Privacy Policy

ATHENA PRIVACY POLICY

Athena AI Holdings Inc., its service providers, contractors, agents, successors, assigns, and other third parties acting on our behalf (“Athena”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy (“Policy”) explains how we collect, use, disclose, and safeguard Personal Information when you use our websites, mobile apps, products, and online or offline services (collectively, the “Services”). “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

1. Scope

This Policy applies to Personal Information we process as a business in connection with the Services. Additional notices may apply to certain products (for example, our Gramm-Leach-Bliley Act (GLBA) financial privacy notice) and will be provided where relevant.

2. Notice at Collection

We collect Personal Information (e.g., identifiers, financial account and transaction information, internet activity, geolocation) to operate our sites and mobile app; to open, service, and secure your accounts; to onboard you to deposit and payment services and verify your identity; to monitor transactions for fraud, security, and legal-compliance purposes; to service your debit card; for analytics; and (if enabled) for targeted advertising. We retain Personal Information for as long as needed to provide the Services. See the “Your Privacy Rights” section to opt out of sale/sharing or targeted ads and to submit access/deletion/correction requests.

3. Information We Collect

We may collect the following categories of Personal Information: identifiers (e.g., name, postal address, email address, phone number, government ID where permitted); account information (e.g., username, credentials, settings, preferences); financial information (e.g., income, assets, liabilities, deposit-account balances and transactions, and bank account details you choose to share); commercial information (e.g., records of products or services considered or purchased); internet or network activity (e.g., log files, device identifiers, cookies, analytics data); communications (e.g., messages, call recordings with notice and consent); inferences drawn from the information above to create profiles reflecting preferences or characteristics; and sensitive information where required for the Services and permitted by law (e.g., SSN, credit data; handled under GLBA/FCRA where applicable).

Sources of Information. We collect your personal information, for example, when you open or use a deposit account or debit card, apply for a loan, or provide account, income, or employment information; when we verify your identity and onboard you to deposit and payment services; when we monitor and service your transactions; and when you interact with us through cookies, SDKs, and similar technologies. We also collect information from service providers and partners (e.g., identity, income, and credit bureaus with your authorization) and from public sources and anti-fraud databases where permitted. We may also collect information from other third parties, such as advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, data brokers, and other third parties as appropriate to further our legitimate business purposes unless otherwise prohibited by applicable law.

4. How We Use Personal Information

We use personal information to: provide, maintain, and improve the Services; process applications, verify identity, assess eligibility, and service accounts; detect, prevent, and investigate fraud, security incidents, and abuse; comply with law, industry standards, and contractual obligations; communicate with you about your account and the Services; personalize content and measure engagement; conduct research, analytics, and product development; and facilitate marketing with your consent where required (you may opt out at any time). We may also use personal information to perform compliance audits, to engage in debugging activities, and to further any of our other legitimate business and commercial purposes unless otherwise prohibited by applicable law.

5. How We Disclose Personal Information

We may disclose Personal Information with: service providers who perform services on our behalf under contracts that restrict use of the information; financial partners and other entities necessary to provide the Services at your request; credit, identity, or fraud-prevention agencies where you authorize or as permitted by law; legal and compliance recipients to comply with applicable law, regulation, legal process, or government request, to enforce our terms, or protect rights, privacy, safety, or property; and business transfers in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy’s protections. We may also disclose Personal Information with other third parties, such as advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, data brokers, and other third parties as appropriate to further our legitimate business purposes unless otherwise prohibited by applicable law.

Third-party data and verification providers. To deliver our deposit, payment, and onboarding services, we work with third-party data, identity, and account-verification providers. Depending on the features you use, we may share Personal Information with these providers so they can verify your identity and phone or device; link and verify your external financial accounts and retrieve account and transaction information you authorize; verify your income or employment and, at your direction, connect or update your direct deposit; and retrieve and verify account and loan or liability information (for example, an outstanding balance or payoff amount) in connection with payments you make through the Services. The categories of information shared may include your identifiers, contact details, financial account and transaction information, and income or employment information, as applicable to the service you use. Some of these providers use the information only to perform services for us; others act as independent parties that also collect information directly from you and process it under their own privacy policies, which we encourage you to review.

We may allow other parties to collect Personal Information about your online activities over time and across different websites when you use the Services.

6. How We Protect Your Information

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable federal or state laws and regulations. These measures include computer safeguards and secured files and buildings. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. However, no internet transmission is ever fully secure, and we cannot guarantee absolute security.

7. How Long We Keep Your Information

We keep your Personal Information for as long as your account is open and for as long as needed to provide the Services, and afterward in accordance with our record retention schedule. How long we retain information depends on the type of information and the purpose for which we hold it, including our need to comply with legal, regulatory, tax, recordkeeping, and audit obligations, resolve disputes, enforce our agreements, and detect and prevent fraud. Where applicable law or regulation requires us to retain certain records — such as records of your accounts, transactions, and the consents and authorizations you provide — for a minimum period, we retain them for at least that period, and we retain other information only for as long as it is needed for the purposes described in this Policy. When information is no longer needed, we securely destroy, delete, or de-identify it.

For deidentified information, we will take reasonable measures to ensure that the information cannot be associated with an individual, and we publicly commit to maintain and use the information in deidentified form and not to attempt to reidentify the information. We will contractually obligate any recipients of the information to comply with these deidentification provisions.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights: Right to Access (request to know what personal information we have collected about you); Right to Delete (request deletion of your personal information); Right to Correct (request correction of inaccurate personal information); Right to Opt-Out (opt out of sale of personal information or targeted advertising); Right to Portability (receive your personal information in a portable format); Right to Limit the Use and Disclosure of Sensitive Personal Information; the Right to Opt-Out, Access, or Appeal Automated Decisionmaking Technology; and the Right to Question Profiling Results, Be Informed of Profiling Reasoning, Be Informed of Actions to Secure a Different Decision, Review Personal Information Used in Profiling, and Have Profiling Decisions Reevaluated Based on Correct Information; and the Right to Appeal Responses to Privacy Requests.

Universal Opt-Out Mechanism. We honor the Global Privacy Control (GPC) and other universal opt-out preference signals recognized by applicable state law. We will recognize new mechanisms within six months of their official listing. We do not respond to Do Not Track signals.

Exercising Your Rights. To exercise your privacy rights, email us at privacy@athenamoney.co or call 877-687-0111. In your request, please provide us with your name, address, and last four digits of your Social Security number, which we will match against our business records to verify your identity before responding to any privacy requests. You may also need to complete our required multifactor authentication process. An authorized agent or a parent / legal guardian may submit a privacy request by following these same instructions, but rather than completing the multifactor authentication process, we may require appropriate documentation of authority to submit such requests.

We will not discriminate or retaliate against you for exercising any of your privacy rights.

9. Do Not Sell or Share My Personal Information

You have the right to opt out of the sale or sharing (as such term is defined under applicable law as cross-context behavioral advertising) of your Personal Information. To opt out, email privacy@athenamoney.co with the subject line “Do Not Sell or Share My Personal Information”.

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We do not collect, use, or sell Personal Information for the purpose of training large language models.

10. Children’s Personal Information

The Services are intended for adults and are not directed to children under the age of 13 years, and we do not knowingly collect, use, or share personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete and dispose of that information promptly using secure methods. If you believe a child under 13 has provided us personal information, contact us at privacy@athenamoney.co so we can take appropriate action.

We have no actual knowledge of any sales or sharing of the Personal Information of consumers under 16 years of age.

Contact Us

Athena AI Holdings Inc. 11 Carlisle Street, Suite 303, Hanover, PA 17331 privacy@athenamoney.co

For accessibility requests: accessibility@athenamoney.co