, or investment advice.
• Mossy is not your financial advisor, fiduciary, broker, or tax professional.
• AI-generated outputs can make mistakes, may be incomplete or inaccurate, and should always be independently reviewed before you act.
• You are solely responsible for decisions made using the Service.

4A. Accuracy of Financial Information and Potential Discrepancies

Mossy displays balances, transactions, spending totals, budgets, net worth, insights, and projections based on data retrieved from your connected financial institutions through third-party aggregation providers and on information you enter manually. This information is provided for your convenience and general awareness only. It may not match, and should not be relied on in place of, the official records, statements, or balances maintained by your financial institution, which are always the authoritative source of truth for your accounts.

Figures shown in Mossy may differ from those shown by your bank or other financial institution for reasons that include, but are not limited to, the following:

• Timing and synchronization delays. Data is refreshed periodically rather than in real time, so recent activity at your institution may not yet be reflected, and Mossy may briefly show an older state.
• Pending vs. posted transactions. A transaction may appear as pending, change amount, re-date, or be removed entirely between when it is authorized and when it finally posts at your institution.
• Transaction classification and categorization. How a transaction is labeled (for example, as spending, income, a transfer, a refund, or a particular category) is determined automatically and may be incomplete or incorrect, which can affect spending totals, budgets, and insights.
• Transfers between your own accounts. Movements of money between accounts you own, and incoming credits such as e-transfers, deposits, or payroll, may not be detected as internal or as income in every case, and may be counted or excluded differently across screens.
• Institution or provider data quality. The completeness and accuracy of data depend on your financial institution and on the aggregation provider; some institutions expose limited, delayed, duplicated, or malformed data, or temporarily stop providing data.
• Connectivity outages and re-authentication. A connection may temporarily fail, require you to re-authenticate, or need to be re-linked, during which balances and transactions may be stale, missing, or partially updated.
• Currency, rounding, and formatting. Rounding, currency conversion, and display formatting may introduce small differences from your institution's figures.
• Manual entries and edits. Transactions, categories, budgets, or amounts you add or edit yourself, and any duplicate or offsetting entries, will affect the totals Mossy shows.
• Different calculations across features. Different screens and features may define or compute a figure (such as monthly spending) using different rules, time windows, account selections, or filters, which can produce different results for what may appear to be the same number.
• Hidden, closed, removed, or newly added accounts. Accounts that are hidden, unlinked, closed, or recently connected may be included or excluded from a given figure, changing the total.
• Estimates, projections, and AI-generated insights. Any forward-looking or estimated figure is a projection based on available data, not a guarantee, and actual results will differ.

You acknowledge that discrepancies of this kind can occur, that Mossy does not warrant that the information displayed is accurate, current, complete, or free of error, and that Mossy is not liable for any action taken, or decision made, in reliance on figures shown in the Service. Always verify important financial information directly with your financial institution before acting on it.

5. Third-Party Services

The Service relies on third-party providers for functions such as financial connectivity, AI processing, hosting, communications, analytics, security, and support. We are not responsible for third-party service availability, errors, policy changes, or independent processing practices. Your use of an optional connected service may also be subject to that provider's terms and disclosures presented when you connect it.

5A. Beta Testing Programs

If you use pre-release versions of the Service through beta channels (including TestFlight, beta web environments, and Android testing tracks), you acknowledge and agree that:

• Beta features are experimental, may be incomplete, and may change or be removed at any time.
• Functionality may break, produce errors, lose settings, or be temporarily unavailable.
• Performance may be degraded and compatibility may vary across devices and operating systems.
• Data loss, delayed synchronization, or inaccurate outputs may occur in beta environments.
• We may collect enhanced diagnostics and feedback to improve stability and security.
• Beta access may be suspended or revoked at our discretion without notice.

6. Prohibited Conduct

• Do not misuse the Service, attempt unauthorized access, or interfere with functionality.
• Do not upload malicious content, violate law, or infringe third-party rights.
• Do not reverse engineer or abuse APIs except where law permits.

6A. Reverse Engineering Restrictions

Except where applicable law expressly prohibits this restriction, you may not copy, modify, decompile, disassemble, reverse engineer, or otherwise attempt to derive source code, underlying models, data schemas, or non-public implementation details of the Service.

7. Intellectual Property

Mossy and its licensors retain all rights in the Service, software, trademarks, and content except where rights are expressly granted.

8. Feedback

If you submit feedback, you grant us a worldwide, royalty-free license to use it to improve products and services without obligation.

9. Suspension and Termination

We may suspend or terminate access if we reasonably believe these Terms are violated, required by law, or necessary to protect users, systems, or third parties.

We also reserve the right to restrict, suspend, or ban accounts involved in fraud, harassment, abusive behavior, security abuse, or other conduct that creates risk to users, employees, partners, or the Service.

10. Disclaimers

The Service is provided "as is" and "as available" to the fullest extent permitted by law, without warranties of merchantability, fitness for a particular purpose, or non-infringement.

Beta and testing environments are provided with no uptime, reliability, or data preservation guarantees.

11. Limitation of Liability

To the maximum extent allowed by law, Mossy is not liable for indirect, incidental, special, consequential, or punitive damages, or for lost profits, revenues, or data.

12. Indemnification

You agree to defend and indemnify Mossy from claims arising from your misuse of the Service, violation of these Terms, or infringement of third-party rights.

13. Governing Law and Venue

These Terms are governed by the laws of Canada and applicable provincial laws, without regard to conflict-of-law rules, subject to mandatory consumer protections.

14. Updates to Terms

We may revise these Terms. Continued use after updates means you accept the revised Terms.

15. Subscription Cancellation and Refund Policy

• You may cancel your subscription at any time from your account settings or through the purchase platform used to subscribe.
• When you cancel, your subscription remains active until the end of your current paid billing period.
• We do not provide full or partial refunds for unused time when a user cancels during an active subscription term, except where required by applicable law.
• If billing occurred due to a verified platform error or unauthorized charge, please contact us for review.

Referral Program Terms

These Referral Program Terms ("Referral Terms") govern the Mossy referral program (the "Program") and supplement the Terms of Use above. By participating in the Program as a referrer or as a referred user, you agree to these Referral Terms. Capitalized terms not defined here have the meaning given in the Terms of Use. To the extent of any conflict, the Terms of Use control except for matters specific to the Program addressed here.

1. Eligibility

• You must be an adult with a Mossy account in good standing to participate as a referrer.
• Referred users must be new Mossy users who have never previously created or held a Mossy account.
• You and the referred user must reside in the same country, and the Program must be available in that country.
• Referred users must consent to receiving your invitation. You may only share your referral code or link with people you personally know and who agree to receive it. You may not spam, post to unsolicited audiences, use paid search or misleading advertising, impersonate Mossy, or distribute codes in any deceptive, automated, or bulk manner.
• Self-referrals and the creation or use of duplicate, fake, incentivized, purchased, or fraudulent accounts are prohibited.

2. How Referrals Qualify

• A referral counts only when the referred user signs up using your referral code and then completes two (2) consecutive paid subscription months as a paying subscriber.
• Free trials, promotional periods, complimentary access, and periods that are later refunded, charged back, reversed, or cancelled do not count toward qualification.
• If a referred user receives a refund or chargeback, or cancels before completing the required paid period, the referral will not qualify, and any related reward may be withheld or reversed.
• Mossy determines, in its sole discretion, whether a referral is valid and has qualified. Mossy's determination is final.

3. Rewards

• For every two (2) qualified referrals, you earn thirty (30) days of free Mossy subscription access.
• You may earn a maximum of sixty (60) free days within any rolling twelve (12) month period, regardless of the number of referrals.
• Rewards are issued as subscription credit only. Rewards have no cash value and are not redeemable for money, except where required by law.
• Rewards are personal to you, are non-transferable, and may not be sold, assigned, auctioned, or combined with certain other offers, discounts, or promotions.
• Reward days are applied to your subscription and may be forfeited if your account is closed, suspended, terminated, or found to be in violation of these Referral Terms or the Terms of Use.
• You are responsible for any taxes that may apply to rewards you receive.

4. Fraud, Abuse, and Enforcement

• Mossy may withhold, delay, reduce, revoke, or reverse rewards, and may disqualify referrals, where it reasonably suspects fraud, abuse, gaming, manipulation, or violation of these Referral Terms or the Terms of Use.
• Prohibited activity includes, without limitation, self-referral, fake or duplicate accounts, automated or bulk distribution, bots, scripts, spam, payment of others to subscribe, and any attempt to circumvent Program limits or detection.
• Mossy may suspend or terminate the Program participation of, or close the accounts of, users who engage in prohibited activity, and may pursue any other remedies available under the Terms of Use or applicable law.

5. Changes and Termination

• Mossy may modify, suspend, limit, or terminate the Program, or change these Referral Terms, at any time and without prior notice, to the extent permitted by law.
• Rewards that have already been validly earned and applied to your account before a change takes effect will be honored.
• The Program is void where prohibited or restricted by law.

6. Disclaimers and General

• The Program is provided on an "as is" and "as available" basis without warranties of any kind, to the fullest extent permitted by law.
• The Limitation of Liability, Indemnification, and Governing Law and Venue provisions of the Terms of Use apply to your participation in the Program.
• If any provision of these Referral Terms is held unenforceable, the remaining provisions remain in full force and effect.

Contact

For legal, privacy, or compliance inquiries, contact: legal@mossyapp.com