Effective Date: February 24, 2026
Last Updated: February 24, 2026

Hutsy Financial Corp. (“Hutsy,” “we,” “us,” or “our”) values your privacy. This Privacy Policy explains how we collect, use, process, disclose, and safeguard your information when you use the Hutsy mobile application, website, and related services (collectively, the “Services”).

By creating an account or using the Services, you acknowledge and consent to the practices described in this Privacy Policy.

1. Information We Collect

A. Information You Provide Directly

• Name
• Email address
• Phone number (if provided)
• Account credentials (encrypted authentication data)
• Customer support messages
• Information you type into chat

B. Financial & Account Data (With Your Authorization)

When you connect financial accounts through third-party providers (e.g., Plaid, Array), we may receive:

• Account balances
• Transaction history
• Credit card balances and limits
• Credit profile metrics
• Loan-related data (if applicable)

We do not receive or store your banking login credentials. Account connections are handled securely by our third-party aggregation partners.

C. Automatically Collected Data

• Device information (model, OS version)
• IP address
• App usage analytics
• Session duration
• Feature interaction data
• Push notification interaction data

2. How We Use Your Information

• Provide AI-powered financial insights
• Analyze transaction patterns and balances
• Generate alerts and recommendations
• Improve financial monitoring features
• Facilitate access to loan marketplace partners
• Provide customer support
• Prevent fraud and secure accounts
• Comply with legal obligations

We do not sell your personal financial information.

3. AI & Automated Processing

Hutsy uses artificial intelligence and machine learning systems to generate financial insights.

When you provide consent within the app, certain financial and interaction data may be processed by third-party AI service providers acting as data processors on our behalf.

Depending on the feature used, the data processed may include:

• Transaction summaries
• Account balance snapshots
• Credit utilization metrics
• User-provided chat messages

Where feasible, we may minimize, tokenize, summarize, or mask sensitive identifiers before sending data for AI processing. However, the specific data processed depends on the functionality being used.

AI-generated outputs are automated, probabilistic, and may contain inaccuracies. They are informational and not financial advice.

4. Legal Basis for Processing

We process your information based on:

• Your consent (e.g., AI processing, account connections)
• Performance of our contract with you
• Legitimate business interests
• Compliance with legal obligations

5. Sharing of Information

We may share information with:

• Financial data providers (e.g., Plaid, Array)
• AI service providers (acting as processors)
• Cloud hosting providers
• Analytics providers
• Payment processors (if subscriptions apply)
• Lending partners (only if you actively pursue loan options)
• Legal authorities when required by law

We require service providers to protect your information and use it only for authorized purposes.

6. Data Security

We use commercially reasonable safeguards including:

• Encryption in transit (TLS/SSL)
• Encrypted cloud storage
• Access controls and role-based permissions
• Security monitoring

No system is completely secure, and we cannot guarantee absolute security.

7. Data Retention

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

• Provide Services
• Comply with legal requirements
• Resolve disputes
• Enforce agreements

Upon verified account deletion request, we will delete or anonymize your data within a commercially reasonable timeframe, except where retention is legally required.

8. Your Privacy Rights

Depending on your jurisdiction, you may have rights to:

• Access your data
• Correct inaccurate data
• Request deletion
• Withdraw consent
• Object to certain processing
• Request data portability

To exercise your rights, contact: contact@hutsy.com

9. International Data Transfers

Your information may be processed in countries other than your country of residence. We take appropriate safeguards to protect data transferred internationally.

10. Push Notifications & Communications

We may send service-related notifications and alerts. You may manage push notifications in your device settings.

11. Children’s Privacy

The Services are not intended for individuals under 18. We do not knowingly collect data from minors.

12. Business Transfers

If Hutsy is involved in a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of that transaction.

13. Third-Party Links

We are not responsible for the privacy practices of third-party websites or services.

14. Changes to This Policy

We may update this Privacy Policy periodically. Continued use of the Services after updates constitutes acceptance.

15. Contact Us

Hutsy Financial Corp.
Email: contact@hutsy.com
Website: www.hutsy.com