Wealth Rewards

Privacy Policy

1. Introduction

Wealth Rewards, Inc. ("Wealth Rewards," "we," "us," or "our") operates the Wealth Rewards mobile and web application (the "App"). We are committed to protecting your privacy and handling your personal information with transparency and care.

This Privacy Policy explains what information we collect when you use the App, how we use and share that information, your rights regarding your information, and how to contact us with questions or requests.

By creating an account or using the App, you agree to the collection and use of your information as described in this Privacy Policy. If you do not agree, please do not use the App.

[NOTE: Confirm effective date and publication mechanism before finalizing. Verify consent capture mechanic complies with E-SIGN and applicable state requirements.]

 

2. Information We Collect

2.1 Information You Provide

When you create an account or use the App, you provide us with:

  • Identity information: Full name, email address, phone number, and date of birth;

  • Government-issued identification: When required for identity verification (KYC) under applicable law, we collect and verify a government-issued ID through our identity verification partner, Persona. This data is held by Persona; we do not store copies of your identification documents in our primary database;

  • Financial account information: When you connect a bank account, you do so through Plaid, our bank account linking partner. Wealth Rewards does not receive or store your bank login credentials. Plaid provides us with a secure token representing your bank account link, and we receive transaction data and account balance information necessary to operate the App;

  • Payment information: If you add a payment card, the card number is processed and tokenized by Stripe. Wealth Rewards never receives or stores your raw card number or CVV; and

  • Communications: Messages you send to our customer support team.

2.2 Information Collected Automatically

When you use the App, we automatically collect:

  • Device information: Device type, operating system, unique device identifiers, and app version;

  • Usage data: Features used, screens viewed, button taps, and in-app actions (collected via our analytics provider, PostHog, using anonymized identifiers where possible);

  • Log data: IP address, timestamps, error logs, and diagnostic information; and

  • Location: General location inferred from IP address. We do not collect precise GPS location.

2.3 Information from Third-Party Partners

We receive information from our licensed partners to operate the App:

  • From Plaid: Bank account balance data, transaction history, and account metadata for bank accounts you connect to the App. This information is used solely to provide you with App features (tracking rewards, calculating savings) and is not used to train AI or machine learning models;

  • From Stripe: Payment processing confirmations, payout status, and Connected Account status for your Wealth Rewards wallet; and

  • From Persona: Confirmation that your identity has been verified and your OFAC screening status. We do not store underlying identity document data in our own systems.

 

3. How We Use Your Information

We use your personal information for the following purposes:

  • Operating the App: Processing transactions, issuing and redeeming rewards, maintaining your account, and providing customer support;

  • Identity verification and compliance: Verifying your identity as required by anti-money laundering (AML) and Know Your Customer (KYC) laws, screening against government watchlists (OFAC), and complying with other legal obligations;

  • Security: Detecting and preventing fraud, unauthorized access, and other malicious activity;

  • Communications: Sending you transaction confirmations, security alerts, and service updates. We will send you marketing communications only with your explicit consent, and you may withdraw consent at any time;

  • Improving the App: Analyzing anonymized usage patterns to improve App features and user experience; and

  • Legal compliance: Complying with applicable laws, regulations, court orders, and regulatory requests.

We do not use your Plaid-sourced bank transaction data to train any artificial intelligence or machine learning model.

 

4. How We Share Your Information

We share your personal information only in the following circumstances:

4.1 With Service Providers

We share information with trusted service providers who process data on our behalf and are contractually required to protect it:

  • Stripe (payment processing and banking infrastructure): [PARTNER LINK]

  • Plaid (bank account linking and transaction data): [PARTNER LINK]

  • Persona (identity verification and KYC): [PARTNER LINK]

  • PostHog (product analytics — anonymized data only)

  • Cloud infrastructure providers (AWS/GCP) for hosting and data storage

4.2 With Referral Partners

With your consent, we may share limited information with licensed financial service partners (currently Charles Schwab for brokerage referrals and Ethos Life / Allianz for insurance referrals) to facilitate referrals you initiate within the App. We share only the minimum information necessary and do not sell your data to these partners.

4.3 For Legal Compliance

We may disclose your information when required to do so by law, including in response to a lawful subpoena, court order, government agency request, or to comply with reporting obligations under the Bank Secrecy Act (e.g., Suspicious Activity Reports or Currency Transaction Reports).

4.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of WRA's assets, your personal information may be transferred as part of that transaction. We will provide notice before your information is subject to a materially different privacy policy.

WE DO NOT SELL, RENT, OR LICENSE YOUR PERSONAL INFORMATION TO ANY THIRD PARTY FOR THEIR OWN COMMERCIAL OR MARKETING PURPOSES.

 

5. Data Retention

We retain your personal information for the period necessary to provide the App's services, satisfy our legal and regulatory obligations, resolve disputes, and enforce our agreements. Detailed retention periods are set forth in our Data Retention and Disposal Policy. In general:

  • Account and identity data: Retained for the duration of your account plus five (5) years after account closure, as required by applicable financial regulations;

  • Transaction records: Retained for five (5) years from the transaction date;

  • Plaid transaction data: Retained for twelve (12) months from the date the data was pulled, unless required for an active dispute; and

  • Marketing preferences and consent records: Retained for five (5) years.

When data is deleted, we use cryptographic erasure and secure deletion methods to ensure it cannot be recovered.

 

6. Security

We take the security of your personal information seriously. Our security program includes:

  • Encryption of all personal and financial data in transit (TLS 1.2+) and at rest (AES-256);

  • Multi-factor authentication for all accounts;

  • Role-based access controls limiting employee access to only the information needed for their role;

  • Regular security assessments and penetration testing; and

  • A documented Incident Response Plan.

No security system is impenetrable. In the event of a security breach affecting your personal information, we will notify you as required by applicable law.

 

7. Your Privacy Rights

7.1 Rights Available to All U.S. Users

  • Access: You may request a copy of the personal information we hold about you;

  • Correction: You may request correction of inaccurate personal information; and

  • Deletion: You may request deletion of your personal information, subject to our legal retention obligations (see Section 5).

7.2 California Residents (CCPA/CPRA)

California residents have the following additional rights:

  • Right to Know: The categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties with whom we share it;

  • Right to Opt-Out of Sale or Sharing: We do not sell or share personal information as defined under CCPA. No opt-out is needed, but you may submit a request to confirm our non-sale practices;

  • Right to Limit Sensitive Personal Information Use: You may direct us to limit our use of sensitive personal information to the uses necessary to provide the App;

  • Right to Non-Discrimination: We will not deny you service, charge different prices, or provide a different level of service based on your exercise of privacy rights; and

  • Right to Correct: You may request correction of inaccurate personal information we hold about you.

7.3 Additional State Rights

Residents of Colorado, Connecticut, Virginia, Texas, and other states with applicable privacy laws have rights including access, correction, deletion, and portability of personal information. To exercise any of these rights, contact us using the information in Section 10.

7.4 How to Submit a Request

To submit a privacy rights request, email privacy@mywealthrewards.com with your full name, email address associated with your account, and the specific right you wish to exercise. We will verify your identity before processing your request and respond within 45 days (or as required by applicable law).

 

8. Children's Privacy

The Wealth Rewards App is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will delete it promptly. If you believe a minor has provided us with their information, please contact us at privacy@mywealthrewards.com.

 

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy in the App and, where required by law, by direct notification to the email address associated with your account. Your continued use of the App after the effective date of a revised Policy constitutes acceptance of the updated Policy.

 

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

  • Email: privacy@mywealthrewards.com

  • Mailing Address: Wealth Rewards, Inc., 9961 Interstate Commerce Drive, Suite 160, Fort Myers FL 33913, United States