Privacy Policy

Operator - The Services are currently operated by Steven Michael Snary, a sole proprietor located in Ontario, Canada, doing business as MyFinancialApps.io. We may, in the future, transfer ownership and operation of the Services to a U.S. limited liability company affiliated with the same principal. If that occurs, this Policy will be updated to reflect the new operator and you will be notified in accordance with Section 12.

Advisor as Controller; MyFinancialApps as Processor - When a financial professional ("Advisor") inputs, uploads, or generates personal information about a client they have invited to the App ("Client Data"), the Advisor acts as the data controller of that Client Data and we act as the data processor on the Advisor's behalf. Advisors are responsible for obtaining all necessary consents from their clients, complying with the privacy and financial-services laws applicable to them, and providing their clients with their own privacy notices where required.

Account Categories - The Services support two categories of accounts: (a) Advisor accounts, created by financial professionals who subscribe to the App, and (b) Client accounts, which can only be created by an end-client after receiving an invitation from an Advisor. Without an Advisor invitation, a person cannot proceed past the welcome screen or create a Client account.

Information You Provide - We collect information you provide directly, such as your name, email address, phone number, business address (for Advisors), licensing or registration information (for Advisors), and the financial planning information you enter into the App (which may include income, expenses, insurance coverage, budget allocations, paycheck allocations, cashflow data, and related notes). If you are an Advisor on a paid plan, we also keep your subscription details (plan, status and billing records); your payment card details are entered on and held by Stripe, our payment processor, and never reach us.

Client Data Entered by Advisors - Where an Advisor enters Client Data on behalf of an invited client, we process that information on behalf of the Advisor in accordance with Section 1.2. The Advisor is responsible for the accuracy, lawfulness, and consent basis of any Client Data they input.

Change History of Your Financial Profile - When information in your financial profile changes, PlanTogether keeps a record of the change: what was changed, the previous value and the new value, who made the change (you or one of your financial professionals), and when. This covers the profile details of each household member, contact details (such as address, phone and email), goals, income, debts, housing, savings and assets, and existing insurance policies. Changes made by the same person within the same hour are combined into one record, and long text is shortened to 500 characters. You can see your change history in the app under Your Profile → Change history. The financial professionals you have connected with, and PlanTogether's administrators, can see it too, so everyone works from an accurate record of your information. The history is kept for as long as your financial profile exists. When you delete your data or your account in the app, your change history is deleted with it.

Usage and Device Information - We collect information about how you interact with the App and Services, including device identifiers, operating system, app version, IP address, log data, crash reports, and usage events. This information helps us operate, secure, and improve the Services. This includes records of milestones in the App, such as when you complete a step, and, if the App asks whether a possible new feature would help you, whether you saw the question and told us you would use it. We use these records, counted across users, to understand how the App is used and to decide what to build; we do not share them with third parties or use them for advertising.

Cookies and Similar Technologies - Our website (myfinancialapps.io) sets no cookies and runs no analytics or advertising scripts. The PlanTogether web app keeps your sign-in session in your browser's storage so you stay signed in, and uses Google reCAPTCHA (through Firebase App Check) to protect against abuse, which may set Google's own cookies. Payment pages are hosted by Stripe and may set Stripe's own cookies.

Information from Third-Party Sign-In - If you choose to sign in or connect a third-party account (such as Google or Microsoft), we collect the limited information authorized by you through that provider. See Sections 9 and 10 for Google-specific and email-connection disclosures.

Device-Integrity Diagnostics - The App checks that it is running on a genuine device and an unmodified copy of the App, using Firebase App Check with Apple App Attest or Google Play Integrity. Only if that check fails, the App sends us one diagnostic report containing the platform (iOS or Android), the App version, the operating-system version, and the error code with the first 200 characters of the error message. The report contains no device model, account or user identifier, email address, or token, and is sent at most once per installation for each App version and error code. We keep it only as a server log entry for 30 days, never in the App's database, and use it only to diagnose and fix problems with that check and to understand how often they occur. Like any request to our servers, the network (IP) address the report was sent from also appears in our standard server request logs, which we keep for 30 days. It is not linked to you and is not used for tracking or advertising.

Reminders From Your Financial Professional - If a financial professional invited you, PlanTogether may remind you, in that professional's name, to finish a step you started: accepting their invitation, completing your profile, or starting your budget and keeping it current. If you have an account, reminders are push notifications titled with the professional's name. If you were invited but haven't joined yet, you may get up to two reminder emails, sent through our email provider (see Section 5.2), with replies going to the professional. Reminders are sent in the evening in your local time, at most one a day and three a week, never within a day of you opening the App, and they stop once the step is done. To decide whether to send one, we use information already in your account, such as when you last signed in and which steps you have finished, and the province or state on your profile (or, if there is none, your professional's) to work out your local time. We keep a record of each reminder sent (who it was from and to, the type of reminder, when it was sent and whether you came back), with no names or financial information. The professional who sent it can see their own records, and each record is deleted after 35 days. Professionals also get a weekly count of how many of their clients were reminded, without names. You can turn off push notifications in your phone's settings, use the unsubscribe link in any reminder email, or decline the invitation. From version 2.16, the App also stores your phone's time-zone name (for example, America/Toronto) in your settings so reminders arrive at the right local time; you, the financial professionals you're connected to and PlanTogether's administrators can see it. You can also turn reminders off in Your Profile, and your professional can pause them for you or turn them off for all their clients.

Client Meetings - If your financial professional schedules a meeting with you in the App, we store its date, time, length and format (in person, video or phone), the place, video link or phone number, the agenda, and whether you accepted or said you can't make it. You and that professional can both see it. Meeting invitations, changes and cancellations are emailed to you through our email provider (see Section 5.2) with a calendar file attached. "Add to my calendar" opens your phone's own calendar app, where you choose the calendar; we never read or sync your calendar. You and your professional each get a reminder notification the day before. Your professional's notes about a meeting are visible only to that professional and to PlanTogether's administrators, as with the rest of their records; you don't see them.

Providing the Services - We use information to create and authenticate accounts, deliver the App's functionality (including the Insurance, Budget, Payday Planner, and Cashflow Calendar modules), generate compliance documents at the Advisor's direction, send service-related notifications, and respond to support requests.

Improving and Securing the Services - We use aggregate and de-identified usage information to monitor performance, diagnose issues, prevent fraud and abuse, and improve the Services. We do not use Client Data for product analytics in a way that identifies individual clients.

Communications - We may send you transactional messages (such as account, security, billing, and service notices). We will only send marketing or promotional messages where permitted by applicable law (including Canada's Anti-Spam Legislation, "CASL," and applicable U.S. laws), and you may opt out at any time using the unsubscribe link in such messages or by contacting us using Section 13.

Legal and Safety - We may use information to comply with applicable laws, respond to lawful requests from public authorities, enforce our Terms, and protect the rights, property, or safety of MyFinancialApps, our users, or others.

No Sale of Personal Information - We do not sell personal information for monetary or other valuable consideration, and we do not engage in "sharing" of personal information for cross-context behavioural advertising as those terms are defined under applicable U.S. state privacy laws.

Where Your Data Is Stored - Personal information processed through the Services is stored in encrypted form in our database, which is hosted on Google Cloud Platform / Firebase, with primary servers located in Montreal, Quebec, Canada.

Cross-Border Transfers - Because the Services are available to users in both Canada and the United States, personal information may be accessed, transferred to, or processed in jurisdictions other than your own. By using the Services, you acknowledge that your information may be subject to the laws of those jurisdictions, including lawful access requests by government authorities. We rely on contractual and technical safeguards (including the use of Google Cloud's standard data-processing terms and our internal access controls) to protect your information during any such transfer.

With the Inviting Advisor (for Clients) - If you are a Client, the financial planning information you and your Advisor enter into the App is shared with your Advisor as part of the core function of the Services. This sharing is the reason the App exists.

Service Providers (Sub-Processors) - We share personal information with vetted service providers that help us operate the Services: Google Cloud Platform / Firebase (hosting, database, authentication, file storage, push notifications and security checks); Twilio SendGrid (email delivery, including documents sent by email); SignWell (electronic signatures: the names and email addresses of the people signing and the documents being signed, which can include financial and insurance information from the client's file); and Stripe (subscription billing for Advisors). These providers are contractually bound to use the information only to provide services to us and to protect it with safeguards no less protective than ours. Some of them process information in the United States (see Section 4.2).

Legal and Compliance - We may disclose information in response to a valid subpoena, court order, or other lawful request; to comply with applicable laws and regulations; to enforce our Terms; or to protect the rights, property, or safety of MyFinancialApps, our users, or others.

Business Transfers - We may share or transfer information in connection with the planned transfer of the Services to our affiliated U.S. limited liability company (see Section 1.1), or in connection with any future merger, acquisition, financing, or sale of all or part of our business. Any successor will be bound by privacy commitments no less protective than this Policy, and we will provide notice of material changes per Section 12.

No Sale of Information - We do not sell personal information. See Section 3.5.

Encryption and Access Controls - Personal information is encrypted in transit using industry-standard TLS, and is encrypted at rest within our Google Cloud Platform / Firebase database. We maintain role-based access controls, audit logging, and least-privilege access for our personnel and authorized service providers.

No Absolute Security - No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable safeguards designed to protect personal information, we cannot guarantee absolute security.

Retention - We retain personal information for as long as your account remains active and as needed to provide the Services. We may retain certain information for a limited period afterwards as required for legal, tax, regulatory, audit, security, fraud-prevention, or dispute-resolution purposes, or as otherwise permitted by applicable law. Change history (2.3) is kept for as long as your financial profile exists and is deleted with it. Records of milestones and feature interest (2.4) contain no financial information and are linked only to an internal account identifier; we keep them after an account is deleted so our counts stay accurate. When an account is deleted, or a client and their financial professional stop working together, upcoming meetings are cancelled; past meeting records and the professional's notes are kept as part of the professional's records.

Breach Notification - In the event of a security breach affecting personal information, we will notify affected users and applicable regulators (including the Office of the Privacy Commissioner of Canada and applicable U.S. state regulators) as required by applicable law.

Access, Correction, and Deletion - You may review and update most of your information directly in the App. You may also delete your account and associated user-generated data using the Delete Account function in the Profile section of the App, or by contacting us using Section 13. Where Client Data is involved, deletion requests by Clients may be coordinated with the inviting Advisor in their capacity as data controller. Deleting your data or your account also deletes your change history (2.3).

Withdrawing Consent - Where we rely on consent to process your information, you may withdraw that consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may limit your ability to use parts of the Services.

Canadian Users (PIPEDA, Quebec Law 25, and Provincial Equivalents) - If you are located in Canada, you have the right under the Personal Information Protection and Electronic Documents Act ("PIPEDA"), Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25), and substantially similar provincial laws (including Alberta's PIPA and British Columbia's PIPA where applicable), to request access to and correction of your personal information, to file a complaint, and to receive information about our policies and practices. You may direct any request or complaint to our Privacy Officer (Section 13). If we are unable to resolve your complaint, you may contact the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, or your provincial regulator.

Quebec-Specific Rights - Users in Quebec have additional rights under Law 25, including the right to request the cessation of dissemination of personal information, the right to be informed of any automated decision-making affecting them, and the right to data portability in a structured, commonly used technological format, subject to the conditions and exceptions set out in applicable law.

U.S. State Privacy Rights - Depending on your state of residence (including California, Colorado, Connecticut, Virginia, Utah, and other states with comprehensive consumer-privacy laws), you may have rights to: (a) confirm whether we process your personal information and access it; (b) correct inaccurate personal information; (c) request deletion of personal information; (d) opt out of the sale of personal information or its use for targeted advertising (we do neither - see Section 3.5); and (e) appeal a denial of a request. To exercise any of these rights, contact us using Section 13. We will verify your identity before fulfilling a request and will respond within the time periods required by your state's law.

Non-Discrimination - We will not discriminate against you for exercising any of the rights described above.

The Services are not directed to, and we do not knowingly collect personal information from, individuals under the age of 18. If we learn that we have collected personal information from a person under 18 without verifiable parental consent or other legal basis, we will delete that information.

Data Accessed - Where an Advisor chooses to connect a Gmail account to the email feature described in Section 10, we request read-only access to their Gmail through the OAuth scope https://www.googleapis.com/auth/gmail.readonly, together with Google's basic sign-in information that identifies which Google account is connected. We use it only to show the Advisor's email threads with a specified client. Google accounts are not used to sign in to PlanTogether.

Data Usage - We use Google user data solely to provide that feature: showing an Advisor their email threads with a specified client inside the App. We do not use Google user data for advertising, marketing, profiling, or any purpose other than delivering the Services.

Data Sharing - We do not sell Google user data. Gmail message content goes only between your device and Google and is not transferred to our servers or to any third party (see Section 10).

Data Storage and Protection - Gmail message content is read directly between your device and Google and is not stored on our servers (see Section 10). Any other Google user data is encrypted in transit and at rest within our Firebase backend (servers located in Montreal, Quebec, Canada). We maintain strict access controls and comply with Google's security requirements.

Data Retention and Deletion - We retain Google user data only as long as necessary to provide the Services or as required by law (typically no longer than 30 days after account deletion). You may request deletion of all your data (including any linked Google data) at any time using the Delete Account feature in the App or by emailing Steve@MyFinancialApps.io. We will action the request within 30 days and confirm by email.

Limited Use Disclosure - MyFinancialApps's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

What It Is - Advisors can choose to connect their own mailbox (Gmail, Outlook or Microsoft 365, or another mailbox through IMAP) to read their email threads with a specific client inside the App. The connection is optional, available to Advisors only, and read-only: the App does not send, delete, move or change any email, and for Gmail and Microsoft accounts it has no permission to.

Microsoft Data Accessed - Where you choose to connect a Microsoft account, we request these delegated Microsoft Graph permissions: Mail.Read, to read your mail, and openid, profile and offline_access, to sign you in and keep you signed in. Our app registration also lists User.Read (your basic profile). We do not request permission to send mail or to change your mailbox. Gmail connections use the read-only scope described in Section 9.

How It Works - The App connects directly from your device to Microsoft, Google or your IMAP mail server and finds the messages between you and the client you are viewing. To find them in an Outlook or Microsoft 365 mailbox, the App may retrieve basic details (sender, recipients, subject and a short preview) of other messages to your device and discard those that don't involve that client; none of it leaves your device. Some emails contain images hosted by the sender. If they are shown, your device fetches them from the sender's server, which can tell the sender the email was opened. From version 2.0.14 of the App, these images stay hidden until you choose to show them. Email content is not sent to or stored on our servers, and we do not use it for advertising, profiling, or any purpose other than showing you those threads. Our servers record only which type of mailbox your business email address uses (Gmail, Outlook or IMAP), never its content.

Sign-In and Credentials - You sign in on Microsoft's or Google's own sign-in screen; we never see your Microsoft or Google password. Sign-in tokens stay on your device. They are protected by your operating system's secure storage (the iOS Keychain or the Android Keystore), or held by Google's or Microsoft's own sign-in apps on your device, and are never sent to our servers. If you connect through IMAP, your mail-server settings and app password are stored only on your device, in that same secure storage.

On Your Device - To show your threads, the App keeps the email content you view on your device. Attachments you open are saved to the device temporarily and deleted automatically.

Revoking Access - You can revoke the App's access at any time: for a personal Microsoft account at account.live.com/consent/Manage, for a work or school account at myapps.microsoft.com, and for Google at myaccount.google.com/permissions. Deleting your PlanTogether account also signs the App out of your mailbox and removes the connection from your device. From version 2.0.14, logging out of PlanTogether also removes the connection from your device.

The Services may contain links to, or integrations with, third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing any personal information to them.

We may update this Policy from time to time to reflect changes in our practices, in the Services, or for legal, regulatory, or operational reasons. When we make material changes, we will update the "Last updated" date above and provide reasonable notice through the App, by email, or by posting a notice on our website before the change takes effect.

Privacy Officer - Steven Michael Snary serves as our designated Privacy Officer for MyFinancialApps.io.

Contact - For privacy questions, requests to exercise the rights described in Section 7, or complaints, please email us at Steve@MyFinancialApps.io.

Response Time - We aim to acknowledge privacy requests within 10 business days and respond substantively within 30 days, or such shorter period as required by applicable law.