Privacy Policy

What this policy covers

This policy covers the Fearless Wealth client portal: the website where you sign in to see your financial plan, upload documents, and connect your bank accounts. It tells you what we collect in the portal, why, who we share it with, how we protect it, how long we keep it, and how to ask us to delete it.

Our privacy notice for clients, which you receive with our Form ADV, also applies to you. If the two differ, the one that protects you more applies.

What we collect

We collect only what we need to give you financial advice and to run the portal:

• Your name, email address and the details of your login.
• What you and your household tell us, or upload: for example income, accounts, goals, insurance, estate documents and statements.
• Identification numbers you give us, such as a Social Security number or account numbers. We store these encrypted and show only the last four digits.
• Bank account data that you choose to connect through Plaid (see the next section).
• Notes from our meetings with you.
• Technical data about your sign-in: the time, your IP address and your browser, to keep your account secure.

Bank data we receive through Plaid

You can connect a bank account to the portal. We use Plaid Inc. (“Plaid”) to make that connection. You choose the bank, and you sign in to it inside Plaid's own window. We never see or store your bank username or password.

Before the connection opens, we ask you to confirm it is you with a second sign-in step, and to agree to this policy. We record that agreement with the date and time.

Through Plaid, we receive:

• the name of your bank, and the name and type of each account you connect;
• the last four digits of each account number;
• account balances;
• transactions: the date, the description, the amount and Plaid's category.

We use this data to show your spending and cash flow, to keep your net worth current, and to give you advice. We update it about once a month, and when you or we ask for a refresh.

Plaid collects and uses your data under its own End User Privacy Policy, at https://plaid.com/legal/#end-user-privacy-policy.

You can disconnect a bank at any time in the portal, from Spending › Add transactions › Disconnect. We then stop receiving data from that bank at once, and we remove our access at Plaid. The data we already received stays in your records until it is deleted as the section “How long we keep it” describes.

How we use your information

We use your information only to:

• give you financial planning and investment advice, and keep your plan up to date;
• run the portal and keep it secure;
• bill you for our services;
• meet our legal and regulatory duties as an investment adviser.

We do not sell your information, and we do not use it for advertising.

Who we share it with

We share your information only with companies that help us run the portal and our firm, and only so that they can do that work for us. These include companies that host the portal and its database, store your documents, send our email, process payments and electronic signatures, connect your bank (Plaid), and read documents.

Some of these companies use automated tools, including artificial intelligence, to read the documents you upload and to suggest names and categories for transactions. When we send transactions for a suggestion, we do not send your household's name. A person on our staff reviews each suggestion before it changes your records.

We also share information when you ask us to, and when the law requires it, for example to a regulator.

How we protect it

We protect your information with these controls:

• All traffic between your browser and the portal is encrypted (HTTPS, TLS 1.2 or newer).
• Our database and document storage are encrypted at rest. Your bank connection keys and your identification numbers are encrypted a second time by the portal.
• Signing in can take two steps: your password, and a code we email to you (or your password, if you sign in with an email link). Connecting a bank always takes both steps.
• Our staff can see only what their role allows. Clients see only their own household.
• We keep our software up to date, and we scan it for known security problems.

How long we keep it, and how to ask us to delete it

We keep your information while you are our client. After you stop being our client, we keep the records that the law requires investment advisers to keep, for as long as the law requires (for most records, five years). Then we delete them.

You can ask us to delete your information, including the bank data we received through Plaid. Write to hello@fearlesswealth.com. We answer within 30 days. We delete what the law allows us to delete, and we tell you what we must keep and why.

We review how long we keep information, and this policy, at least once a year.

Your choices

• You do not have to connect a bank. You can upload statements or add transactions by hand instead.
• You can disconnect a bank at any time.
• You can ask us for a copy of your information, ask us to correct it, or ask us to delete it.

Changes to this policy

If we change this policy, we post the new version here with a new date. If a change affects the bank data we receive through Plaid, we ask you to agree again before you connect another bank.

Contact us

Questions about this policy, or about your information: write to hello@fearlesswealth.com.