Privacy Policy

1. About This Policy

This Privacy Policy describes how Fulfillment and Logistics Solutions LLC, doing business as WealthCircle ("we," "our," or "us"), incorporated in Florida, collects, uses, and protects your personal and financial information when you use our service at wealthcircle.polsia.app.

By using WealthCircle, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use our service.

2. Information We Collect

2.1 Account Information

When you create a WealthCircle account, we collect:

• Email address (used for magic link authentication and notifications)
• Name (optional, if you choose to provide it)
• Profile information (username, avatar, bio for community features)
• Account preferences and settings

2.2 Financial Data via Plaid

When you connect your bank accounts through Plaid, we collect:

• Account balances (checking, savings, credit cards, investment accounts)
• Transaction history (merchant names, amounts, dates, categories)
• Account metadata (financial institution names, account types, last four digits of account numbers)

Important: Your bank login credentials (username and password) are sent directly to Plaid using 256-bit encryption. WealthCircle never sees, stores, or has access to your bank passwords. Plaid is a SOC 2 Type II certified service trusted by thousands of financial apps.

2.3 Crypto Portfolio Data

If you manually enter cryptocurrency holdings, we collect:

• Crypto asset types (Bitcoin, Ethereum, etc.)
• Quantity of holdings
• Purchase prices and dates (optional)

This data is stored securely and used only to calculate your total net worth and provide portfolio insights.

2.4 User-Generated Content

When you use community features, we collect:

• Financial goals (savings targets, debt payoff plans)
• Community tips (money-saving advice you share with others)
• Investment tips (educational content you post in the community)
• Comments and interactions (likes, replies, shares)

2.5 Usage Data

We automatically collect:

• Device information (browser type, operating system, device model)
• IP address and general location (city/state level, not precise GPS)
• Pages visited and features used
• Time spent on the platform
• Referral source (how you found WealthCircle)

3. How We Use Your Information

We use your data to:

• Calculate your financial health score: Analyze spending patterns, debt-to-income ratio, and savings rate
• Provide spending analysis: Categorize transactions and identify trends
• Track goal progress: Monitor your progress toward savings goals and debt payoff
• Enable community features: Display anonymized profiles and user-generated tips (we never share your real name or account balances publicly)
• Personalize recommendations: Suggest perks, savings strategies, and relevant content based on your spending
• Send notifications: Alert you about goal milestones, new perks, or account activity (you can opt out anytime)
• Improve the platform: Analyze usage patterns to build better features and fix bugs
• Prevent fraud and abuse: Detect suspicious activity and protect user accounts

4. Data Security

4.1 Bank-Level Encryption

All financial data is protected with:

• 256-bit AES encryption at rest (the same standard used by banks)
• TLS/SSL encryption in transit (HTTPS for all connections)
• Secure data centers with physical and network security controls

4.2 Plaid Security

Plaid handles your bank credentials directly. When you authenticate with your bank:

• Your credentials are encrypted with 256-bit encryption
• Data is transmitted directly to your bank—WealthCircle never sees it
• Plaid is SOC 2 Type II certified and trusted by major financial institutions

4.3 Read-Only Access

WealthCircle has read-only access to your financial data. We cannot:

• Transfer money from your accounts
• Make purchases or payments
• Change your bank account settings or beneficiaries
• Access your account without your explicit permission

4.4 Access Controls

Your data is protected by:

• Role-based access controls (only authorized personnel can access production systems)
• Audit logging (all access to sensitive data is logged and monitored)
• Multi-factor authentication (required for all team members)

5. Data Sharing

5.1 We Do NOT Sell Your Data

WealthCircle will never sell your financial data to advertisers, data brokers, or third parties. Your financial information is yours alone.

5.2 Service Providers

We share data with trusted third-party service providers who help us operate the platform:

• Plaid: Secure bank connections and transaction data
• Cloud hosting providers: Secure data storage and infrastructure (AWS, Google Cloud, or similar)
• Email service providers: Send account notifications and magic link emails
• Analytics services: Anonymized usage data for platform improvements (Google Analytics or similar)

All service providers are bound by strict data protection agreements and are prohibited from using your data for their own purposes.

5.3 Legal Requirements

We may disclose your information if required by law, such as:

• In response to a valid subpoena or court order
• To comply with legal obligations (tax reporting, anti-money laundering laws)
• To protect our rights, property, or safety
• To prevent fraud or illegal activity

5.4 Business Transfers

If WealthCircle is acquired or merged with another company, your data may be transferred to the new owner. We will notify you before your data is transferred and becomes subject to a different privacy policy.

6. Your Rights

You have the right to:

6.1 Access Your Data

• Request a copy of all personal data we have about you
• View your connected accounts, transaction history, and profile data in your dashboard

6.2 Update or Correct Your Data

• Edit your profile information in account settings
• Update your email address or preferences

6.3 Delete Your Data

• Request full account deletion by contacting Support@wealthcircle.com
• All financial data will be permanently deleted within 30 days
• Some data may be retained for legal compliance (e.g., tax records, fraud prevention logs)

6.4 Disconnect Bank Accounts

• Remove bank connections at any time from your dashboard
• Disconnecting will immediately revoke WealthCircle's access to your financial data

6.5 Opt Out of Communications

• Unsubscribe from marketing emails via the link at the bottom of any email
• Disable push notifications in your account settings
• Note: We may still send critical account notifications (e.g., security alerts)

6.6 California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know: Request details about the categories and specific pieces of personal information we collect
• Right to delete: Request deletion of your personal information (with certain exceptions)
• Right to opt out: Opt out of the "sale" of personal information (note: we do not sell your data)
• Right to non-discrimination: Exercise your privacy rights without discriminatory treatment

To exercise these rights, contact Support@wealthcircle.com with "CCPA Request" in the subject line.

6.7 International Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

• Right to access: Request a copy of your personal data
• Right to rectification: Correct inaccurate data
• Right to erasure: Request deletion of your data ("right to be forgotten")
• Right to restrict processing: Limit how we use your data
• Right to data portability: Receive your data in a machine-readable format
• Right to object: Object to certain types of data processing
• Right to withdraw consent: Withdraw consent at any time

To exercise these rights, contact Support@wealthcircle.com.

7. Data Retention

We retain your data for as long as your account is active or as needed to provide services. Specifically:

• Financial data: Retained while your account is active; deleted within 30 days of account deletion
• Transaction history: Retained for up to 2 years (or as required by law)
• User-generated content: Retained while your account is active; you may delete individual posts anytime
• Anonymized usage data: May be retained indefinitely for analytics and research
• Legal records: Retained as required by law (e.g., tax records for 7 years)

8. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Authentication: Keep you logged in securely
• Preferences: Remember your settings and dashboard layout
• Analytics: Understand how users interact with the platform (via Google Analytics or similar)
• Performance: Monitor site speed and fix bugs

Cookie Types

• Essential cookies: Required for the service to function (authentication, security)
• Analytics cookies: Help us improve the platform (Google Analytics)
• Preference cookies: Remember your settings

You can disable cookies in your browser settings, but some features may not work properly. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block all cookies (may break functionality)

9. Children's Privacy

WealthCircle is not intended for users under 18 years of age. We do not knowingly collect personal information from children.

If you believe we have collected data from a minor, please contact us immediately at Support@wealthcircle.com, and we will delete it promptly.

10. International Data Transfers

WealthCircle is based in the United States. If you access our service from outside the U.S., your data may be transferred to and stored in the U.S., where data protection laws may differ from those in your country.

By using WealthCircle, you consent to the transfer of your data to the U.S. and our processing of your data in accordance with this Privacy Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via:

• Email notification
• In-app notification
• A notice on our website

Continued use of WealthCircle after changes means you accept the updated Privacy Policy. You can always review the latest version at wealthcircle.polsia.app/privacy.

12. Governing Law

This Privacy Policy is governed by the laws of the State of Florida, United States, without regard to conflict of law principles.

13. Contact Us

Questions, concerns, or requests about this Privacy Policy? Contact us:

• Email: Support@wealthcircle.com
• Legal Entity: Fulfillment and Logistics Solutions LLC (d/b/a WealthCircle)
• State of Incorporation: Florida
• Website: wealthcircle.polsia.app

For CCPA or GDPR requests, please include the relevant identifier ("CCPA Request" or "GDPR Request") in your email subject line.