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PRIVACY POLICY

Fomo-Fi - ACera Tech LLC 

Effective Date: 08/18/2026

Last Updated: 08/12/2026

1. SCOPE AND OVERVIEW

This Privacy Policy (this “Policy”) explains how ACera Tech LLC, doing business as Fomo-Fi (“Fomo-Fi,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information in connection with the Fomo-Fi website, web application, mobile applications, customer support, and related products and services (collectively, the “Service”).

This Policy applies when you visit, access, or use the Service, communicate with us, or otherwise provide personal information to us. It does not apply to information processed solely by a third party under that third party’s own privacy policy, except to the extent we receive that information from the third party.

This Policy is intended to provide notice of our information practices and should be read together with our Terms of Service. By accessing or using the Service, you acknowledge that you have reviewed this, Policy. If you do not want us to process your information as described in this Policy, do not use the Service or connect a financial account.

2. PERSONAL INFORMATION WE COLLECT

The personal information we collect depends on the features you use, the accounts you connect, the choices you make, and the permissions you grant.

2.1 Information You Provide Directly

Account and Profile Information. Your name, email address, account identifier, authentication selections, and profile settings. Passwords and third-party sign-on credentials are processed through our authentication provider, Clerk, as described below.

Financial Planning Information. Income amounts and frequency, pay schedules, budget preferences, savings goals, target allocations, custom transaction-categorization rules, and other information you enter to configure the Service.

Debt and Liability Information. Balances, interest rates, minimum payments, payment due dates, payment frequency, liability types, and related assumptions you enter into debt-planning tools.

Communications. Information you provide in support requests, feedback, surveys, inquiries, or other communications with us.

Subscription and Billing Information. Your selected plan, subscription status, purchase and cancellation dates, invoices, and limited payment-related information made available to us by Stripe or an applicable app store, such as card brand, last four digits, and payment status. We do not receive or store full payment card numbers.

2.2 Information from Connected Financial Accounts

If you choose to connect a bank or other financial account, we use Plaid Inc. (“Plaid”) to facilitate the connection. The Plaid interface will identify the accounts and data you authorize Plaid to obtain and share with Fomo-Fi. Depending on the account, institution, Plaid product, and permissions you select, we may receive account names and types, masked account identifiers, balances, transaction dates, amounts, merchant or payee information, transaction descriptions and categories, recurring transaction patterns, liability information, and historical transaction data made available through the connection. The exact scope and historical period may vary by institution and account.

Fomo-Fi does not receive or store the login credentials you submit to your financial institution through Plaid. Plaid’s independent collection and use of information are governed by the Plaid End User Privacy Policy. You should review the permissions shown in Plaid before connecting an account.

2.3 Information Collected Automatically

Device and Network Information. Internet Protocol address, browser type, device type, operating system, screen or display information, language, application version, device or browser identifiers, and similar technical information.

Usage Information. Dates and times of access, features and screens used, interactions, session duration, referral information, and other information about how you use the Service.

Logs and Diagnostics. Authentication events, security logs, application errors, crash information, performance metrics, and diagnostic events, including information processed through monitoring and error-tracking providers such as Sentry.

Notification Information. Push-notification tokens and related delivery information if you enable notifications on your device.

Cookies and Similar Technologies. Session cookies, local storage, software development kits, and similar technologies used for authentication, security, preferences, analytics, and Service operation, as further described in Section 5.

2.4 Information from Service Providers and Other Sources

We may receive information from providers that support the Service, including Plaid, Clerk, Stripe, mobile app stores, hosting and database providers, customer-support providers, communications providers, security and fraud-prevention providers, and analytics or error-monitoring providers. We may also receive information from your financial institution or another third party when you direct or authorize that party to provide information to us.

2.5 Information We Derive

We derive information from the data described above, including transaction categories, recurring obligations, budget allocations, projected cash flow, debt-payoff schedules, alerts, and other calculations, patterns, or inferences used to provide the Service.

2.6 Categories of Personal Information

For purposes of U.S. state privacy laws, the categories below describe personal information that we collect and have collected during the preceding twelve (12) months, depending on how a person uses the Service:

Identifiers and account information, such as name, email address, user or device identifiers, IP address, and masked financial-account identifiers.

Customer-record and financial information, such as financial-account details, balances, transactions, income, debts, budget preferences, and limited billing information.

Commercial and subscription information, such as the subscription plan selected, purchase history, billing status, and interactions with the Service.

Internet or other electronic-network activity, such as device, browser, session, usage, security, and diagnostic information.

Inferences, such as recurring-payment patterns, transaction categories, budget allocations, forecasts, and debt-payoff calculations.

Communications and support information, such as the content of messages you send to us and records of our responses.

Sensitive personal information, such as connected financial-account information and access tokens, to the extent classified as sensitive under applicable law. Financial-institution credentials submitted through Plaid are handled by Plaid and are not received or stored by Fomo-Fi.

We collect these categories from you, your device or browser, connected financial institutions through Plaid at your direction, and the service providers described in this Policy. We use them for the purposes in Section 3 and disclose them to the recipient categories in Section 4. We do not knowingly collect biometric information, precise geolocation, government-issued identification numbers, or protected-class characteristics through the ordinary operation of the Service.

3. HOW WE USE PERSONAL INFORMATION

Provide the Service. Create and maintain accounts; connect financial accounts; import, normalize, categorize, and display financial data; calculate budgets, forecasts, and debt-payoff schedules; provide calendars, alerts, and other requested features; and process subscriptions.

Personalize the Service. Apply your settings, preferences, classifications, and goals and present information relevant to your use of the Service.

Operate and Support the Service. Authenticate users, administer accounts, respond to inquiries, troubleshoot issues, send administrative messages, and provide customer support.

Protect Users and the Service. Detect, investigate, and prevent fraud, abuse, unauthorized access, security incidents, and violations of our Terms of Service.

Analyze and Improve. Monitor performance, evaluate feature usage, fix defects, develop and test improvements, and understand the operation of the Service.

Communicate. Send transactional, security, subscription, support, and Service-related communications, and send optional marketing communications where permitted by law and subject to your choices.

Comply with Law and Protect Rights. Meet legal, tax, accounting, recordkeeping, and regulatory obligations; respond to lawful process; establish, exercise, or defend legal claims; and protect our rights, users, personnel, and others.

3.1 Automated Processing and Artificial Intelligence

The Service uses automated rules, models, and calculations to categorize transactions, identify patterns, prepare forecasts, and generate other budgeting outputs. These functions do not make decisions about your eligibility for credit, lending, insurance, employment, housing, or legal rights.

Fomo-Fi does not sell connected financial information, use it for cross-context behavioral advertising, or submit it to third-party general-purpose artificial-intelligence models for training. Our service providers may process information to provide, secure, support, or improve their services under their agreements with us, and certain providers, including Plaid, may also process information independently under their own privacy policies. We do not control a provider’s independent processing.

3.2 Aggregated and De-Identified Information

We may aggregate or de-identify information so that it cannot reasonably be linked to you and use or disclose that information for lawful purposes, including analytics, security, research, and Service improvement. Where required by law, we will maintain de-identified information in de-identified form and will not attempt to re-identify it except to test whether our de-identification processes are effective.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information in the following circumstances:

Service Providers and Contractors. To providers that perform services for us or help operate the Service, including Plaid for financial connectivity; Clerk for authentication and account management; Stripe and app stores for billing; cloud-hosting and database providers; Sentry and similar analytics, monitoring, and error-tracking providers; communications and notification providers; customer-support providers; and security, fraud-prevention, professional, and technical service providers. We disclose only information reasonably necessary for the relevant service, subject to contractual restrictions where the provider acts on our behalf.

At Your Direction. To financial institutions, Plaid, or other third parties when you request a connection, transaction, disclosure, or other action, or when you otherwise consent to the disclosure.

Legal and Safety Purposes. To courts, regulators, law-enforcement agencies, government authorities, adverse parties, or others when we reasonably believe disclosure is required or permitted by law, necessary to respond to lawful process, or appropriate to protect rights, property, safety, users, the Service, or the public.

Professional Advisers and Insurers. To lawyers, auditors, accountants, consultants, banks, and insurers subject to appropriate professional or contractual duties.

Affiliates. To a parent, subsidiary, or other entity under common control, if any, for purposes consistent with this Policy.

Business Transactions. In connection with an actual or proposed financing, merger, acquisition, reorganization, bankruptcy, sale of assets, or similar transaction, subject to customary confidentiality protections where appropriate.

Aggregated or De-Identified Information. In a form that cannot reasonably be linked to you, as described in Section 3.2.

We do not sell personal information for money, and we do not share personal information for cross-context behavioral advertising. We have not done so during the preceding twelve (12) months. We do not disclose nonpublic personal financial information about current or former users to nonaffiliated third parties for those third parties’ own marketing purposes, and we do not knowingly sell or share personal information of anyone under sixteen (16) years of age.

5. COOKIES, TRACKING TECHNOLOGIES, AND COMMUNICATION CHOICES

5.1 Cookies and Similar Technologies

We and providers working on our behalf may use cookies, local storage, software development kits, pixels, and similar technologies for authentication, security, preferences, diagnostics, analytics, and Service operation. These providers may collect information about activity on the Service over time as necessary to provide their functions. We do not permit third-party advertising partners to use the Service to collect personal information across unaffiliated websites or applications for targeted advertising.

5.2 Do Not Track and Global Privacy Control

Some browsers offer a “Do Not Track” setting. Because there is no uniform industry standard for interpreting that signal, the Service does not currently respond to Do Not Track signals. This does not change our statement that we do not sell personal information or share it for cross-context behavioral advertising. If our practices change in a manner that requires us to honor an opt-out preference signal, such as Global Privacy Control, we will do so as required by applicable law.

5.3 Email and Push Notifications

You may unsubscribe from marketing emails using the link in the message. You will continue to receive non-promotional communications necessary to administer your account or subscription. You may disable push notifications through your device settings; disabling notifications may prevent delivery of alerts you configured in the Service.

6. DATA RETENTION, DISCONNECTION, AND DELETION

We retain personal information for as long as reasonably necessary to provide the Service, maintain your account, complete the purposes described in this Policy, comply with legal and contractual obligations, resolve disputes, enforce agreements, maintain security, and protect against fraud or abuse. Retention periods vary based on the type of information, the sensitivity of the information, the purpose for which it is processed, and applicable legal requirements.

Subscription Cancellation. Canceling a paid subscription stops future renewal charges but does not necessarily delete your account or information. To delete your account, use the account-deletion function if available or submit a deletion request under Section 9.

Financial-Account Disconnection. Disconnecting a financial institution stops future retrieval through that connection but may not delete information already imported into the Service. You may separately request deletion of previously imported information, subject to applicable exceptions.

Account Deletion. After a verified account-deletion request, we will delete or de-identify personal information within a reasonable period, subject to legal, security, fraud-prevention, dispute, tax, accounting, and other permitted retention needs. We will revoke or delete connected-account access tokens under our control when the related connection or account is deleted.

Backups and Provider Records. Residual copies may remain in encrypted or access-restricted backups until overwritten in the ordinary course. Payment processors, app stores, Plaid, financial institutions, and other independent providers may retain information under their own policies and legal obligations.

7. DATA SECURITY

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, loss, or disclosure. Depending on the system and information involved, safeguards may include encryption in transit and at rest, access controls, authentication protections, logging, monitoring, vulnerability management, incident-response procedures, and service-provider oversight.

No method of transmission, storage, or security is completely secure, and we cannot guarantee absolute security. You are responsible for using a strong, unique password, protecting your credentials and devices, and promptly notifying us at support@fomo-fi.app if you suspect unauthorized access. If a security incident requires notice under applicable law, we will provide notice in the manner and within the time required by law.

8. YOUR ACCOUNT CONTROLS

Profile and Preferences. You may review and update available profile fields, settings, financial-planning inputs, categories, and notification preferences through the Service.

Connected Accounts. You may disconnect a linked financial institution through the Service where that function is available. You may also manage eligible Plaid connections through Plaid’s consumer tools.

Subscription. You may cancel recurring billing using the cancellation method associated with your purchase, as described in the Terms of Service. Uninstalling the application or disconnecting a financial account does not cancel a subscription.

Account Deletion. You may request deletion through the Service, if available, or by emailing support@fomo-fi.app. Deletion is subject to Section 6 and may be irreversible.

9. U.S. STATE PRIVACY RIGHTS

Depending on where you reside and whether an applicable privacy law covers Fomo-Fi or the information at issue, you may have rights to:

Confirm whether we process your personal information and access that information.

Correct inaccuracies in your personal information.

Delete personal information, subject to exceptions.

Obtain a portable copy of certain personal information.

Opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, or certain profiling.

Limit certain uses and disclosures of sensitive personal information.

Appeal a decision concerning a privacy request.

Receive equal service and not be discriminated against for exercising applicable privacy rights.

We do not currently sell personal information, share it for cross-context behavioral advertising, use it for targeted advertising, or use it to make decisions producing legal or similarly significant effects. We use sensitive financial information only for purposes reasonably expected to provide, secure, and administer the Service and for other purposes permitted by law.

9.1 Submitting a Request

You may submit a request through an available in-app privacy control or by emailing support@fomo-fi.app. Please describe your request and provide the email address associated with your account. We may ask for information reasonably necessary to verify your identity and authority. We will use verification information only for verification, fraud prevention, and compliance. If we cannot verify a request, we may deny it as permitted by law.

An authorized agent may submit a request where permitted by law. We may require proof of the agent’s authority and may ask you to confirm the request directly. We will respond within the period required by applicable law. If we deny an appealable request, you may appeal by emailing support@fomo-fi.app with the subject line “Privacy Appeal” and explaining the basis for your appeal. We will decide the appeal within the period required by applicable law.

9.2 California Disclosures

If and to the extent the California Consumer Privacy Act applies, the categories of personal information collected during the preceding twelve (12) months are described in Section 2.6; the sources are described in Section 2; the business and commercial purposes are described in Section 3; and the categories of recipients to whom information is disclosed for business purposes are described in Section 4. During the preceding twelve (12) months, we have disclosed the categories described in Section 2.6 to service providers and other recipient categories described in Section 4 for the stated business purposes. We have not sold or shared personal information as those terms are defined by California law, and we have no actual knowledge that we sell or share the personal information of consumers under sixteen (16). We do not use or disclose sensitive personal information for purposes that require a right to limit under California law.

California’s “Shine the Light” law may permit residents to request information regarding disclosures of personal information to third parties for their own direct-marketing purposes. We do not make such disclosures.

9.3 Exempt Information

Privacy rights may not apply to information or entities exempt from an applicable state privacy law, including information governed by the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, or another sector-specific law. We will process non-exempt information in accordance with applicable requirements.

10. FINANCIAL INFORMATION PRACTICES

To the extent federal or state financial privacy laws apply to Fomo-Fi or particular information, this Section supplements the other disclosures in this Policy. We collect the financial-information categories described in Section 2 to provide budgeting and forecasting tools. We disclose that information only to service providers and other parties as described in Section 4, including to process and service transactions or requested products, maintain and secure accounts, prevent fraud, comply with law, and act at your direction. We do not disclose nonpublic personal information about current or former users to nonaffiliated third parties for those third parties’ own marketing. Based on our current practices, we do not make disclosures that require an opt-out under federal financial privacy law. If those practices change, we will provide any notice and choice required by law.

11. THIRD-PARTY SERVICES AND LINKS

The Service relies on or may link to services operated by third parties. Their privacy practices may differ from ours, and this Policy does not govern information they process independently. You should review the applicable provider policies, including the Plaid End User Privacy Policy, Clerk Privacy Policy, and Stripe Privacy Policy.

12. CHILDREN AND ELIGIBILITY

The Service is intended only for U.S. residents who are at least eighteen (18) years old. It is not directed to children or minors, and we do not knowingly collect personal information from anyone under eighteen (18). If you believe a minor has provided personal information to us, contact support@fomo-fi.app. After appropriate verification, we will take reasonable steps to delete the information.

13. U.S. PROCESSING

The Service is offered to U.S. residents. Personal information may be processed in the United States and in other jurisdictions where our service providers operate. Those jurisdictions may have different data-protection laws than your state of residence.

14. CHANGES TO THIS POLICY

We may update this Policy to reflect changes in the Service, our practices, technology, or applicable law. We will post the revised Policy and update the “Last Updated” date. If a change is material, we will provide additional notice through the Service, by email, or by another legally required method before the change takes effect. Unless otherwise stated, the revised Policy applies prospectively from its effective date.

15. CONTACT US

For questions, privacy requests, or concerns about this Policy, contact:

ACera Tech LLC d/b/a Fomo-Fi

Attention: Legal and Privacy

Email: support@fomo-fi.app

Website: https://www.fomo-fi.app

Mailing Address: 38 S. Forge Manor Dr., Phoenixville, PA 19460