Privacy policy

Contents and use

This Privacy Policy explains how Anseris Wealth, Inc. collects, uses, discloses, retains, and protects personal data when an individual uses the Anseris mobile application, website, and related consumer services. It is a separate public notice; the internal Information Security Policy and Data Retention and Secure Disposal Policy do not replace it.

• Scope and roles: the Anseris Services, separate regulated providers, and other notices

• Data map: information provided by the user, connected accounts, investments, subscriptions, devices, and derived outputs

• Processing: purposes, algorithmic categorization, tailored guidance, and investment tiers

• Disclosures: service providers, financial institutions, regulated entities, legal recipients, and corporate events

• Lifecycle: cookies and SDKs, retention, security, account disconnection, deletion, and backup handling

• Rights: privacy choices, state rights, authorized agents, appeals, opt-out signals, and contact methods

1. Scope

This Privacy Policy applies to personal data processed by Anseris Wealth, Inc. (Anseris, we, us, or our) through the Anseris mobile application, website, support channels, and related consumer features that link to this Policy (the Services).

It does not by itself govern a bank, financial institution, financial-data provider, broker-dealer, investment adviser, custodian, fund, payment processor, app store, or other third party when that party determines its own purposes and means of processing. Those parties may provide separate privacy notices. Section 14 explains how regulated financial privacy notices interact with this Policy.

This Policy is drafted for United States users acting in an individual or household context. Workforce and applicant data are governed by separate notices where required.

2. Who is responsible for your data

Anseris is responsible for personal data when it decides why and how the data are processed for the Services. Our contact information appears in Section 18.

For an enabled investment or banking feature, one or more separately identified regulated entities may independently control or jointly determine processing for account opening, identity verification, suitability or best-interest review, advice, order handling, custody, clearing, banking, tax reporting, and compliance. The application and applicable agreement must identify those entities and link their privacy notices before data are collected for that purpose.

Anseris may also process data for a regulated provider under contract. The applicable agreement and notice will explain the roles if that occurs.

3. Personal data we collect

The data we collect depends on the features you request, accounts you connect, plan you purchase, jurisdiction, and whether investment services are enabled.

3.1 Account, profile, and contact data

We may collect your name, email address, telephone number, mailing address, login identifier, authentication and recovery information, communication preferences, state of residence, age or age confirmation, account status, and records showing which notices and terms you accepted.

We store authentication secrets in protected form. We may collect device-bound authentication information or multifactor-enrollment status, but we do not receive the underlying biometric template used by your device’s Face ID, Touch ID, or similar platform authentication unless a separate feature expressly says otherwise.

3.2 Questionnaire and financial-wellness data

We may collect responses about financial goals, budgeting and saving habits, income and expense patterns, household circumstances, liabilities, expected obligations, emergency savings, time horizon, risk preferences, investment knowledge or experience, and other information needed to provide a requested category, plan, or feature.

Avoid entering information we do not request, particularly health, precise location, immigration, biometric, or other highly sensitive details in a free-text field or support message.

3.3 Connected financial-account data

If you authorize a connection, we may receive from your financial institution through a contracted provider:

• up to the prior 90 days of transactions for the initial connection and ongoing transaction updates;

• current balances, account type, account nickname, partial or masked account identifiers, and institution name;

• current investment holdings, securities, cost or performance fields, and cash positions where an enabled feature requires them;

• current liabilities, payment information, rates, or related metadata where an enabled feature requires them;

• provider request identifiers, synchronization cursors, authorization status, and connection-error information; and

• other fields shown in the connection-consent flow and reasonably necessary for the requested feature.

Anseris is designed not to collect or store your financial institution username or password. The provider or institution handles the authorization interface and may issue an encrypted connection credential or token to our backend service. We do not place connection credentials in client code, general logs, analytics, or support tools.

3.4 Investment-account and regulated financial data

If you apply for or use an enabled investment feature, Anseris or the identified regulated provider may collect:

• legal name, date of birth, residential and mailing address, taxpayer identification number, citizenship or residency, and government identification;

• employment, occupation, employer, income, net worth, liquid net worth, source of funds, affiliations, and regulatory or insider status;

• investment objectives, time horizon, risk tolerance, experience, liquidity needs, restrictions, and questionnaire responses;

• bank instructions, funding source, transfer status, cash balance, positions, orders, executions, confirmations, statements, fees, tax lots, distributions, and tax forms;

• sanctions, identity, fraud, account-approval, suitability, best-interest, compliance, complaint, and supervisory records; and

• account agreements, disclosures, consents, electronic-delivery choices, and communications.

The collecting entity, required fields, legal basis, sharing, and retention must be identified before the feature is used. Do not submit this information through an ordinary support channel.

3.5 Subscription, payment, and transaction data

We may collect plan, price, billing interval, trial, promotion, subscription status, renewal, cancellation, receipt, tax, refund, and payment-status information. A payment processor or app store generally collects and stores full payment-card or payment-account credentials. We may receive a token, partial identifier, billing address, and transaction result.

3.6 Communications and support data

We collect messages, requests, complaints, survey responses, call or chat metadata, attachments you choose to provide, troubleshooting information, privacy-rights requests, and records of how we responded. We may collect a non-sensitive provider request identifier to investigate a connection problem.

Do not send financial institution credentials, full account numbers, connection tokens, recovery codes, or unnecessary financial screenshots to support.

3.7 Derived and inferred data

We may derive transaction classifications, recurring-payment indicators, cash-flow measures, financial-health or habits categories, target budgets, savings suggestions, liability-payoff scenarios, investment or fund tiers, risk-related outputs, feature vectors, quality indicators, and minimal decision provenance such as algorithm version and timestamp.

Derived data can be personal data even when it is not directly provided by you. We protect and retain user-linked outputs under the applicable schedule in Section 10.

4. Sources of personal data

We collect personal data from:

• you, including through signup, questionnaires, settings, subscriptions, applications, support, and privacy requests;

• your authorized financial institutions and financial-data providers, when you connect an account;

• regulated financial entities and service providers, including identity, brokerage, advisory, custody, clearing, banking, fund, transfer, payment, tax, fraud, and sanctions providers if a feature is enabled;

• your device and use of the Services, through logs, cookies, SDKs, and similar technologies;

• public, government, sanctions, identity, and compliance sources, when needed for security or regulated account opening; and

• other people you authorize, such as an authorized agent or account representative, subject to verification.

5. How we use personal data

We use personal data only for documented purposes reasonably necessary and proportionate to the Services, including to:

• create, authenticate, secure, maintain, and close your Anseris account;

• connect, refresh, display, reconcile, disconnect, and delete authorized financial-account data;

• administer the questionnaire and calculate financial-health or habits categories;

• generate target budgets, savings guidance, liability-payoff scenarios, educational content, and tailored financial-wellness outputs;

• display investment holdings and performance information from connected or regulated-provider accounts;

• determine feature eligibility and, if regulated services are enabled, support identity verification, account opening, suitability or best-interest processes, advice, orders, custody, funding, tax, and compliance;

• provide subscriptions, process payments, send receipts and renewal notices, handle cancellation, and prevent billing abuse;

• respond to support, complaints, privacy rights, security reports, and legal requests;

• monitor reliability, debug errors, measure aggregate use, test changes, and improve accessible product operation;

• prevent fraud, account takeover, misuse, money laundering, sanctions violations, market abuse, and other harmful or unlawful activity;

• protect rights, safety, systems, users, providers, and the integrity of algorithms and data;

• comply with law, regulation, court order, tax, recordkeeping, examination, audit, insurance, and contractual obligations; and

• establish, exercise, or defend legal claims and complete a merger, financing, reorganization, or similar corporate transaction.

We do not use Restricted user data for employee curiosity, unrelated advertising, or training a general-purpose model. We will conduct a privacy and security review before adding a materially new data category, use, recipient, tracking technology, algorithmic purpose, or retention period and will provide notice or obtain consent when required.

6. Algorithmic processing and financial profiles

6.1 What the system does

The Services combine questionnaire responses with permitted connected-account data and apply version-controlled rules or models to assign a financial-health or habits category, generate a target budget, and tailor savings, liability, and financial-wellness guidance. If investment features are enabled, a separate process may use questionnaire and financial information to place a user in an investment or fund tier or to support a regulated recommendation.

The inputs may include information you provide and patterns visible in available balances, transactions, holdings, liabilities, and cash flow. The exact factors and weights depend on the feature and current version. We do not claim to evaluate information that is missing, unlinked, stale, or outside the authorized scope.

6.2 Consequences and limits

An output may affect which educational content, budget, savings suggestion, payoff sequence, product explanation, or investment tier you see. It may also determine that there is not enough information to provide an output. An Anseris financial-health category is not a credit score and is not intended for use in employment, housing, insurance, education, credit, or another third-party eligibility decision.

Algorithmic outputs may be wrong because an institution supplied incomplete data, a transaction was misclassified, a questionnaire response was inaccurate, or circumstances changed. We test boundary conditions and safe fallbacks, record the algorithm version and decision timestamp needed for investigation, and limit verbose user-level traces.

6.3 Your choices and review

You may update questionnaire responses, disconnect an account, request correction of inaccurate personal data, contact support about an output, and exercise applicable privacy rights. Where applicable law grants a right to access information about or opt out of automated decision-making or profiling, submit a request under Section 13.

If processing is necessary to provide a feature you requested, opting out may mean that we cannot provide the category, tailored guidance, investment tier, or regulated service. A regulated investment recommendation or account decision may be governed by separate review and complaint procedures.

7. How we disclose personal data

We disclose personal data only as described below, as directed by you, or with notice or consent required by law.

7.1 Service providers and processors

We use contracted providers for cloud hosting, databases, identity and authentication, financial-data connectivity, encryption and key management, monitoring, security, analytics, crash reporting, communications, support, payment, document delivery, and professional services. They may process data only for contracted purposes and must apply confidentiality, security, incident, subprocessor, rights-assistance, and deletion obligations appropriate to risk.

7.2 Financial institutions and regulated providers

When you request a connection or investment feature, we may disclose data to or receive data from your financial institution, financial-data provider, broker-dealer, investment adviser, custodian, clearing firm, bank, fund issuer or manager, transfer agent, payment network, identity-verification provider, tax provider, and other entity needed for that feature.

These parties may act as our service providers or as independent regulated entities. Their agreements and privacy notices govern their independent processing. We will identify the entities before collecting data for account opening or regulated investment activity.

7.3 Professional advisers and insurers

We may disclose data to lawyers, accountants, auditors, consultants, penetration testers, insurers, and other professional advisers under confidentiality and only as reasonably necessary for advice, compliance, risk, claims, or defense.

7.4 Legal, safety, and integrity disclosures

We may disclose data when we reasonably believe it is necessary to comply with law, regulation, legal process, examination, tax obligation, regulator, law enforcement, or court order; enforce agreements; investigate fraud, security incidents, market abuse, or unlawful conduct; or protect the rights, safety, property, and integrity of users, providers, Anseris, or the public.

We evaluate requests and disclose only the information reasonably necessary, unless prohibited from doing so.

7.5 Corporate transactions

We may disclose data in connection with due diligence, financing, merger, acquisition, reorganization, sale of assets, insolvency, or similar transaction. Recipients must protect the data and may use it only for the transaction unless they provide required notice and choices for a new purpose.

7.6 Aggregate and de-identified information

We may disclose aggregate or de-identified information when re-identification is not reasonably likely in context, and we apply technical, contractual, and organizational controls against re-identification. Pseudonymous information remains personal data when it can reasonably be linked back to a person.

8. Sale, sharing, targeted advertising, and sensitive data

We do not sell personal data for money or other valuable consideration. We do not share personal data for cross-context behavioral advertising or process Restricted financial data for unrelated advertising. We do not sell sensitive personal data.

We use limited service-provider analytics to understand and secure our own Services. Before publication, Anseris must verify every website cookie, advertising tag, mobile SDK, referral tool, and analytics contract because some state laws may treat certain third-party advertising or measurement disclosures as a sale, sharing, or targeted advertising even when no money changes hands.

If our practices change, we will update this Policy, provide any required notice, and offer legally required opt-outs before the new processing begins. We honor applicable opt-out preference signals as described in Section 13.

9. Cookies, mobile SDKs, and similar technologies

Our website and application may use:

• strictly necessary technologies for sign-in, security, fraud prevention, consent, load balancing, and core operation;

• preference technologies for language, accessibility, and saved settings;

• measurement technologies for redacted usage, performance, crash, and reliability analytics; and

• communications technologies for service messages and support.

The current technology inventory and controls will be available through in-app controls and browser controls. You may manage non-essential technologies through in-app controls, device settings, or browser controls. Blocking a necessary technology may prevent a feature from working.

We do not permit ordinary analytics events to contain raw financial payloads, institution credentials, connection tokens, full account numbers, questionnaire content, target budgets, or recommendation content.

10. Retention and deletion

We keep personal data only as long as reasonably necessary and proportionate to the stated purpose, contract, or legal obligation. The following are maximum default periods from the internal retention schedule; a feature may use a shorter period. A legal hold, security incident, dispute, tax, regulated recordkeeping duty, or other approved legal requirement may extend a specifically scoped period.

When you disconnect an account, we immediately stop new collection for that connection and initiate provider-supported revocation or deauthorization. When you close your Anseris account or submit a valid deletion request, our internal target is to disable ordinary processing immediately and complete deletion from active company systems within 30 calendar days, unless a faster legal deadline or a narrow exception applies.

Active systems include replicas, caches, indexes, data warehouses, feature stores, analytics, and exports; they are not treated as backups. We keep minimal deletion evidence without reconstructing deleted financial content. If a backup is restored, we replay deletion, disconnection, and consent changes before normal use resumes.

11. Security

We maintain administrative, technical, and physical safeguards designed for the sensitivity of personal and financial data. These include role-based access, multifactor authentication, encryption in transit and at rest, managed secrets, environment separation, secure development, vulnerability management, logging and alerting, service-provider review, encrypted backups, restore testing, incident response, and secure disposal.

No method of transmission or storage is completely secure. You can help by using a unique password, enabling available multifactor authentication, protecting your device and recovery methods, reviewing account activity, and reporting suspected compromise immediately to support@anseriswealth.com.

If an incident affects your data, we will investigate and provide notices required by applicable law or a regulated agreement. A notice may come from Anseris or an identified regulated provider when that provider is responsible for the affected account or information.

12. Your privacy choices

12.1 Account and questionnaire information

You may review and update available profile, contact, questionnaire, and preference information through account settings. Contact support if a field cannot be changed directly. Some regulated records may require verification or must be preserved as an audit trail even after a correction.

12.2 Connected accounts

You may disconnect an account through [IN-APP DISCONNECTION PATH]. This stops new collection and initiates revocation and deletion under Section 10. Disconnecting may remove or reduce categories, budgets, investment views, and other dependent features.

12.3 Marketing and notifications

You may unsubscribe from marketing email through the message link and manage push notifications through the application or device settings. We may still send security, billing, legal, privacy, account, and other non-marketing service messages.

12.4 Cookies and mobile technologies

Manage non-essential technologies through in-app controls or browser controls. See Section 9.

12.5 Account closure and deletion

Closing an Anseris account, cancelling a subscription, disconnecting a financial account, and closing an investment account are separate actions. Use [ACCOUNT CLOSURE PATH] to request Anseris account closure, and follow the separate provider’s procedure for an investment or bank account. We will explain any narrow record we must retain and its expected deletion point.

13. United States state privacy rights

Depending on your state and whether an exemption applies, you may have the right to:

• confirm whether we process your personal data and access or obtain a copy;

• correct inaccurate personal data;

• delete personal data, subject to lawful exceptions;

• receive portable data in a usable format where technically feasible;

• know the categories or specific pieces of data, sources, purposes, categories of recipients, or third parties involved;

• opt out of sale, sharing, targeted advertising, or certain profiling or automated decision-making;

• limit certain uses or disclosures of sensitive personal data;

• withdraw consent for processing that depends on consent;

• appeal a decision on a privacy request; and

• receive equal service and not be discriminated against for exercising a right.

13.1 How to submit a request

Submit a request by sending an email to support @anseriswealth.com. Describe the right, state of residence, and account email. Do not send a password, connection token, full Social Security number, or unnecessary identification document.

We will verify a request proportionately based on the sensitivity and requested action. If we deny or limit a request, we will explain the basis and available appeal process. Submit an appeal through support@anseriswealth.com with the original request identifier. We will respond within applicable deadlines, generally 45 days under many state laws, subject to permitted extensions.

An authorized agent may submit a request where law permits. We may verify the agent’s authority and, where allowed, ask you to confirm the request directly. A parent or guardian must use the process in Section 15 for a minor.

13.2 Opt-out preference signals

We do not currently sell or share personal data for cross-context behavioral advertising. Where required, our website will process a recognized browser-based opt-out preference signal, such as Global Privacy Control, as a request for the browser or device and, when known, the associated account. Because we do not currently engage in the covered sale or sharing, processing the signal ordinarily confirms the existing no-sale and no-sharing practice.

The application must verify signal handling and display any status required by law before publication. You may also use the methods in Section 13.1.

13.3 California notice

For California residents, the categories described in Section 3 map generally to identifiers; customer records; protected classification information if voluntarily provided or legally required; commercial and subscription information; internet or electronic activity; general geolocation inferred from IP; audio or communications information if a support channel records it with notice; professional or employment information used for account opening; education or experience information if requested; financial information; and inferences or profiles.

In the prior 12 months, Anseris may collect, use, and disclose those categories for the purposes in Section 5 and to the recipient categories in Section 7. We do not sell them or share them for cross-context behavioral advertising. Sensitive personal information, such as account credentials handled by providers, government identifiers used for regulated account opening, and precise authentication information, is used or disclosed only for permitted service, security, compliance, and other disclosed purposes unless we provide a separate right to limit.

California residents may exercise the rights in this Section, including applicable rights to access information about or opt out of certain automated decision-making technology. The scope and implementation schedule of those rights depend on the applicable California regulations and the feature’s use of automated processing.

13.4 Maryland, Delaware, and other state rights

Maryland residents may have rights to limit, opt out, correct, know, receive equal treatment, and delete under the Maryland Online Data Privacy Act. Delaware residents may have rights to access, correct, delete, port data, opt out of sale, targeted advertising, and certain profiling, consent to and withdraw consent for sensitive-data processing, and appeal a decision.

Residents of other states may have similar rights. Anseris may choose to honor a right more broadly even when a statute does not require it, but doing so does not concede that a particular law applies or waive an exemption for data governed by federal financial-privacy law.

13.5 Nevada and no-sale requests

Nevada residents may submit a verified request not to make a covered sale using Section 13.1. We do not currently make such sales.

14. Financial privacy notices and regulated data

This Policy is the general Anseris online and mobile privacy notice. It is not automatically a substitute for a notice required under the Gramm-Leach-Bliley Act, Regulation P, SEC Regulation S-P, or another financial-services law.

If Anseris or an identified affiliate becomes a covered financial institution, broker-dealer, investment company, or registered investment adviser, we or the applicable regulated entity will provide the required initial, annual, opt-out, safeguarding, disposal, and incident notices. A separately delivered financial privacy notice controls for the nonpublic personal information and regulated relationship it covers, while this Policy continues to govern Anseris processing outside that notice’s scope.

If two notices appear inconsistent, contact support@anseriswealth.com before providing additional information. We will identify the relevant entity and controlling notice.

15. Children and teens

The Services are not directed to children under 18, and we do not knowingly permit a person under 18 to create an account. If you believe a minor provided personal data, contact support@anseriswealth.com so we can investigate and delete it as appropriate.

Do not connect or submit another person’s account or data, including a child’s data, unless the feature expressly supports it and you have all required authority and consent. Any future custodial or teen feature will require a separate review, notice, consent, and product flow before launch.

16. United States processing

The Services are offered for United States users, and personal data may be processed and stored in the United States. If we later offer the Services outside the United States or transfer data subject to another country’s law, we will update this Policy and provide required safeguards and notices before the processing begins.

17. Changes to this Policy

We may update this Policy to reflect a product, provider, data, security, legal, or operational change. We will post the revised Policy with a new effective date and provide additional notice for a material change. We will obtain consent before a materially new use when required.

We retain the version and acceptance or notice evidence needed to show which Policy applied. A change does not silently authorize unrelated use of previously collected Restricted data.

18. Contact us

Anseris Wealth, Inc.

• Attention: Chief Compliance Officer / Privacy

• Mailing address: 5245 E Joppa Rd, Perry Hall, MD, 21128

• Privacy requests and questions: support@anseriswealth.com

• Privacy appeals: support@anseriswealth.com

• Security reports: support@anseriswealth.com