Privacy Policy

Effective date: July 27, 2026
Last updated: July 27, 2026

This Privacy Policy describes how Matzu Finance ("Matzu," "we," "our," or "us") collects, uses, discloses, and protects information when you use the Matzu Finance mobile application and related services (the "Service"). Matzu Finance is a product of Matzu LLC (Hawaii, formation in progress), operated on behalf of Kavon Wright. Our privacy contact is privacy@matzu.finance.

1. Data controller

Matzu LLC (Hawaii, formation in progress)
Principal: Kavon Wright
Privacy contact: privacy@matzu.finance
General contact: hello@matzu.finance

2. Information we collect

We collect the minimum information needed to operate the Service.

2.1 Account information

When you create an account, we collect:

• Your email address (via Firebase Authentication or Sign in with Apple)
• A user identifier we assign to you (Firebase Auth UID)
• Your chosen display name, if you provide one
• Your device's time zone
• Session and refresh tokens issued by Firebase Authentication

2.2 Financial information (via Plaid)

If you choose to connect a financial account, we use Plaid Inc. to retrieve transaction, account, and balance data from your bank or card issuer. Plaid acts as a data provider on our behalf. When you link an account through Plaid, we receive:

• Transaction records (merchant, amount, date, category, pending status)
• Account and institution names, and account balances
• Account and routing information only where a specific product requires it. Matzu Finance does not initiate payments and does not use routing numbers to move money.

Matzu never sees your bank username or password. Those credentials go directly to Plaid and are never stored on our servers or on your device by Matzu. Plaid's own privacy practices are described in the Plaid End User Privacy Policy.

You can revoke Plaid access at any time from inside the Matzu app or by contacting us. As required by CFPB §1033 and Plaid's terms, we will ask you to reauthorize financial data access at least every twelve months.

2.3 Manual and shortcut-entered transactions

You can enter transactions manually or via an Apple Shortcut. When you do, we collect the merchant name, amount, date, and any category or note you provide.

2.4 Coach conversations

Matzu includes an AI coach. When you send the coach a message, we store the message you sent and Matzu's reply. To generate replies, we send your message and a scoped summary of your recent financial activity to OpenAI, our AI model provider, through a server-side proxy. Your personal financial data does not go to any other AI provider.

Matzu limits what the model can see to the smallest slice needed to answer your question, and never sends another user's data with your request. OpenAI does not use your data to train its models (per the OpenAI API terms in effect when we send the request) and retains it for up to 30 days for abuse monitoring and safety enforcement.

2.5 Device and diagnostic information

We collect crash reports and basic performance data (via Firebase Crashlytics and Firebase Performance Monitoring) to keep the app working. These may include a device model, an operating system version, an app version, and a stack trace when a crash occurs. They do not include your transactions or your coach messages.

2.6 Push notifications

If you grant permission for push notifications, we store an FCM device token linked to your account so we can deliver notifications you have opted into. You can revoke push permission at any time in iOS Settings.

3. Legal bases for processing

Where the GDPR applies (see Section 8), our legal bases are:

• Performance of a contract — for account creation, authentication, transaction sync, coach replies, and other core Service functions.
• Legitimate interest — for security monitoring, fraud prevention, and diagnostics, balanced against your interests.
• Consent — for push notifications, optional financial account connections, and any future marketing communications.
• Legal obligation — for retention and disclosure required by law.

4. What we do not collect and do not do

• We do not sell your personal information.
• We do not share your data with advertisers or ad networks.
• We do not use your data to train third-party AI models. OpenAI does not train on API data sent by Matzu.
• We do not use tracking pixels or cross-site advertising trackers.
• We do not respond to browser Do Not Track signals and do not engage in cross-site tracking.
• We do not initiate payments, transfers, or loans on your behalf.
• We do not report your data to credit bureaus.

5. How we use your information

We use your information only to:

• Operate the Service and show you your own financial picture
• Generate coach replies about your own finances
• Detect and prevent fraud, abuse, and security incidents
• Meet legal, tax, and audit obligations
• Communicate with you about the Service (transactional notifications, account emails, security notices)

6. Third-party subprocessors

We share your information only with the service providers that make Matzu work. Each is contractually limited to processing your data on our behalf.

We may also share information:

• With household members you invite. If you invite another person to share a household, and they accept, the two of you can share specific data you choose to share, using per-user sharing preferences. Sharing is opt-in and revocable. Matzu does not merge your financial data with another user's data without your explicit invitation and their explicit acceptance.
• When required by law. We may disclose information in response to a valid legal request, or to protect our rights, our users, or the public.
• In a business transfer. If Matzu is acquired or merged, information may transfer to the successor entity subject to this policy.

We do not share your data for any other purpose.

7. How long we keep your information

• Active account data — retained while your account is active.
• Transaction data — retained while your account is active; deleted when you delete the transaction, or when you delete your account (subject to the grace window in Section 9).
• Coach messages — retained while your account is active; deleted when you delete your account.
• Authentication logs — retained for up to 12 months for security monitoring.
• Crash and performance data — retained for up to 90 days.
• AI provider retention — OpenAI retains API data for up to 30 days for abuse monitoring, then deletes it.
• Backups — When you delete your account, we remove your data from active systems immediately and prevent restoration from backup. Backups age out naturally per our backup rotation. This approach is aligned with current GDPR and CCPA enforcement guidance.
• Legal records — we may keep records we are legally required to retain, for as long as the law requires (for example, tax records for at least 3 years in Hawaii, 7 recommended).

8. Regional rights

8.1 California (CalOPPA, CCPA, CPRA)

Matzu Finance complies with the California Online Privacy Protection Act (CalOPPA). We disclose the categories of personal information we collect (Section 2), the categories of third parties with whom we share it (Section 6), our response to Do Not Track signals (Section 4), our policy change notification method (Section 11), and the effective date of this policy (top of page).

We do not currently meet the thresholds for CCPA/CPRA applicability, but as a matter of policy we honor California-resident requests to access, correct, or delete personal information, and we do not sell or share personal information as those terms are defined by CCPA/CPRA.

8.2 European Economic Area, United Kingdom, and other GDPR regions

If you are in a region with additional data protection rights, you have the right to access, correct, delete, restrict, or object to processing of your personal data, and the right to data portability. Matzu Finance is currently offered in the United States only; if you access the Service from outside the United States, you consent to processing of your data in the United States. If we later serve EU users at scale, we will implement Standard Contractual Clauses for US data transfers and designate an EU representative under Article 27.

8.3 Canada (PIPEDA)

If you are a resident of Canada, you have rights under PIPEDA including access, correction, and complaint to the Office of the Privacy Commissioner of Canada. Contact us at privacy@matzu.finance to exercise these rights.

9. Your rights and choices

You have the following rights over your data. To exercise any of them, use the in-app controls or contact us at privacy@matzu.finance.

• Access. You can see your data inside the app. On request, we will provide an export.
• Correction. You can edit transactions, categories, and profile fields in the app.
• Deletion. You can delete your account in the app. Deletion begins immediately, with a short grace window during which you can cancel. After the grace window, your account and its data are permanently removed from active systems, subject to any legal retention obligations. Refresh tokens are revoked before deletion begins.
• Withdrawal of financial connectivity. You can disconnect Plaid at any time in the app. This stops future transaction fetches; historical transactions remain in your account until you delete them.
• Reauthorization. As required by CFPB §1033 and Plaid's terms, we will ask you to reauthorize financial data access at least every twelve months.
• Push notifications. You can revoke push notification permission in iOS Settings at any time.
• Communications. You can opt out of non-transactional emails at any time.

We aim to respond to requests within 30 days. In no case will we take longer than 45 days (CCPA) or the applicable statutory maximum under your local law.

10. Security

We use industry-standard measures to protect your data:

• All data is encrypted in transit using TLS 1.2 or higher.
• Data at rest in Firestore is encrypted by Google Cloud using AES-256.
• Authentication credentials are hashed by Firebase Authentication using industry-standard algorithms; Matzu never sees your password.
• Plaid access tokens are stored only on our server, never in the iOS app on your device.
• Access to production systems is limited, logged, and requires multi-factor authentication.
• Firestore Security Rules enforce per-user data isolation.

No system is perfectly secure. If we discover a security incident that affects you, we will notify you as required by law, including within the timelines required by Hawaii HRS §487N, California Civil Code §1798.82 (as amended by SB-446), and any other applicable state or federal breach notification law.

11. Children

Matzu Finance is not directed to children under 13 (or 16 in the EEA/UK), and we do not knowingly collect data from children. If we become aware that we have collected data from a child, we will delete it. If you believe a child has provided data to us, contact us at privacy@matzu.finance.

12. Changes to this policy

We may update this policy. When we do, we will update the "Last updated" date at the top and, for material changes, notify you in the app or by email at least 14 days before the change takes effect.

13. Contact

For privacy questions, requests, or complaints:

Matzu Finance
Attn: Privacy
privacy@matzu.finance

We aim to respond within 30 days.