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Privacy Policy

FinClarity LLC · Effective Date: July 7, 2026

Draft for attorney review. This document has not been finalized for publication. Contact privacy@finclarity.io with questions.

This Privacy Policy explains how FinClarity LLC (“FinClarity,” “we,” “us”) collects, uses, shares, and protects information when lenders and other business customers (“Customers”) use our platform, and when merchants and their representatives (“Merchants”) complete verifications requested by a Customer. It also describes your choices and rights. By using our websites, applications, or verification pages, you acknowledge this Policy.

1. Information We Collect

Account and business information: name, work email, password, company legal name, DBA, website, business address, support contact information, and billing details (payment card data is processed by our payment processor; we do not store full card numbers).

Verification data: business name and EIN; bank account data retrieved through the Customer's own Plaid connection at the Customer's direction (account and routing details, balances, transactions, account-holder identity information on file with the bank); data captured during browser-based and screen-share verification sessions, including session video recordings, page URLs, and AI-generated verification results; and verification outcomes, timestamps, and funding-confirmation (FundLock) events.

Communications and usage data: emails and support communications; device, browser, log, and usage information; and data collected through cookies, pixels, SDKs, and similar technologies on our sites and applications.

2. How We Use Information

To provide the Services: run verifications, generate reports and summaries, deliver meeting and verification links, process payments, and provide support.

Fraud prevention and network integrity: matching verification events across the FinClarity network to generate duplicate-verification and funding (FundLock) alerts for FinClarity Customers, and detecting misuse of the platform.

Analytics, product development, and intelligence: analyzing platform activity to operate dashboards and internal analytics; developing, training, and improving our products, detection systems, and models; and creating de-identified and aggregated data sets, benchmarks, indices, scores, and market intelligence.

Marketing and advertising: sending marketing communications about our products; advertising and measuring our services on major advertising platforms (such as Google, Meta, LinkedIn, TikTok, and X), including through cookies and pixels and by matching hashed business contact information to create custom, matched, or lookalike audiences.

Legal and safety: complying with law, enforcing agreements, and protecting FinClarity, our Customers, Merchants, and the public.

3. How We Share Information

With the requesting Customer: verification results, bank data, reports, and recordings for verifications that a Customer initiates for a Merchant.

Across the FinClarity network: limited verification-event signals (for example, that a business identified by its EIN was verified or accepted funding, with timing) are visible to other FinClarity Customers as fraud-prevention alerts. These signals do not disclose the originating Customer's identity, pricing, or terms.

Service providers: vendors that host, process, or support the Services, including cloud hosting and storage, payment processing, communications, and AI processing providers, under contracts limiting their use of the data. Bank connectivity runs through each Customer's own Plaid account — FinClarity does not resell or provision Plaid access.

Advertising partners: subject to Section 6, we may share identifiers, hashed contact information, and activity data with advertising and analytics platforms for advertising and measurement.

Data products: we may license, sell, or otherwise commercialize de-identified and/or aggregated data and insights that do not identify you or any natural person.

Corporate and legal: in connection with a merger, financing, acquisition, or sale of assets; and where required by law, subpoena, or to protect rights and safety.

4. Bank Connectivity (Bring Your Own Plaid)

FinClarity connects to banks through each Customer's own Plaid account (Bring Your Own Plaid). When a Merchant connects a bank account, information is transmitted by Plaid in accordance with the Plaid End User Privacy Policy, which is presented during the connection flow and available at plaid.com/legal. Bank credentials are entered with the bank or Plaid directly and are never visible to FinClarity or to the requesting Customer. Data obtained through a Customer's Plaid connection is used and shared only as permitted by these terms, our agreements, and applicable law; it is not sold and is not used for third-party advertising.

5. Cookies and Similar Technologies

We and our partners use cookies, pixels, and similar technologies to operate the Services, remember preferences, analyze usage, and support advertising and measurement. You can control cookies through your browser settings and, where available, our cookie preferences tool. Depending on your settings, some features may not function.

6. Your Privacy Rights; Selling and Sharing

Some of the sharing described above — in particular, sharing identifiers and hashed contact information with advertising platforms, and licensing certain data — may be considered a "sale" or "sharing" of personal information under certain U.S. state privacy laws. Where those laws apply, you may opt out of the sale or sharing of your personal information and of targeted advertising by emailing privacy@finclarity.io or using the "Do Not Sell or Share My Personal Information" link on our website. Depending on your state, you may also have rights to access, correct, delete, or obtain a copy of your personal information, and to not be discriminated against for exercising rights. We honor authorized-agent requests and applicable opt-out preference signals where required. We do not knowingly sell or share the personal information of anyone under 16, and de-identified and aggregated data is not treated as personal information.

7. Financial Privacy

Where FinClarity processes nonpublic personal information of individuals in connection with financial products, we handle it in accordance with applicable financial privacy laws, including the Gramm-Leach-Bliley Act where applicable, and we use bank data obtained through verifications to provide the Services requested, for fraud prevention and network integrity, and as otherwise permitted by law and our contracts. Bank data associated with identifiable individuals is not used for third-party advertising and is not sold; data used in our commercial intelligence products is de-identified and/or aggregated first.

8. Retention and Security

Session recordings are retained for thirty (30) days after a verification is completed and then permanently deleted. Verification metadata, results, and network event records are retained for the life of the network to support fraud prevention, dispute resolution, and legal compliance. Account and billing records are retained as required by law. We use administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption in transit and at rest; no system is perfectly secure.

9. Children; International Users

The Services are for businesses and are not directed to children under 16; we do not knowingly collect their information. The Services are operated from the United States; if you access them from elsewhere, your information will be processed in the U.S.

10. Changes; Contact

We may update this Policy from time to time; material changes will be posted with a new effective date and, where appropriate, additional notice. Questions and privacy requests: privacy@finclarity.io, or FinClarity LLC, Attn: Privacy, [business address].