Privacy Policy

1. Who We Are and What This Policy Covers

KeepYours is a personal finance information and alerting tool operated by LBYM Labs, Inc. ("LBYM Labs," "KeepYours," "we," "us," or "our"), a Delaware corporation headquartered in the United States. This Privacy Policy explains what information we collect when you use the KeepYours website, apps, and services (the "Service"), how we use and share it, and the choices and rights you have.

This Privacy Policy is part of the terms and conditions set forth in our Terms of Service, which governs your use of our Service. By using the Service, you agree to this Privacy Policy and the Terms of Service. If you have questions, contact us at legal@lbymlabs.com.

You also acknowledge that LBYM Labs is an integrated financial technology platform offering a variety of proprietary and third-party services. By using this website and Services, you consent and agree that LBYM Labs has the right to collect and use the data about you, whether provided by you or provided by or for a third party (including a financial institution) whose services were on or provided through the Platform.

2. A Note on Financial-Privacy Law (GLBA and State Laws)

KeepYours handles financial information that you provide us access to through your accounts with financial institutions and other third parties that may be subject to the federal Gramm-Leach-Bliley Act (GLBA) and its implementing rules.

3. Information We Collect

3.1 Information you provide

• Account information — your email address and password used to access the Service. Passwords are hashed and stored securely through our authentication provider; we never store them in plaintext.
• Contact information — your mobile phone number, if you provide it to receive SMS alerts (see Section 5).
• Communications — information you send us, such as support requests and feedback.

3.2 Financial account data (via Plaid)

When you connect a financial account, our data provider Plaid Inc. gives us read-only access to information from that account. We receive data such as account names and types, balances, and transaction history (including transaction descriptions, amounts, dates, and merchant categories). We do not receive or store your username or password for your account with any financial institution or other third party at any point.

3.3 Information we generate

• Insights and predictions — fee detections, bill predictions, shortfall forecasts, spending categorizations, benchmark comparisons and other information intended to help you anticipate and avoid avoidable fees and otherwise understand your personal finances that we derive from your data.
• Consent records — your opt-in/opt-out choices for marketing, SMS, and partner data sharing, including the timestamp and source of each choice, retained for compliance.

3.4 Information collected automatically

Usage and device data — product analytics events (such as pages viewed and features used) and, through session-analytics tools, recordings and heatmaps of interactions with the Service. Device and log data may include IP address, browser or device type, and timestamps.

Cookies and similar technologies — see Section 8.

Payment processing data — Our payment processor, Stripe, independently collects information when you complete a payment transaction — including device and browser information, IP address, and behavioral signals used for fraud detection. Stripe may also retain partial information from checkout sessions that are not completed. This collection is governed by Stripe's own Privacy Policy (stripe.com/privacy), not this Policy.

4. How We Use Your Information

We use the information we collect to:

• detect fees in your transaction history and try to alert you and otherwise provide the Service;
• predict upcoming bills and try to warn you about potential cash shortfalls before they happen;
• generate personalized insights, spending categorization, and benchmark comparisons;
• send service messages — such as fee, low-balance, and shortfall alerts; reconnect prompts; security notices; subscription and account-status messages; and confirmations. These relate to your account and the operation of the Service and are sent regardless of marketing preferences;
• send marketing messages — such as trial reminders, product updates, and feature announcements — where you have not opted out (and, for SMS marketing, where you have opted in);
• where you request it and have not opted out, help match you with financial partners (such as earned-wage-access, credit-union, or lending options);
• operate, secure, maintain, troubleshoot, and improve the Service;
• improve and develop our products and technology, including training and refining the machine-learning models that power our fee detection, cash-flow prediction, and shortfall forecasting features. For these model-improvement purposes, we use only de-identified and aggregated data patterns that cannot reasonably be attributed to any individual user. We do not use your raw personal financial records for model training;
• detect and prevent fraud and abuse; and
• comply with legal obligations and enforce our Terms.

We do not use your data to:

• serve third-party advertising,
• make or assist in making credit, employment, housing, or insurance decisions, and
• we do not sell it.

5. SMS Text Messages

If you provide your mobile number and opt in, we send you recurring automated text messages through our messaging provider — for example, fee and shortfall alerts and, if you separately opt in, account or promotional messages, as described in our Terms of Service. We use your mobile number only to deliver the messages you signed up for and to operate the messaging program; we do not sell or share your mobile number or SMS opt-in for third-party marketing. Message and data rates may apply, and frequency varies. You can text STOP to opt out at any time and HELP for help. See the SMS section of our Terms of Service for full program terms.

6. How We Share Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share information only as described below.

6.1 Service providers

We share information with vendors that operate the Service on our behalf, under contracts that limit them to using it only to provide services to us. We maintain the current list of these providers, what each one does, and what data is involved, on a dedicated Sub-processors page, so it can be kept up to date independently of this Policy.

6.2 Financial partners (only when you ask)

To provide access to cash advance, earned-wage-access (EWA) advance, personal loan, or similar product or service through the Service, and you have not opted out of partner sharing, we may share information with third party providers of such products and services to help identify offerings you may be eligible for.

What data we share. We share financial information that you provide us access to through your accounts with financial institutions and other third parties — such as income patterns, account balance trends, recurring payment history, and the advance amount you have requested — along with contact information necessary to complete the referral. We do not access, use or share consumer report data (credit bureau data) subject to the Fair Credit Reporting Act (FCRA) in this process.

What KeepYours does and does not do. We analyze the financial information that you provide us access to to try to identify financial products and services offered by third parties that you may be eligible for. We may make recommendations regarding such products and services based on our assessment of the estimated cost and qualifications. We do not make credit decisions, approve or deny you for any financial product or service, or determine creditworthiness. If you elect to apply for one of the third party financial products or services we identify, the third party offering that product or service will make its own independent determination of your eligibility using its own underwriting and other applicable criteria.

If a third party declines. A third party's decision to approve, deny, or modify the terms of a product or service is made independently by that third party, not by KeepYours. If a third party declines to offer you credit or otherwise takes adverse action on your application — whether based on its own underwriting or on a consumer report it obtains separately — that third party is responsible under applicable law for providing any required adverse action notice to you directly. KeepYours is not the source of any consumer report, and is not responsible for the adverse impact any application for credit with a third party you may choose to make has on your credit.

Referral fees. We may receive a referral fee when you connect with a third party provider of financial products or services.

Opt-out. You can opt out of partner sharing at any time in Settings. Once you opt out, we will not share your information with financial partners, and the matching feature will be unavailable. Opting out does not affect any other part of the Service.

6.3 Legal and safety

We may disclose information if required by law or valid legal process, or where we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, or to investigate fraud or security issues.

6.4 Business transfers

If we are involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. The recipient will be obligated to honor this Policy or notify you of any material change.

7. Your Privacy Choices

• Marketing emails — you may opt out anytime via the unsubscribe link or your in-app settings. Service messages are unaffected.
• SMS — you may text STOP to stop messages at any time.
• Financial-partner sharing — you may opt in or out anytime in your settings.

We record each choice with a timestamp so we keep an accurate record of your consent. We never require a fee, account closure, or any condition to honor an opt-out.

8. Cookies and Tracking

We use cookies and similar technologies that are necessary to run the Service (such as authentication/session cookies) and, with appropriate controls, to understand usage. We do not use third-party advertising cookies and do not allow third parties to track you across other websites for advertising through the Service. Our analytics providers may set first-party cookies to distinguish unique visitors. You can control cookies through your browser settings; disabling some cookies may affect how the Service works.

9. Your Privacy Rights

Subject to applicable law, we offer the following rights to all users, regardless of where you live:

• Know / access — request a copy of the personal information we hold about you, including categories, sources, purposes, and recipients.
• Delete — request deletion of your account and personal information.
• Correct — request correction of inaccurate information.
• Opt out of marketing — unsubscribe from marketing emails and stop SMS as described above.
• Opt out of partner sharing — toggle off in your settings.
• Non-discrimination — we will not deny service, charge a different price, or provide a different level of service because you exercised a privacy right.

To exercise a right, email legal@lbymlabs.com or use the controls in your account. We will verify your request (typically by confirming control of your account email) and respond within the time required by applicable law. You may use an authorized agent where the law allows.

9.1 California, Colorado, Virginia, and other state residents

Depending on your state, you may have additional rights, such as the right to opt out of "sale," "sharing," or targeted advertising (we do not engage in these), the right to limit use of sensitive personal information, the right to appeal a denied request, and the right to non-discrimination. To appeal a decision, reply to our response or email us with "Appeal" in the subject line.

10. Data Retention

We keep your account information for as long as your account is active. If you delete your account, we delete your personal information within 30 days, except where we must retain certain records to meet legal, regulatory, tax, security, or fraud-prevention obligations, or to resolve disputes and enforce our agreements. Transaction data synced from Plaid is retained to support year-over-year insights, unless you delete your account or revoke access to a Plaid linked account sooner. We retain consent records as needed for compliance. Where we retain information, we limit its use to the purposes that justify retention. Our payment processor, Stripe, maintains its own records of payment transactions as required by applicable financial regulations. These records are subject to Stripe's data retention policy and are not within our control to delete. If you have questions about data Stripe holds, please contact Stripe directly at stripe.com/privacy.

11. Security

We use administrative, technical, and physical safeguards designed to protect your information. Data is encrypted in transit (TLS) and at rest. Access tokens for linked accounts are encrypted before storage. We restrict access to personal information to people who need it to operate the Service. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we become aware of a breach affecting your information, we will notify you and regulators as required by law.

12. Children's Privacy

The Service is intended only for users 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact us and we will delete it.

13. International Users

The Service is operated in the United States and intended for U.S. residents. If you access it from outside the United States, you understand your information will be processed in the United States, where data-protection laws may differ from those in your location.

14. Changes to This Policy

We may update this Policy from time to time. When we do, we will update the "Last updated" date and, for material changes, notify you by email or in-app. Your continued use of the Service after the effective date means you accept the updated Policy.

15. Contact Us

LBYM Labs, Inc.
5000 Plaza on the Lake, Suite 100
Austin, TX 78746
Privacy: legal@lbymlabs.com
General: hello@keepyours.com