Privacy Policy
Draft template — not legally sufficient. This is a starting structure for KUN-58. Counsel will review and finalize before public launch.
1. Who we are
Wallie is operated by [Legal entity TBD — KUN-52]. Wallie is not a bank. We do not hold, pool, or move your money. Wallie is a software assistant that reads transactions from the apps you already use and opens those apps with payment details pre-filled; the apps you link move the money.
2. What we collect
- Account information you provide: email, phone, display name.
- Transaction details from the accounts you link through Plaid with your consent: amount, date, memo, counterparty, and institution label. We never receive your banking login credentials.
- Device information: OS version, model, language, timezone, and a fraud-prevention device fingerprint.
- Hashed contacts you explicitly sync from your phone. Raw phone numbers and emails of your contacts never leave your device; we only receive salted SHA-256 digests.
- Product usage analytics (crash reports, performance metrics).
3. How we use it
To operate the Wallie assistant, answer your questions across your linked accounts, detect fraud and abuse, and improve the product. We do not sell your personal information. We do not share it with advertisers.
4. GLBA disclosures
To the extent Wallie is a financial institution under the Gramm-Leach-Bliley Act, this section describes the categories of nonpublic personal information we collect and the limited purposes for which we share it. [Counsel-drafted — includes opt-out categories per 12 CFR 1016.]
5. CCPA / CPRA and other state rights
California residents have the right to know, delete, correct, and opt out of sale or sharing of personal information. Because we do not sell or share personal information for cross-context behavioural advertising, there is nothing to opt out of. To exercise your rights, visit getwallie.app/delete-account or email privacy@getwallie.app.
6. Security
Encryption in transit and at rest. Access tokens scoped and rotated. Two-factor authentication available. We maintain a written information security program consistent with the GLBA Safeguards Rule.
7. Deleting your data
You can delete your Wallie profile from the mobile app or at getwallie.app/delete-account. When you confirm deletion we remove your profile and unlink your accounts immediately. Backups are scrubbed within 30 days. Anonymized aggregates used for service metrics may persist for up to 13 months before they are scrubbed.
8. Contact
privacy@getwallie.app [pending KUN-61 brand clearance].
Last updated: draft.