CARPE MONEY· Festina Lente ·Privacy Policy
This Policy describes, in general terms and where reasonably practicable, how Carpe Money may collect, use, retain, and disclose certain information in connection with the Services. It is drafted to be read as a whole.
1Overview and scope
This Privacy Policy (this "Policy") describes, in general terms and where reasonably practicable, the manner in which Carpe Solutions, LLC ("Carpe Money," "we," "us," or "our") may, from time to time and in its sole discretion, collect, use, retain, disclose, and otherwise process certain information in connection with your access to or use of the Carpe Money mobile applications, websites, and any related features, content, or services (collectively, the "Services"). This Policy is intended to be read together with our Terms of Use and any supplemental notices, disclosures, or in-product statements that we may make available from time to time.
This Policy applies solely to information processed in connection with the Services and does not govern the practices of any third party that we do not own or control, including but not limited to your financial institutions, data-aggregation providers, application marketplaces, or any website or service to which the Services may link. Capitalized terms used but not otherwise defined herein shall have the meanings we may reasonably ascribe to them in the context in which they appear.
Your continued access to or use of the Services following the posting of this Policy constitutes your acknowledgement of, and where applicable your agreement to, the practices generally described herein, as such practices may be modified from time to time.
2Definitions
For purposes of this Policy, and except where the context otherwise requires: "Linked-Bank Data" means account balances, transactions, and related information obtained through a read-only connection to a financial institution by means of a third-party aggregation provider; "Manual Account Data" means account information that you elect to enter yourself; "Account Information" means the credentials and profile details associated with your Carpe Money account; and "Device" means the personal computing device on or through which you access the Services.
The foregoing definitions are provided for convenience and are not intended to be exhaustive. We reserve the right to interpret and, where we deem it appropriate, to supplement these definitions in a manner consistent with the general purpose of this Policy.
3Information we may collect
Depending on how you interact with the Services, and subject to the limitations described elsewhere in this Policy, we may collect or otherwise process certain categories of information, which may include, without limitation:
- Account Information that you provide when you register, such as an email address and authentication factors, which we may retain for so long as we consider reasonably necessary to operate the Services.
- Configuration and preferences, including alert rules, category assignments, recurring-charge settings, and similar parameters that you establish within the Services.
- Technical and diagnostic information that may be generated automatically, such as approximate device type, application version, and aggregated or de-identified usage signals, to the extent we determine such information is reasonably useful for the operation, maintenance, or improvement of the Services.
- Communications that you send to us, including support inquiries and any information you elect to include therein.
We do not knowingly collect categories of information beyond those we consider reasonably necessary or appropriate for the purposes described in this Policy, although the specific information processed may vary depending on your configuration and use of the Services.
4Information we do not retain
It is a foundational and deliberate characteristic of the Services that Linked-Bank Data is fetched live and is not stored on our servers. Where the Services display balances or transactions obtained from a linked financial institution, such information is, as a general matter, retrieved at the time of your request, presented to you, and retained only on your Device. We do not require, request, receive, or store the login credentials for your financial institutions, which are handled exclusively by the applicable financial institution and the aggregation provider described in Section 5.
Nothing in this Section shall be construed as a representation or warranty that any particular item of information will, in every instance and under all circumstances, be handled in precisely the manner described, it being understood that transient processing, caching for the limited duration reasonably necessary to render a response, and comparable technical operations incidental to the ordinary functioning of the Services may occur. The commitment described in this Section is directed to Linked-Bank Data and should not be read to extend to Manual Account Data, which is addressed separately in Section 6.
5Bank connections and Plaid
Connections to your financial institutions are facilitated by Plaid Inc. or a comparable aggregation provider that we may engage from time to time (the "Aggregation Provider"). When you elect to link an account, you will ordinarily be directed to an interface operated by the Aggregation Provider or your financial institution, at which you may authenticate directly. Your online banking credentials are provided to your financial institution and are never shared with us. Access obtained on our behalf is read-only, and the Services do not provide any capability to move, transfer, or disburse funds.
Your use of the Aggregation Provider's services is subject to the Aggregation Provider's own terms and privacy practices, over which we exercise no control and for which we assume no responsibility. We encourage you to review such terms and practices, as they may be amended from time to time and may differ materially from those described herein.
6Manually entered accounts
As a deliberate and limited accommodation to the convenience of synchronization across your Devices, Manual Account Data that you voluntarily enter may be stored by us in encrypted form. We employ measures that we consider commercially reasonable in an effort to protect such information at rest, and we intend, over time and without any binding commitment as to timing or outcome, to move toward an operator-blind arrangement. Nothing in this Section shall be construed as a guarantee that any such objective will be achieved by any particular date or at all.
You acknowledge that Manual Account Data is provided at your election and that you are solely responsible for the accuracy, legality, and appropriateness of any information you choose to enter.
7How we may use information
We may use the information described in this Policy for purposes that we consider reasonably related to the operation and improvement of the Services, which may include, among other things: providing, maintaining, and securing the Services; evaluating and enforcing alert rules and comparable features you configure; communicating with you regarding your account, transactions you request, or material changes to the Services; detecting, investigating, and endeavoring to prevent activity that we reasonably believe to be fraudulent, unauthorized, or otherwise contrary to our terms or applicable law; and complying with legal obligations to which we are or may become subject.
We do not sell your personal information, and we do not share your personal information with third parties for their independent marketing purposes. This commitment is stated plainly and is intended to be relied upon.
8Disclosure to third parties
We may disclose information to the limited extent that we determine, in our reasonable judgment, to be necessary or appropriate: (a) to service providers, processors, and contractors who perform functions on our behalf and who are subject to obligations of confidentiality; (b) as required or permitted by applicable law, regulation, legal process, or governmental request; (c) to enforce our terms or to protect the rights, property, or safety of Carpe Money, our users, or others; and (d) in connection with, or during negotiations of, any merger, financing, acquisition, reorganization, or sale or transfer of some or all of our assets, in which event information may be among the assets transferred.
Except as generally described in this Policy or as otherwise directed or authorized by you, we do not intend to disclose your personal information to unaffiliated third parties for purposes unrelated to the provision of the Services.
9Cookies and similar technologies
We and, where applicable, our service providers may employ cookies, local storage, and comparable technologies to the extent we consider reasonably necessary to operate, secure, and maintain the continuity of the Services. We do not use such technologies to build advertising profiles or to facilitate third-party behavioral advertising. Your device or browser may offer controls for managing certain of these technologies; disabling them may, however, impair the functioning of the Services.
10Retention
We retain information for such period as we consider reasonably necessary to fulfill the purposes described in this Policy, unless a longer or shorter retention period is required or permitted by applicable law. Linked-Bank Data, as described in Section 4, is generally not retained by us. Account Information and Manual Account Data may be retained for the duration of your account and for a reasonable period thereafter, after which we may delete, de-identify, or aggregate such information in a manner and on a timeline that we determine to be appropriate.
11Security
We maintain administrative, technical, and organizational safeguards that we consider commercially reasonable and appropriate to the nature of the information processed, including read-only bank access, encryption of Manual Account Data at rest, and support for passkeys and two-step authentication. Notwithstanding the foregoing, no method of transmission or storage can be guaranteed to be absolutely secure, and we do not and cannot warrant that the Services, or any information processed in connection therewith, will at all times be free from unauthorized access, loss, or alteration.
12Your choices and rights
Depending on your jurisdiction, you may be entitled to exercise certain rights with respect to information relating to you, which may include rights of access, correction, deletion, or portability, subject to such conditions, exceptions, and verification requirements as applicable law permits or requires. You may also, at any time, export your data in a common format, disconnect a linked institution, or delete your account, in each case through the controls made available within the Services or by contacting us as described in Section 16. We will endeavor to respond to legitimate requests within a reasonable period and to the extent we are able to do so consistent with applicable law.
13Children
The Services are intended for use by adults and are not directed to individuals under the age of majority in their jurisdiction of residence. We do not knowingly collect information from such individuals. If we become aware that we have collected information from a person who does not meet the applicable age requirement, we may take such steps as we consider appropriate to address the matter.
14International processing
The Services may be operated from, and information may be processed in, jurisdictions other than the one in which you reside, and such jurisdictions may have data-protection laws that differ from those of your jurisdiction. By using the Services, you acknowledge that information may be transferred to and processed in such jurisdictions as we consider reasonably necessary or appropriate for the operation of the Services, subject to such safeguards as applicable law may require.
15Changes to this Policy
We may amend, revise, or otherwise modify this Policy from time to time, in our sole discretion, to reflect changes in our practices, the Services, or applicable law. When we do so, we will revise the "Last updated" date above and, where we consider it appropriate, provide additional notice by means we deem reasonable. Any modified Policy will become effective upon posting or on such other date as we may specify, and your continued use of the Services thereafter will constitute your acknowledgement of the modified Policy.
16How to contact us
Questions regarding this Policy, or requests relating to information about you, may be directed to us at support@carpemoney.app. We will endeavor to review and respond to such correspondence within a reasonable period, consistent with the general practices described in this Policy.