Privacy Policy

Our Philosophy

Cent Capital was founded with a singular purpose: to reduce global financial inequality by democratizing financial intelligence. We believe that just as wealth creation is a human right, so is the fundamental right to data privacy. This Privacy Policy is not just a legal document; it is a core component of our mission. It outlines our unwavering commitment to protecting your personal information, handling it with transparency, and using it solely for the purpose of empowering you on your financial journey.

Who We Are

The services described in this policy are provided by Cent Capital Global Inc., a Delaware corporation based in New York, NY. We are the "data controller" for your information. Our service is designed to be a dedicated partner in your financial journey, providing enterprise-grade financial intelligence through our AI-powered co-pilot to help you move from financial anxiety to financial control.

Scope of This Policy

This Privacy Policy applies to all information we collect through our website (cent.capital), the Cent Capital web application, and any related services, communications, and events (collectively, the "Services").

The "Education, Not Advice" Principle and Your Data

Our entire service is built upon a revolutionary "education-not-advice" compliance framework. This distinction is critical to how we handle your data. We use your information to provide empowering knowledge, personalized benchmarks, and powerful scenario-planning tools. For example, we might show you how your spending in a certain category compares to your peers or model how an increased savings rate could impact your long-term goals. We do not, however, provide regulated financial advice, such as telling you to buy a specific stock or open a specific product. Our data architecture and processing logic are intentionally designed with guardrails to support this educational mission, ensuring your data is used to empower you with knowledge, not to make decisions for you. This approach is fundamental to our ability to offer a globally scalable, low-cost service and is the foundation of the trust you place in us.

A. Information You Provide to Us Directly

• Account Information: When you sign up for Cent Capital, we ask for your name, email address, and country of residence. We also require you to create a password. This information is essential for creating your account, securing it, communicating with you, and providing relevant, localized educational benchmarks. To enhance security, this personally identifiable information (PII) is stored in a highly-restricted and isolated pii schema within our database.
• Payment Information: To access our subscription services, you will need to provide payment information, such as a credit or debit card number. This information is provided directly to our third-party payment processor, Stripe, which is a certified PCI Service Provider Level 1. Cent Capital does not receive or store your full payment card details on our servers, ensuring your sensitive payment data is handled with the highest level of security.
• Communications: If you contact us for support or other inquiries (e.g., via hello@cent.capital or support@cent.capital), we will collect the information you include in your communications to us. We use this information to investigate and respond to your inquiry, provide support, and improve our Services.

B. Information We Collect from Your Financial Institutions (With Your Consent)

The core of the Cent Capital experience is a holistic view of your finances. To enable this, we require your explicit consent to securely connect to your financial accounts.

• The Secure Connection Process: We use trusted, industry-leading third-party financial data aggregators, such as Plaid for our Tier 1 markets (US, UK, Canada) and other specialized regional partners for our global expansion (e.g., Mono, Setu, Belvo). When you connect an account, you are directed to that aggregator's secure environment to enter your login credentials for your financial institution.
• Crucial Clarification: The authentication process happens directly between you and your financial institution through the aggregator's secure portal. Cent Capital never sees, receives, or stores your bank login credentials (username or password). The aggregator provides us with a secure, read-only access token that allows us to retrieve your financial data on an ongoing basis without ever having access to your credentials.
• Types of Financial Data: Once you have successfully connected an account, we receive the following categories of financial information from the aggregator, which are stored in our secure finance schema:
  • Account Information: Institution name, account name, account type (e.g., checking, credit card), and currency.
  • Account Balances: Current and available balances, and credit limits.
  • Transaction History: Information about your transactions, including date, amount, vendor, and category.
  • Loan and Credit Information: Details about your loans (e.g., student loans, mortgages), including balances, interest rates, and payment due dates.
  • Investment Holdings: Information about your investment accounts, including holdings, balances, and transaction history (as this feature becomes available).

This data is the essential fuel for the AI co-pilot, allowing us to provide the personalized insights and reports that make our service valuable.

C. Information We Collect Automatically (Usage and Technical Data)

When you use our Services, we automatically collect certain technical and usage information to ensure our platform is functioning correctly, securely, and efficiently.

• Device and Log Information: We collect standard log information, including your Internet Protocol (IP) address, browser type and version, operating system, and the dates and times you access our Services.
• Usage Data: We collect information about how you interact with our Services, such as the features you use, the links you click, and the time you spend on different pages. This data is logged in our ops schema and helps us understand how our product is being used, identify areas for improvement, and troubleshoot issues. We use tools like Sentry for real-time application monitoring and error tracking to proactively resolve problems.

A. To Provide, Maintain, and Improve Our Services

The primary use of your information is to deliver the core Cent Capital experience. We use your financial data to create a single, holistic view of your finances, automatically categorize your transactions, and generate your Monthly Wealth Report. We use your technical and usage data to monitor the performance of our Services, diagnose and fix bugs, and plan for future feature development.

B. To Power Your AI Financial Co-Pilot

This is where we turn your data into valuable, personalized knowledge. We use your financial data as input for our advanced AI models, which are powered by Google's Gemini API. The output of this analysis is always educational and designed to build your financial confidence. This includes:

• Personalized Nudges: Clear, visual insights that highlight opportunities for improvement (e.g., "Your dining spend is 25% of your income; peers in your city typically spend 12%.").
• Peer Benchmarking: Objective, data-driven comparisons that provide context for your financial habits against relevant peer groups based on factors like income, age, and location.
• Scenario Modeling: Powerful tools that show you the long-term impact of small behavioral changes (e.g., "If you increase your savings by $100/month, you could reach your home down payment goal 18 months sooner.").

To protect your privacy, we are committed to using anonymized or pseudonymized data in our AI processes wherever feasible.

C. To Provide Security and Detect Fraud

We turn data collection into a protective feature for you. Our system actively monitors your connected accounts for suspicious activity, potential duplicate charges, and hidden bank fees. When we detect a potential issue, we alert you in real-time, helping you protect your money and stay in control.

D. To Communicate With You

We use your contact information to send you important communications about our Services. This includes essential service-related notifications like your Monthly Wealth Report, security alerts, and updates to our terms or policies. We may also send you marketing communications about new features or offers, but you will always have a clear and easy way to opt-out of these non-essential messages.

What We Will Never Do With Your Data

Our business model is built on a foundation of trust and alignment with our users, not on data exploitation. This stands in direct contrast to many "free" fintech apps that have created a profound trust deficit in the market. Therefore, we make the following commitments:

• We do not and will not sell your personal financial data to third parties for their own marketing purposes.
• We do not share your personal financial data with third parties unless it is necessary to provide our Services (as detailed in Part III) or we are required to do so by law.

These limitations are not just legal constraints; they are a core feature of our product and a deliberate choice to put your interests first.

A. With Our Service Providers (Sub-processors)

We rely on trusted third-party companies to help us operate, secure, and improve our Services. These providers, also known as sub-processors, are contractually obligated to safeguard your data and are prohibited from using it for any other purpose. We maintain a rigorous vetting process for all our providers. Our categories of service providers include:

• Cloud & Infrastructure: We use Supabase for our managed database, authentication, and serverless backend functions.
• Financial Data Aggregation: We use Plaid and other regional partners to securely connect to your financial accounts.
• AI Processing: We use Google's Gemini API to power the analytical capabilities of our AI co-pilot.
• Payment Processing: We use Stripe to securely handle subscription payments.
• Communications: We use Amazon Simple Email Service (SES) to send service-related emails.
• Analytics & Monitoring: We use Sentry for application monitoring and error tracking.

We are committed to transparency and will maintain an up-to-date list of our key sub-processors on our website.

B. With Our Affiliate Partners

Our dual-revenue model combines a low-cost subscription with a curated affiliate marketplace. This model allows us to keep our subscription price accessible (at ~$1/month) while generating revenue in a way that is aligned with your success. The affiliate process is a potential source of conflict of interest for many financial platforms, which is why we are committed to "Radical Transparency" in how it works.

• The Process: Our Service first educates you on financial concepts and benchmarks your progress. Within the platform, we may feature a curated marketplace of vetted third-party financial products (e.g., high-yield savings accounts, credit cards). If you choose to learn more about one of these products, you will be redirected to the partner's website.
• Tracking and Commissions: We may use a unique tracking link to let the partner know that you were referred by Cent Capital. If you decide to sign up for their product, we may receive a commission from the partner. This commission does not increase the cost of the product for you.
• Our Commitment to Unbiased Education: Our educational insights, peer benchmarks, and AI-driven nudges are generated independently based on your data and our models. They are not influenced by our affiliate relationships. This is a foundational principle of our "Trust Moat" and our core differentiator against platforms that are often biased by affiliate payouts.
• Data Shared: We do not share your personal financial transaction history or account balances with our affiliate partners. The information shared is limited to the minimum necessary for referral tracking, which may include an anonymized or unique user ID.

C. For Corporate Transactions

If Cent Capital is involved in a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. The new entity would be bound to uphold the commitments made in this Privacy Policy.

D. In Response to Legal Process

We may disclose your information to a third party if we believe that disclosure is reasonably necessary to (a) comply with any applicable law, regulation, legal process, or governmental request, (b) enforce our agreements and policies, (c) protect the security or integrity of our Services, or (d) protect ourselves, our users, or the public from harm or illegal activities. Where legally permissible, we will make a reasonable effort to notify you in the event we are required to provide your information to a third party as part of a legal process.

A. Our "Trust by Design" Security Architecture

We have engineered our platform from the ground up with your security and privacy as our top priority. This "Trust by Design" approach translates our technical architecture into tangible protections for you.

• Data Isolation: We utilize Supabase's Row-Level Security (RLS), a powerful database-level feature. In simple terms, this means your financial data is stored in a way that makes it cryptographically impossible for any other user to access it. Our own architecture enforces this separation at the most fundamental level, ensuring data leakage between users is virtually impossible.
• PII Segregation: We have made a deliberate design choice to store your personal identity information (like your name and email) in a separate, highly-restricted pii schema, physically isolating it from the bulk of your financial data. This compartmentalization minimizes risk and ensures your identity is protected.
• Encryption: All data is encrypted in transit between you and our servers using industry-standard Transport Layer Security (TLS). Your data is also encrypted at rest when stored in our databases.

B. How Long We Keep Your Information

• Active Accounts: We retain your personal and financial information for as long as your account remains active. This is necessary to provide you with the full functionality of the Services, including historical analysis and tracking your progress over time.
• Account Deletion: You can delete your account at any time through your account settings. When you delete your account, we will initiate a process to permanently delete your personal and financial information from our production systems. This process will be completed within a reasonable timeframe, typically no longer than 90 days, subject to any legal or regulatory obligations that may require us to retain certain information for longer periods (e.g., for financial audits or to resolve legal disputes).
• Anonymized Data: After you delete your account, we may retain and use your information in an aggregated and anonymized format that can no longer be linked to you. We use this data for statistical analysis, research, and to improve our Services.

A. Your Universal Rights

We extend the following core data protection rights to all our users:

• The Right to Access: You have the right to request a copy of the personal information we hold about you.
• The Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information.
• The Right to Erasure (Deletion): You have the right to request the deletion of your personal information, subject to certain legal exceptions.
• The Right to Restrict Processing: You have the right to request that we limit the way we use your personal information in certain circumstances.
• The Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another service.

B. How to Exercise Your Rights

You can exercise most of these rights directly through your account settings. For any requests you cannot fulfill through your settings, please contact us at privacy@cent.capital. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

A. Our Global Operations

Cent Capital Global Inc. is a company based in the United States. Our primary technology infrastructure and service providers (including Supabase, Google, and Stripe) are also located in the U.S.. This means that if you are using our Services from outside the United States, your personal information will be transferred to, stored, and processed in the United States.

B. Legal Basis for International Transfers

Data protection laws vary among countries, and the laws of the United States may differ from those in your country of residence. For users in the European Economic Area (EEA), the United Kingdom, and other regions with specific regulations governing data transfers, we take additional measures to ensure your data is protected. We rely on legally-provided mechanisms to lawfully transfer data across borders. For transfers of personal data from the EEA and the UK to the U.S., we rely on Standard Contractual Clauses (SCCs) or an equivalent data processing addendum with our sub-processors to ensure your information is afforded a level of protection that is consistent with European law.

A. Our Policy Towards Children

Our Services are not directed to individuals under the age of 18 or the applicable age of majority in their jurisdiction. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete such information as soon as possible.

B. Cookies and Other Tracking Technologies

We use cookies and similar technologies to provide and support our website and Services. Cookies are small text files stored on your device that help us with functions like keeping you logged in, remembering your preferences, and understanding how you use our Services. For more detailed information about the cookies we use, please see our Cookie Policy.

C. Links to Third-Party Websites

Our Services may contain links to other websites or services that are not operated by us, such as the websites of our affiliate partners. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

D. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make a material change, we will notify you by email (sent to the email address specified in your account), through a notification in our application, or as otherwise required by applicable law. We encourage you to periodically review this page for the latest information on our privacy practices.

E. How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, please do not hesitate to contact us.