Effective Date: February 24, 2026
Last Updated: March 19, 2026

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

By creating an account, connecting accounts, subscribing, or otherwise 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 authentication and login data
• Customer support messages
• Information you type into chat or forms
• Information you provide during onboarding or identity-related flows

B. Financial & Account Data (With Your Authorization)

When you connect financial accounts through third-party providers such as Plaid or Array, we may receive:

• Account balances
• Transaction history
• Recurring bills and payment patterns
• Credit card balances and limits
• Credit profile metrics and report data
• Loan-related or offer-related data where available

We do not receive or store your online banking login credentials. Account connections are handled by third-party providers.

C. Automatically Collected Data

• Device information, including model and OS version
• IP address and approximate location derived from IP
• App usage and analytics events
• Session duration and feature interaction data
• Push notification delivery and interaction data
• Crash logs, diagnostic data, and performance data

D. Subscription & Billing Information

If you purchase paid features, subscriptions, or in-app products, billing is processed by Apple App Store or Google Play. We may receive limited subscription-related information, such as subscription status, entitlement status, product identifier, renewal state, and transaction metadata needed to operate the Services.

We do not receive or store your full payment card number from Apple App Store or Google Play billing flows.

2. How We Use Your Information

• Provide and operate the Services
• Generate AI-powered financial insights and summaries
• Analyze transaction patterns, balances, recurring payments, and credit-related information
• Generate alerts, reminders, and recommendations
• Enable bank and credit account connection features
• Process subscription entitlements and access to paid features
• Provide customer support
• Prevent fraud, abuse, and unauthorized access
• Improve features, performance, reliability, and security
• Comply with legal obligations and enforce our agreements

We do not sell your personal financial information.

3. AI & Automated Processing

Hutsy uses artificial intelligence and automated systems to generate financial insights, summaries, and support responses.

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

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

• Transaction summaries
• Account balance snapshots
• Recurring payment summaries
• Credit utilization or credit profile metrics
• User-provided prompts or chat messages

Where feasible, we may minimize, mask, summarize, tokenize, or otherwise reduce identifying information before sending information for AI processing. However, the exact data processed may depend on the feature used, your connected accounts, and the data available.

AI-generated outputs are automated, probabilistic, and may contain inaccuracies. They are provided for informational purposes only and are not financial, legal, or tax advice.

4. Legal Bases for Processing

Depending on your jurisdiction, we process your information based on one or more of the following:

• Your consent
• Performance of our contract with you
• Our legitimate business interests
• Compliance with legal obligations
• Protection against fraud, abuse, and security risks

5. Sharing of Information

We may share information with:

• Financial data providers and account connection providers, such as Plaid and Array
• AI service providers acting as processors or service providers
• Cloud hosting and infrastructure providers
• Analytics, crash reporting, and performance monitoring providers
• Payment, subscription, entitlement, or billing infrastructure providers
• Loan, credit, or financial partners only where you actively request or pursue those features
• Professional advisors, auditors, and legal authorities where required

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

6. Subscription Billing, Apple App Store & Google Play

If you subscribe through Apple App Store or Google Play, your purchase, renewal, cancellation, and refund are handled by the applicable platform and subject to that platform’s terms and policies.

We may use subscription-related status information to activate, maintain, restrict, or restore access to paid features.

Refund requests for in-app subscriptions are generally handled by the platform through which the purchase was made, unless otherwise required by applicable law.

7. Data Security

We use commercially reasonable safeguards, which may include:

• Encryption in transit using TLS/SSL
• Encrypted storage where appropriate
• Access controls and role-based permissions
• Security monitoring and logging
• Vendor and infrastructure protections

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

8. Data Retention

We retain information for as long as reasonably necessary to:

• Provide and improve the Services
• Maintain account functionality and subscription access
• Comply with legal, tax, audit, and regulatory requirements
• Resolve disputes
• Enforce our agreements

Upon a verified deletion request, we will delete, de-identify, or anonymize information within a commercially reasonable timeframe, unless retention is required or permitted by law.

9. Your Privacy Rights

Depending on your jurisdiction, you may have rights to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion
• Withdraw consent where processing is based on consent
• Object to or restrict certain processing
• Request portability of certain data

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

10. International Data Transfers

Your information may be processed in countries other than your country of residence. Where required, we take reasonable steps and appropriate safeguards to protect transferred information.

11. Push Notifications & Communications

We may send service-related notifications, reminders, security alerts, billing notices, and product communications. You may manage push notifications through your device settings, though certain service or security communications may still be sent where necessary.

12. Children’s Privacy

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

13. Business Transfers

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

14. Third-Party Links & Services

The Services may contain links to or integrations with third-party services. We are not responsible for the privacy practices of third parties, and their services are governed by their own policies and terms.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may notify you through the app, by email, or by updating the date above. Continued use of the Services after an updated Privacy Policy becomes effective means you acknowledge the updated Policy.

16. Contact Us

Hutsy Financial Corp.
Email: contact@hutsy.com
Website: https://hutsy.com/privacy-policy