Privacy Policy
Momentum Finance LLC
Effective Date: [INSERT DATE WHEN LLC IS APPROVED]
Last Updated: [INSERT DATE]
1. Introduction
Momentum Finance LLC ("Momentum," "we," "us," or "our") operates the Momentum mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.
By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.
2. Information We Collect
2.1 Information You Provide Directly
- Account Information: Name, email address, and password when you create an account.
- Profile Information: Financial goals, monthly income range, and monthly budget preferences provided during onboarding.
- User-Generated Content: Goals, transactions, notes, and other financial data you manually enter into the App.
2.2 Financial Information via Plaid
We use Plaid Inc. ("Plaid") to connect your bank accounts to the App. When you link a bank account through Plaid:
- What Plaid collects: Your bank login credentials are provided directly to Plaid and are never shared with or stored by Momentum. Plaid may collect your account name, type, balance, and transaction history on our behalf.
- What we receive from Plaid: Account balances, transaction history (including date, amount, merchant name, and category), and account metadata (account name and type).
- What we do NOT receive: Your bank login credentials, full account numbers, routing numbers, or Social Security number.
- Plaid's own privacy policy: Your use of Plaid is also subject to Plaid's End User Privacy Policy. We encourage you to review it.
- Data retention from Plaid: We store transaction data and account information received from Plaid to provide App functionality. You may disconnect your bank account and request deletion of this data at any time (see Section 7).
2.3 Payment Information via Stripe
We use Stripe Inc. ("Stripe") to process subscription payments.
- What Stripe collects: Payment card details (card number, expiration date, CVC) are provided directly to Stripe and are never shared with or stored by Momentum.
- What we receive from Stripe: Subscription status, payment confirmation, and a Stripe customer identifier. We do not receive or store your full card number.
- Stripe's own privacy policy: Your use of Stripe is subject to Stripe's Privacy Policy.
2.4 Information Collected Automatically
- Device Information: Device type, operating system, and version.
- Push Notification Tokens: If you enable push notifications, we collect your device's push notification token solely to deliver notifications to your device.
- Usage Data: App feature usage, screen views, and interaction patterns (collected in aggregate, not linked to financial data).
2.5 Information from Third-Party Sign-In
If you sign in using Google or Apple Sign-In, we receive your name, email address, and a unique account identifier from the provider. We do not receive your Google or Apple password.
3. How We Use Your Information
We use the information we collect to:
- Provide and maintain the App — display your financial progress, goals, momentum score, streaks, and challenges.
- Sync financial data — import and categorize transactions from your linked bank accounts.
- Personalize your experience — tailor insights, coaching tips, and weekly recaps based on your financial activity.
- Process payments — manage your subscription through Stripe.
- Send notifications — deliver streak reminders, weekly summaries, and other App-related communications you have opted into.
- Improve the App — analyze aggregate usage patterns to enhance features and fix bugs.
- Ensure security — detect and prevent fraud, unauthorized access, and other harmful activity.
- Comply with legal obligations — respond to legal requests and enforce our Terms of Service.
4. How We Share Your Information
We do NOT sell, rent, or trade your personal information to third parties.
We share information only in the following limited circumstances:
| Recipient | Purpose | Data Shared |
| Plaid Inc. | Bank account linking and transaction sync | Bank credentials (direct to Plaid, never to us) |
| Stripe Inc. | Payment processing | Payment details (direct to Stripe, never to us) |
| Expo / Apple / Google | Push notification delivery | Device push tokens |
| Cloud infrastructure providers | App hosting and data storage | Encrypted app data |
| Law enforcement | When required by law, subpoena, or court order | As legally required |
We may also share aggregated, de-identified data that cannot reasonably be used to identify you.
5. Data Security
We implement industry-standard security measures to protect your information:
- Encryption in transit: All data transmitted between the App and our servers uses TLS/SSL encryption.
- Encryption at rest: Sensitive data is encrypted in our database.
- Authentication tokens: Stored securely on your device using platform-native secure storage (iOS Keychain / Android Keystore).
- Password hashing: Passwords are hashed using bcrypt and are never stored in plaintext.
- Access controls: Internal access to user data is restricted on a need-to-know basis.
- Third-party security: Plaid and Stripe maintain SOC 2 Type II certifications and comply with PCI DSS standards.
While we strive to protect your data, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.
6. Data Retention
- Account data: Retained for as long as your account is active.
- Financial data (from Plaid): Retained for as long as your bank account is linked. You may disconnect at any time.
- Transaction history: Retained for as long as your account is active to provide historical progress tracking.
- Payment records: Retained as required for tax, accounting, and legal compliance purposes.
- Deleted accounts: Upon account deletion, we delete or anonymize your personal data within 30 days, except where retention is required by law.
7. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request correction of inaccurate or incomplete data.
- Deletion: Request deletion of your account and associated data.
- Disconnect bank accounts: Remove linked bank accounts at any time through the App's Settings.
- Opt out of notifications: Disable push notifications through your device settings or the App's Settings.
- Cancel subscription: Manage or cancel your subscription at any time through the App.
To exercise any of these rights, contact us at [email protected].
We will respond to all requests within 30 days.
California Residents (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
- 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 your personal information.
- The right to non-discrimination for exercising your CCPA rights.
8. Children's Privacy
The App is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected data from a child under 18, we will take steps to delete that information promptly.
9. Third-Party Links and Services
The App may contain links to third-party websites or services (such as Plaid and Stripe). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated Privacy Policy in the App.
- Updating the "Last Updated" date at the top of this page.
- Sending a push notification or email for significant changes.
Your continued use of the App after changes are posted constitutes your acceptance of the updated Privacy Policy.
11. Contact Us
If you have questions or concerns about this Privacy Policy, please contact us:
Momentum Finance LLC
Email: [email protected]
Website: https://momentumfinance.app
This Privacy Policy was last updated on [INSERT DATE].