Privacy Policy

Compass Finance ("Compass," "we," "us," or "our") is committed to protecting your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). This policy explains what personal information we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it.

If anything in this policy is unclear, or you want to exercise any of the rights described below, contact us at [email protected].

1. Who We Are

Compass Finance is a Canadian personal finance application. We are a Canadian-scoped product: our service, our data handling, and this policy apply exclusively to Canadian users and Canadian financial institutions.

Igor Pinheiro is designated as the Privacy Officer accountable for Compass Finance's compliance with this policy and with PIPEDA. All privacy inquiries, complaints, and rights requests should be directed to [email protected].

2. Information We Collect

We collect only the information reasonably necessary to provide the Compass service. The categories below reflect what we actually collect, not a general list of what a financial app could collect.

2.1 Account information

Name, email address, date of birth, and authentication credentials (password, and multi-factor authentication enrollment data) provided when you create an account. We use your date of birth to confirm that you meet the eligibility requirement described in Section 10.

2.2 Financial data (via Plaid)

When you connect a bank account or investment account through Plaid, we receive and store transaction records, account balances, and account metadata (institution name, account type) for the accounts you choose to connect. We do not receive or store your online banking credentials; these are handled directly between you and Plaid.

2.3 Billing information (via Stripe)

When you subscribe to a paid tier, Stripe processes your payment on our behalf. Compass does not receive, transmit, or store your full payment card number. Stripe provides us with subscription status, billing history, and limited billing contact information (name, email) necessary to manage your subscription.

2.4 AI interaction data

If you use the Compass Guide AI assistant or AI-powered transaction categorization, we process abstracted representations of your financial data as described in Section 6.

2.5 Usage and support data

Information generated by your use of the app (feature usage, error logs and diagnostic data collected through Sentry) and any information you provide when contacting support.

3. How We Use Your Information

We use personal information only for the purposes it was collected for:

• To provide and operate the Compass service, including bank connectivity, budgeting, net worth tracking, and registered account tracking (TFSA, RRSP, FHSA)
• To categorize transactions and power the AI assistant
• To process subscription billing through Stripe
• To communicate with you about your account, service changes, or support requests
• To maintain the security and integrity of the service
• To meet legal and regulatory obligations

We do not use your financial data for advertising, and we do not sell personal information to third parties.

4. Consent

We obtain your express consent before collecting, using, or disclosing your personal information, separated by purpose:

• Consent to bank connectivity (Plaid) is obtained when you choose to link an account.
• Consent to AI-powered categorization and the AI assistant is obtained separately and can be withdrawn at any time in Settings, without affecting your ability to use the rest of the service.
• Consent to billing data sharing with Stripe is obtained when you subscribe to a paid tier.

You may withdraw consent for any purpose at any time, except where retention or continued processing is required by law or necessary to complete a transaction already in progress (for example, a billing cycle already underway). Withdrawing consent for a given purpose may limit or disable the corresponding feature.

We record the date, method, and content of your consent, and retain consent records for the duration your account remains active plus a reasonable period thereafter, consistent with our retention practices in Section 8.

5. Who We Share Information With

We share personal information only with the service providers necessary to operate Compass, and only for the purposes described in this policy. Compass remains accountable for personal information shared with any provider below; each is contractually required to protect it to a standard consistent with PIPEDA and to use it only for the purpose we specify.

Cross-border data transfer

Because several of our service providers operate outside Canada, some of your personal information is processed in the United States as described in the table above. Under PIPEDA, your personal information remains subject to the laws of the jurisdiction it is processed in, including lawful access requests by that jurisdiction's authorities. We select service providers that maintain security and privacy protections consistent with PIPEDA regardless of where they are located, and we do not transfer personal information to any provider not listed in this policy.

Our primary database, hosted with Supabase, is located in Canada (Canada Central region, Montreal, Quebec). Your account and financial data therefore reside in Canada at rest; cross-border processing occurs only through the specific service providers named above (Plaid, Stripe, Google, Resend, Vercel, Sentry), each for the limited purpose described in the table.

6. AI Categorization and the AI Assistant

Compass uses Google's Gemini API for two distinct, separately-consented features. The specific Gemini model version powering each feature may change over time as Google releases new models; this policy describes the data practice, which remains constant regardless of which model version is in use.

Auto-categorization: When enabled, the merchant name and transaction type (not the amount, not your account identifiers, and not any other personal information) are sent to Google's Gemini API to suggest a spending category. This feature is opt-in and can be disabled at any time in Settings. AI-assigned categories are visibly marked in the app so you always know when a category was machine-suggested versus set by you.

Compass Guide (AI assistant): Available on eligible tiers, the AI assistant operates on abstracted, aggregated spending summaries, not your raw transactions or account identifiers. Conversation history with the assistant is managed server-side for the duration of your session and is not retained beyond what is necessary to provide the feature.

We also maintain a shared merchant-name dictionary that normalizes transaction descriptions across users. If you correct a merchant name, that correction may anonymously contribute to improving this shared dictionary once a threshold of similar corrections is reached; no personal information is included in the shared dictionary.

Categorization suggestions are not a solely automated decision with legal or similarly significant effect on you: you can always view, correct, or override an AI-assigned category, and doing so does not require any special process.

Independent of Compass's own retention practices described in Section 8, Google retains the prompts and outputs sent to the Gemini API for up to 55 days for abuse and safety monitoring purposes. This data is not used to train Google's models.

For more information about how Google handles data submitted to its APIs, see Google's Privacy Policy.

7. Security Safeguards

We protect your personal information using safeguards appropriate to its sensitivity, including encryption in transit and at rest, role-based access controls, row-level security enforced at the database layer, and mandatory multi-factor authentication before you can link a bank account. Full detail on our security practices is documented in our internal Information Security Policy, maintained by our Privacy Officer.

8. Data Retention and Deletion

We retain personal information only as long as necessary for the purposes described in this policy. This section distinguishes three different events: a failed payment, cancelling your subscription, and deleting your account. Only account deletion is immediate and permanent; the other two start a 90-day retention window that reactivation can reverse.

Active accounts: Your data is retained for as long as your account remains active and you continue to use the service.

Payment failure: If a subscription payment fails, you have 7 days to update your payment method before the subscription is suspended. If the issue is not resolved within that window, the subscription is suspended, your linked bank connections are disconnected, and the 90-day retention window described below begins.

Subscription cancellation or lapse: When your subscription is cancelled or lapses following an unresolved payment failure, your linked bank connections are disconnected immediately, at the point the subscription ends, not at the end of the 90-day window and not only upon deletion. This is a full disconnection, not a pause: because the underlying connection cannot be resumed, reconnecting afterward requires re-linking each institution through Plaid Link again. Your account then enters a 90-day read-only window: you retain read access to your existing data and can export your transaction history as a CSV at any time during this period, but no new bank syncs, AI credits, or insights are processed. You will receive an email notice 7 days before the end of this window, which links directly to the export tool. Reactivating your subscription at any point during the 90-day window cancels the pending deletion and restores full access, though your bank connections will still need to be re-linked since they were disconnected at cancellation.

Cancelling your subscription is separate from deleting your account. Cancelling ends billing and starts the 90-day retention window described above; on its own, it deletes nothing. Deleting your account, described below, is a distinct, immediate, and irreversible action you must take separately.

Household accounts: Compass subscriptions are held at the household level. If the household's subscription is cancelled or lapses, every household member's bank connections are disconnected as described above, and non-owner members are suspended from accessing the app; the household owner retains access in order to manage billing and reactivate. If any household member deletes their own account (see "Full deletion" below), the shared household record is dissolved. This does not delete other members' data: remaining members keep their own historical financial data and can continue using Compass, but will need to start their own individual subscription and re-link their own bank connections going forward.

Full deletion: If you request account deletion, or if the 90-day post-cancellation window elapses without reactivation, we perform a full deletion of your account. This is a complete deletion: no personal information, including your name, email address, financial data, or any other identifying information, is retained after this process completes. This differs from the 90-day retention window described above; deleting your account permanently removes your login credentials immediately, and creating a new account afterward would require signing up again as a new user. Deletion records limited to the fact and date that a deletion occurred are retained for a minimum of 2 years, as required by PIPEDA, but these records do not include your personal information.

Plaid data: Your Plaid bank connections are removed at the point your subscription is cancelled or lapses, as described above, not deferred to the end of the 90-day window or to account deletion. This stops Plaid from billing us for the connection and revokes our access token immediately.

Breach records: In the event of a security incident involving personal information, records of that incident are retained for a minimum of 2 years, consistent with PIPEDA's breach record-keeping requirements.

9. Your Rights

Under PIPEDA, you have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Withdraw consent for any purpose described in Section 4, subject to legal or contractual limitations
• Export your data in a commonly used format (CSV or JSON)
• Delete your account and associated personal information, as described in Section 8
• Challenge our compliance with this policy or with PIPEDA

To exercise any of these rights, contact us at [email protected]. We will respond to access requests within 30 days, as required by PIPEDA. There is no charge for a standard access request.

10. Eligibility

Compass is intended for use by individuals who have reached the age of majority in their province or territory of residence. We do not knowingly collect personal information from individuals below this age. If we become aware that we have inadvertently collected information from someone who does not meet this requirement, we will delete it.

11. Cookies and Similar Technologies

Compass uses the following technologies for essential operation and analytics:

Strictly necessary: We use cookies and similar technologies required for authentication and to keep you securely signed in. These cannot be disabled without affecting your ability to use the service.

Analytics — Vercel Analytics: We use Vercel Analytics on our website and application to understand aggregate usage patterns (such as page views and general traffic trends). Vercel Analytics is designed to operate without setting tracking cookies and does not collect personally identifiable information.

Analytics — Google Analytics (planned): We plan to implement Google Analytics on our marketing website (compassfinance.ca) to better understand visitor traffic. Google Analytics uses cookies and may involve cross-border processing in the United States. Before this feature is enabled, we will implement a cookie consent mechanism that allows visitors to accept or decline non-essential analytics cookies, consistent with the consent requirements described in Section 4. This policy will be updated with the specifics of that consent mechanism once implemented, and it will not be enabled beforehand.

12. Changes to This Policy

We may update this policy from time to time. When we make a material change, we will notify you (for example, by email or an in-app notice) and update the "Last updated" date above. Continued use of Compass after a material change takes effect constitutes acceptance of the updated policy. Prior versions of this policy are retained and available on request.

13. How to File a Complaint

If you believe we have not handled your personal information in accordance with this policy or PIPEDA, contact us first at [email protected] so we can investigate and respond. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
1-800-282-1376
www.priv.gc.ca

14. Contact Us

Compass Finance
Email: [email protected]
Website: compassfinance.ca