Public-Facing Document

Privacy Policy

How We Collect, Use, and Protect Your Information

Organization Data Jackson, LLC Document ID PP-2026-001 Version 1.0 Effective DateJune 28, 2026 Last Updated June 28, 2026 Contact Brandon Jackson · brandon@datajackson.com Applies To Financial Coach Application & Plaid-integrated services

Table of Contents

  1. Introduction
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Basis for Processing
  5. Financial Data from Plaid
  6. How We Share Your Information
  7. Data Retention
  8. Security of Your Information
  9. Your Privacy Rights
  10. California Privacy Rights (CCPA/CPRA)
  11. Cookies & Tracking Technologies
  12. Children's Privacy
  13. Changes to This Policy
  14. Contact Us

1 Introduction

Data Jackson, LLC ("Data Jackson," "we," "us," or "our") operates the Financial Coach application and related financial technology services that connect to financial institutions via Plaid, Inc.'s financial data network. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services.

We are committed to protecting your privacy and handling your financial data with the care it deserves. Please read this policy carefully. By using our services, you agree to the collection and use of information as described herein.

Summary for Plaid Questionnaire (Q9 & Q10) This privacy policy is displayed to end-users within the application. We obtain explicit consent from consumers for the collection, processing, and storage of their data before any data is accessed through Plaid.

2 Information We Collect

2.1 Information You Provide Directly

2.2 Financial Information (via Plaid)

When you connect a financial account through Plaid, we receive financial data from your linked institutions. See Section 5 for full details on how we handle Plaid-sourced data. This may include:

2.3 Information Collected Automatically

2.4 Information We Do NOT Collect

3 How We Use Your Information

PurposeData UsedBasis
Provide financial coaching and analysis featuresFinancial transactions, account balances, goalsContract performance / Consent
Personalize your experience and recommendationsTransaction history, preferences, goalsConsent
Authenticate your identity and secure your accountEmail, password hash, device infoContract performance / Legitimate interest
Communicate service updates and notificationsEmail addressLegitimate interest / Consent
Improve and develop our servicesAggregated, de-identified usage data onlyLegitimate interest
Security monitoring and fraud preventionUsage logs, IP address, device infoLegitimate interest / Legal obligation
Comply with legal obligationsAs required by applicable lawLegal obligation

We do not sell your personal information or financial data. We do not use your financial data for advertising purposes.

4 Legal Basis for Processing

We process your personal information based on the following legal grounds:

5 Financial Data from Plaid

Our application uses Plaid, Inc. to connect to your financial institutions. When you use Plaid Link within our application, Plaid's own privacy policy also applies to the data Plaid collects on our behalf.

5.1 What Plaid Data We Receive

5.2 How We Protect Plaid Data

5.3 Your Control Over Plaid Data

5.4 Open Banking Regulatory Developments

The CFPB's Section 1033 open-banking / personal financial data rights rule remains subject to ongoing rulemaking and legal challenge as of this policy's last review. We are monitoring its status and will update this policy and our data-sharing practices as the rule's requirements are finalized; this policy does not make a compliance claim regarding Section 1033 either way.

Plaid's Privacy Policy: Plaid maintains its own privacy policy governing how it processes data. You can review it at plaid.com/legal/privacy-policy.

6 How We Share Your Information

We do not sell, rent, or trade your personal or financial information. We share data only in the following limited circumstances:

RecipientPurposeSafeguards
Plaid, Inc.Financial institution connectivity to retrieve your authorized account dataData Processing Agreement; SOC 2 Type II certified
Cloud infrastructure providers (AWS, GCP)Hosting and data storage for the applicationData Processing Agreement; encrypted storage; SOC 2 / ISO 27001 certified
Authentication service providersSecure user identity and MFA managementIndustry-standard authentication protocols; DPA in place
Legal authoritiesWhen required by law, court order, or to protect safetyDisclosed only as legally required; narrowly scoped

Any third-party service provider receiving your data is contractually bound to process it only for the stated purpose and to maintain appropriate security controls.

7 Data Retention

Data TypeRetention PeriodDeletion Method
Financial transaction data (from Plaid)Deleted immediately on account deletion; backup copies purged within 90 daysImmediate database deletion; cryptographic erasure on backup rotation
Account information (name, email)Deleted immediately on deletion requestSecure deletion from all systems
Usage logs (security and audit)12 months rollingAutomated log expiration
Financial goals and preferencesDeleted immediately on account deletionSecure deletion
Backup copies90 days maximum after primary deletionOverwritten in next backup cycle

When you request account deletion, we verify your identity and then delete all primary data — including revoking any linked Plaid access — immediately, not on a 30-day delay. Backup copies are purged on the next backup rotation cycle, within 90 days. We will confirm completion upon request.

8 Security of Your Information

We implement a comprehensive security program to protect your information (detailed in our Information Security Policy ISP-2026-001). Key safeguards include:

No method of transmission over the Internet or electronic storage is 100% secure. We maintain commercially reasonable security measures appropriate for the sensitivity of the data we process.

9 Your Privacy Rights

You have the following rights regarding your personal information:

RightDescriptionHow to Exercise
AccessRequest a copy of the personal data we hold about youEmail us at brandon@datajackson.com
CorrectionRequest correction of inaccurate or incomplete dataUpdate in-app or contact us
DeletionRequest deletion of your personal dataAccount deletion in-app or email us
PortabilityReceive a copy of your data in a machine-readable formatEmail us at brandon@datajackson.com
Withdraw ConsentWithdraw consent for processing where consent is the basisDisconnect accounts in-app; contact us for full withdrawal
RestrictionRequest restriction of processing in certain circumstancesEmail us at brandon@datajackson.com
ObjectObject to processing based on legitimate interestEmail us at brandon@datajackson.com

We respond to all privacy rights requests within 30 days. Complex requests may require an extension, which we will communicate to you promptly.

10 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

To exercise California rights, submit a verifiable consumer request to: brandon@datajackson.com or via the in-app privacy settings. We respond to verified requests within 45 days (extendable once by an additional 45 days with notice).

10.1 Categories of Personal Information Collected

In the past 12 months, we have collected the following CCPA categories:

11 Cookies & Tracking Technologies

We use essential cookies and similar technologies to operate the application (session management, authentication). We do not use third-party advertising cookies or cross-site tracking technologies.

Essential cookies cannot be disabled as they are necessary for the application to function. You may clear cookies through your browser settings, which will log you out of the application.

12 Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will delete it promptly. If you believe we have collected information from a child, please contact us immediately at brandon@datajackson.com.

13 Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

Your continued use of our services after a policy update constitutes acceptance of the revised policy. For significant changes, we may seek fresh consent.

14 Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Data Jackson, LLC
Privacy Officer: Brandon Jackson
Email: brandon@datajackson.com
Response time: Within 5 business days

For privacy rights requests, you may also submit a request through the privacy settings within the application. We respond to all requests within 30 days.