Privacy Policy

1. Introduction

Comeup.ai ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our financial management service.

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the service.

2. Information We Collect

2.1 Information You Provide

We collect information that you provide directly to us, including:

• Account registration information (name, email address, password)
• Financial information (account balances, transactions, debts, obligations)
• Profile information and preferences
• Communications with us (support requests, feedback)

2.2 Information Collected Automatically

When you use our service, we automatically collect certain information, including:

• Device information (device type, operating system, browser type)
• Usage data (pages visited, features used, time spent)
• Log data (IP address, access times, error logs)
• Cookies and similar tracking technologies

2.3 Information from Third Parties

We may receive information about you from third-party services, including:

• Financial institutions through secure API connections
• Authentication providers (such as Clerk)
• Analytics and marketing service providers

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our service
• Process transactions and manage your account
• Calculate safe spend amounts and provide financial insights
• Generate AI-powered coaching messages and recommendations
• Send you service-related communications
• Respond to your inquiries and provide customer support
• Detect, prevent, and address technical issues and security threats
• Comply with legal obligations and enforce our terms
• Analyze usage patterns to improve user experience

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Cloud hosting and infrastructure providers
• Payment processors and financial data aggregators
• Analytics and monitoring services
• Email and communication services
• Customer support platforms

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

4.3 Business Transfers

If we are involved in a merger, acquisition, or asset sale, your information may be transferred. We will provide notice before your information is transferred and becomes subject to a different Privacy Policy.

4.4 With Your Consent

We may share your information with your explicit consent or at your direction.

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and updates
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

When you delete your account, we will delete or anonymize your personal information, except where we are required to retain it for legal, regulatory, or legitimate business purposes.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information, including:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Portability: Request transfer of your data to another service
• Objection: Object to processing of your personal information
• Restriction: Request restriction of processing
• Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at privacy@comeup.ai. We will respond to your request within a reasonable timeframe.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

For more information about our use of cookies, please see our Cookie Policy or manage your cookie preferences through the cookie consent banner.

9. Children's Privacy

Our service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child without verification of parental consent, we will take steps to delete that information.

10. International Data Transfers

Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction. By using our service, you consent to the transfer of your information to our facilities and those third parties with whom we share it as described in this Privacy Policy.

11. California Privacy Rights

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

• The right to know what personal information is collected, used, shared, or sold
• The right to delete personal information held by us
• The right to opt-out of the sale of personal information (we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights

To exercise these rights, please contact us at privacy@comeup.ai.

12. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR). We are committed to ensuring you can exercise these rights, including:

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing

Our legal basis for processing your personal information includes: (1) your consent, (2) performance of a contract with you, (3) compliance with legal obligations, and (4) our legitimate interests.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@comeup.ai.