Privacy Policy

Last Modified: Nov. 1, 2025

Introduction

Opto Financial Inc. ("Opto" or "We") respect your privacy and are committed to protecting it through our compliance with this Privacy Statement.

This Privacy Statement describes the types of Personal Information we may collect from you or that you may provide when you visit the website or use our application (the "Application") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

"Personal Information" as used in this Statement means information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to a specific natural person. It does not include information that is considered anonymous, de-identified, or aggregated by applicable law.

This Privacy Statement applies to the information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Statement.
From financial institutions and other third-party data sources with whom you have a contractual relationship.

Please read this Privacy Statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or Application. By accessing or using this Website or Application, you agree to this Privacy Statement. This Privacy Statement may change from time to time. Your continued use of this Website or Application after we make changes is deemed to be acceptance of those changes, so please check the Privacy Statement periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information on the Website or the Application. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Website or the Application or through any of its features, register on the Website, make any purchases through the Website or the Application, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at contact@optofinancial.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website and Application, including information:

By which you may be personally identified, such as name, postal address, email address, telephone number, and birthdate ("Personal Information");
That is about you; and/or
About your internet connection, the equipment you use to access our Website or Application, and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the Website or Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, such as third-party data sources with whom you have a contractual relationship and from whom you authorize us to collect data.

Information You Provide to Us

The information we collect on or through our Website or Application may include:

Information that you provide by filling in forms on our Website or Application. This includes information provided at the time of registering to use our Website or Application, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website or Application.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website or Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or Application.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website or Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website or Application, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website or Application and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website or Application according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website or Application.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Opto, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

We do not collect Personal Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

To present our Website and Application and their contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account/subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or Application or any products or services we offer or provide through it.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to contact@optofinancial.com. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

To the extent permitted by applicable law, we also collect, create, process and store information that is not Personal Information such as sets of aggregate data and other de-identified Personal Information that does not reveal your identity. We retain the right to use and disclose information that is not Personal Information in any manner permitted by law.

Disclosure of Your Information

We may disclose Personal Information that we collect or you provide as described in this Privacy Statement:

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Opto's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Opto about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Opto, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Use of Third-Party AI Services

To provide personalized financial insights and categorization of your transactions, we may share certain financial data (such as transaction descriptions, amounts, merchant names, and account balances) with trusted third-party service providers that process data on our behalf.

In particular, we use OpenAI, LLC's application programming interface (API) to analyze transaction data and generate financial coaching insights. OpenAI acts as our service provider. For more details about OpenAI's API terms and practices, see OpenAI's Services Agreement at https://openai.com/policies/services-agreement/.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile, or by sending us an email stating your request to contact@optofinancial.com.

Promotional Offers from Opto. If you do not wish to have your contact information used by Opto to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the Website and adjusting your user preferences in your account profile or by sending us an email stating your request to contact@optofinancial.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Opto as a result of a product purchase, product service experience or other transactions.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by logging into the Website and adjusting your user preferences in your account profile. [For this opt-out to function, you must have your browser set to accept all browser cookies.]

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional Personal Information rights and choices. Please see sections below for more information.

Accessing and Correcting Your Information

You can review and change your Personal Information by logging into the Website or the Application and visiting your account profile page.

You may also send us an email at contact@optofinancial.com to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

Residents of certain states, such as California, Nevada, Colorado, Virginia, Connecticut and Utah may have additional Personal Information rights and choices. Please see the sections below for more information.

California & Other U.S. States Notice at Collection

Opto may collect the following categories of personal data.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, Privacy Statement, education, employment, bank account number, credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age, race, religion or creed, marital status, and gender.	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
K. Inferences drawn from other Personal Information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Sources: We receive information from sources as described in the "Information We Collect About You and How We Collect It" section.

Opto's business and commercial purposes for use: Opto uses personal data for the following business and commercial purposes: to provide Opto products and services; for product research and development; for marketing and promotions; authentication, integrity, security, and safety; to communicate with you; and for legal reasons. For more information, please see "Disclosure of Your Information".

Categories of third parties to whom we disclose Personal Information for business purposes are described in "Disclosure of Your Information".

Opto may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website or app which may constitute a "sale" or "sharing" of data for targeted advertising purposes under certain state privacy laws. See "California & Other U.S. State Privacy Rights" for more information regarding your right to opt-out.

Retention: Opto retains personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law or is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

Access the categories and specific pieces of personal data Opto has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Opto has shared personal data, and obtain the personal data in a portable and, to the extent technically feasible, readily usable format;
Delete personal data under certain circumstances;
Correct personal data under certain circumstances; and
Opt out of the "sale" of personal data or "sharing" of personal data for targeted advertising purposes. We do not sell your personal data in the conventional sense. However, like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our website or app, based on information obtained from cookies or other trackers, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). You can get more information and opt out of the use of cookies and other trackers on our website and app by clicking the Your Privacy Choices link, also on our homepage, and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings. California and Connecticut residents may also set the Global Privacy Control (GPC) to opt out of the "sale" or "sharing" of your Personal Information for targeted advertising for each participating browser system that you use. Opto does not have actual knowledge that it "sells" or "shares" the Personal Information of consumers under 18 years of age.
Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing contact@optofinancial.com.

Opto will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.

Sensitive Information. Opto receives information that may be considered sensitive under some state laws, such as certain Account Information (e.g., financial information, log-in information). Opto processes sensitive Personal Information to provide Opto products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. Opto does not use or disclose sensitive Personal Information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require Opto to provide a right to limit under the CCPA. Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual's information that would produce a legal or similarly significant effect. Opto does not engage in this type of profiling of individuals.

To exercise your rights, you can contact us using the contact details provided under the "Contact Information" heading below and submitting the required verifying information. To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the instructions above.

We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing Opto account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of Personal Information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

California's Shine the Light Law

California Civil Code Section 1798.83, also known as "Shine The Light" law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties' direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties' direct marketing purposes.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and related information will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website and Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website or Application. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website or Application.

Changes to Our Privacy Statement

It is our Privacy Statement to post any changes we make to our Privacy Statement on this page. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. The date the Privacy Statement was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Statement to check for any changes.

Contact Information

To ask questions or comment about this Privacy Statement and our privacy practices, contact us at:

contact@optofinancial.com

Opto Financial Inc, 8 The Green, Suite #16198, Dover, DE 19901.