Privacy Policy

1. Introduction

Financial Fitness Passport, Inc. ("we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, and protect your information when you use the Financial Fitness Passport App ("App").

By using our App, you agree to this Privacy Policy. If you do not agree, please do not use the App.

2. Information We Collect

Personal Information

We collect information that you provide directly to us, including:

• Account Information: Name, email address, password (encrypted), and account credentials
• Verification Data: Email verification status and verification timestamps
• Profile Information: User preferences, settings, and customization choices

Financial Information

You may choose to provide sensitive financial data, including:

• Income, savings, and emergency fund amounts
• Debt balances, interest rates, and repayment plans
• Investment account balances and contribution rates
• Insurance coverage details and estate planning status
• Cash flow data (income sources and expense categories)
• Tax information (filing status, deductions, state tax data)
• Employee benefits details (health plan elections, 401(k) match, HSA/FSA enrollment, equity compensation, and other employer-provided benefits)

AI Inputs & Outputs

When you use our AI-powered Pro features (Penny AI Assistant, AI Tax Planner, Personalized Roadmap, Progress Interpreter, Document Analysis, Employee Benefits Analyzer), we collect:

• Questions, prompts, and messages you submit to the AI
• AI-generated responses and recommendations
• Context data (your financial profile used to personalize AI outputs)
• Chat history and conversation logs

Uploaded Documents

Pro features include the ability to upload financial documents (insurance declarations, estate documents, and employee benefits guides) for AI-powered analysis. When you upload a document:

• The document is temporarily stored in Firebase Storage solely for the purpose of processing
• The document content is transmitted to OpenAI for AI analysis
• The document is permanently and immediately deleted from our systems the moment analysis is complete. No copy is retained.
• The AI-generated analysis (text only) is returned to you and is not stored on our servers

Payment Information

• Processed by Stripe: Credit card information is collected and processed by Stripe, Inc. We do not store full credit card numbers
• Subscription status, billing history, and payment method type
• Promotional codes used and discount applications

Usage Data & Analytics

We automatically collect:

• Device information (type, operating system, browser)
• IP address and approximate geographic location
• App interactions, page views, and feature usage
• Login count and session duration
• Only if you allow analytics: product-usage events (PostHog) and Google Analytics / Firebase Analytics data — see Section 11

Cookies & Tracking Technologies

We use cookies and similar technologies (including browser localStorage) for authentication, security and preferences, and — only with your consent — for analytics and advertising measurement. Section 11 lists them and explains how to change your choice.

3. How We Use Information

We use your data to:

• Operate and improve the App: Provide core features, calculate your Financial Fitness score, generate badge assessments, and track progress
• Provide AI-powered insights: Generate personalized financial recommendations, coaching, roadmaps, and progress analysis using third-party AI engines
• Process payments: Manage Pro subscriptions, apply promotional codes, and handle billing
• Communicate with you: Send account notifications, educational content, feature updates, security alerts, and customer support responses
• Analyze trends and enhance user experience: Understand how features are used, identify bugs, and develop improvements
• Provide benchmarking (opt-in): Aggregate anonymized data for community comparisons
• Comply with legal obligations: Respond to subpoenas, prevent fraud, enforce our Terms, and maintain audit logs
• Maintain security: Detect and prevent unauthorized access, abuse, and security threats

4. How We Share Information

Service Providers

We share data with trusted third-party service providers:

• Firebase (Google): Authentication, Firestore database, Firebase Storage, and Analytics
• Stripe: Payment processing and subscription management
• OpenAI: AI-powered features — GPT-4o-mini for Penny AI chat, Tax Planner, Roadmap, and Progress Interpreter; GPT-4o (vision model) for Document Analysis and Employee Benefits Analyzer, which processes uploaded document content
• Vercel: Application hosting and deployment infrastructure
• PostHog: Product analytics and session replay — only with your analytics consent (Section 11)
• Google Analytics / Firebase Analytics (Google): Website and app usage analytics — only with your analytics consent
• Meta, TikTok and Reddit: Advertising measurement pixels, and for Meta a purchase report from our servers (Conversions API) — only with your marketing consent

These providers are contractually obligated to protect your data and use it only for the purposes we specify.

Third-Party AI Processing

Legal Requirements

We may disclose information when required by law or to:

• Comply with legal process (subpoenas, court orders)
• Protect rights, property, and safety
• Prevent fraud or security threats
• Enforce our Terms and Conditions

Business Transfers

During a merger, acquisition, sale, or reorganization of our business, your information may be transferred to the successor entity. We will notify you of any such change.

Aggregated & Anonymized Data

We may share de-identified or aggregated data that cannot reasonably identify you for research, marketing, or analytics purposes.

We Do Not Sell Your Data

We do not sell your personal information to third parties for monetary consideration.

If you allow marketing cookies, the Meta, TikTok and Reddit pixels receive information about your visit (and, for Meta, a purchase report) to measure our advertising. Some U.S. state laws treat this as “sharing” for cross-context behavioral advertising. It happens only with your consent, you can withdraw it at any time in Cookie preferences, and we treat a Global Privacy Control signal as an opt-out of it.

5. Use of Artificial Intelligence and Data Processing

Our App integrates third-party AI services (OpenAI GPT-4o-mini and GPT-4o) that process user data to generate insights, coaching, roadmaps, progress analysis, and document analysis. This includes the content of any financial documents you upload via the Document Analysis or Employee Benefits Analyzer features.

By using AI-powered features, you consent to your data being transmitted to and processed by external AI providers. You can avoid this by using only the free features of the App.

6. Data Retention

We retain personal and financial data as long as your account is active or as needed to:

• Provide Services and support
• Comply with legal obligations (tax records, financial regulations)
• Resolve disputes and enforce agreements
• Prevent fraud and abuse

Account Deletion

You may request deletion of your account and data at any time by:

• Using the "Delete Account" feature in your Profile settings, or
• Emailing support@financialfitnesspassport.com

Upon deletion, we will remove your personal information within 30 days, except where retention is required by law or for legitimate business purposes (e.g., fraud prevention, dispute resolution, archival logs for compliance).

7. Security

We use reasonable technical and organizational measures to protect your data, including:

• Firebase Authentication with bcrypt password hashing
• Encrypted data transmission (HTTPS/TLS)
• Firestore Security Rules to restrict unauthorized access
• Firebase Storage Security Rules for file protection
• Server-side authentication verification via Firebase Admin SDK
• Email verification enforcement before accessing protected features
• Rate limiting on AI API endpoints
• Technical measures to limit demo usage and prevent abuse (these measures do not involve collecting personal financial or account information)
• Comprehensive security headers (CSP, HSTS, X-Frame-Options)
• Regular security audits and dependency updates
• Archival logging with SHA-256 hashing for audit trails

8. Your Rights

Depending on your jurisdiction (GDPR, CCPA, or other applicable laws), you may have rights to:

Access & Portability

• Access and download your personal data
• Request a copy of your data in a portable format (JSON export available in Profile)

Correction & Deletion

• Correct inaccurate information
• Request deletion of your account and data

Consent & Opt-Out

• Withdraw consent to data processing
• Opt out of marketing communications
• Opt out of community benchmarking (Profile settings)
• Choose or change analytics and marketing cookies at any time (“Cookie preferences” in the footer, or Profile settings) — see Section 11
• Do Not Sell My Personal Information (CCPA) - We do not sell data

Complaints

File a complaint with a data protection authority in your jurisdiction

To exercise your rights, email us at support@financialfitnesspassport.com. We will respond within 30 days.

9. Children's Privacy

Our App is intended for adults (18+). We do not knowingly collect information from minors under 18.

If we become aware that a child has provided information, we will delete it promptly. If you believe we have collected data from a minor, please contact us immediately.

10. International Users & Data Transfers

Our App is operated in the United States. If you access it from outside the U.S., your information will be transferred to, stored, and processed in the United States.

By using the App, you consent to the transfer and processing of your data in the U.S., which may have different data protection laws than your country. We use Firebase and other services with global infrastructure that may process data in multiple jurisdictions.

GDPR (European Users)

If you are in the European Economic Area (EEA), you have additional rights under GDPR, including data portability, erasure, and the right to lodge complaints with supervisory authorities.

CCPA (California Users)

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, request deletion, and opt out of data sales (we do not sell data).

11. Cookies & Tracking Technologies

We use cookies and similar technologies, including browser localStorage and sessionStorage. On the website, nothing optional runs until you make a choice in the cookie banner; until then, and if you choose “Reject non-essential”, only the necessary and functional items below are used.

Necessary (always on)

• Your sign-in session (Firebase Authentication, stored in your browser's IndexedDB)
• Security and app state: the email address for an email sign-in link, advisor view-as sessions, pending invitation codes, and Penny chat history for the current browser session
• Your cookie choice itself (ffp_consent_v1 in localStorage — not a cookie, never sent to us or anyone else)

Functional

• Preferences such as dismissed tips and prompts, onboarding progress, and cached prices (localStorage)
• Referral attribution: when you open a referral link, a first-party cookie (ffp_ref, 30 days) remembers the code so the referrer can be credited when you sign up. It is not shared with advertising networks.

Analytics (only with your consent)

• PostHog (cookie and localStorage ph_*): page views, automatically captured clicks and interactions, and — where enabled — session replay, with all text and form inputs masked. When you are signed in, events are linked to your account ID, email address and name.
• Google Analytics 4 / Firebase Analytics (cookies such as _ga): usage analytics. Google Consent Mode is set to “denied” by default and the Google tag is not loaded until you allow analytics.

Marketing (only with your consent)

• Meta Pixel (cookies such as _fbp, _fbc), TikTok Pixel and Reddit Pixel: measure visits and conversions from our ads
• Meta Conversions API: when you buy a paid plan, our servers may send Meta your email address in hashed form and the Meta click identifiers above — only if marketing consent was in force when you started checkout.

Abuse prevention (Penny demo)

The public Penny demo page computes a device fingerprint from browser characteristics (such as browser version, language, screen size, time zone and how your device renders a small test image) to limit free demo usage. It is stored with a usage count and is not used for analytics or advertising.

Your choices

• Open Cookie preferences (also in the site footer and your Profile) to accept or reject analytics and marketing at any time. The choice is stored on this device.
• Withdrawing analytics consent stops PostHog and Google Analytics at once and deletes their cookies on our domain. Withdrawing marketing consent deletes the pixels' cookies on our domain and reloads the page without them. Data already sent to a provider is handled under that provider's own policies.
• If your browser sends a Global Privacy Control signal, marketing stays off and the advertising pixels are not loaded.
• If you turn analytics off in Profile settings while signed in, it stays off on this device and on other devices where you sign in — the cookie banner cannot turn it back on; only the Profile setting can.
• In the mobile app, the advertising pixels and the Google Analytics website tag are never loaded; product analytics can be turned off in Profile settings.
• Separately from cookies, our servers record some account and billing events (for example, subscription changes), including in our product-analytics tool. These are not stored in your browser and are not controlled by cookie preferences.

12. Email Communications

We may send you:

• Transactional emails: Account verification, password resets, billing notifications (cannot opt out)
• Service updates: Feature announcements, security alerts, Terms changes
• Educational content: Financial wellness tips, academy lessons (opt-out available)
• Marketing communications: Promotions, product news (opt-out available)

You can manage email preferences in your Profile settings or click "unsubscribe" in any marketing email.

13. Community Benchmarking (Opt-In)

Pro users may opt in to share anonymized data for community benchmarking. When you opt in:

• Your passport score and debt metrics are aggregated with other users' data
• All data is fully anonymized before aggregation (no names, emails, or identifiers)
• You can view community averages and compare your progress
• You can opt out at any time from Profile settings

14. Data Breach Notification

In the event of a data breach that affects your personal information, we will notify you and relevant authorities as required by applicable law. Notification will be sent to your registered email address without undue delay.

15. California Privacy Rights (Shine the Light)

California residents may request information about disclosures of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing.

16. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. The latest version will always be posted in the App with a revised "Last Updated" date.

Material changes will be announced via email or in-app notification. Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

17. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your data, contact: