Privacy Policy

Last updated: October 7, 2026

This Privacy Policy explains how Pilot Wealth collects, uses, stores, and protects personal information.

1. Introduction

This Privacy Policy explains how Pilot Wealth ("we", "us", "our"), operated by Pilot Wealth, collects, uses, stores, and protects your personal information.

By using our service, you consent to the collection and use of information in accordance with this Privacy Policy.

This Privacy Policy complies with the Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial and territorial privacy legislation, and other Canadian privacy laws.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use our service, we may collect:

• Account Information: Name, email address, username
• Profile Data: Account preferences, settings, profile photo
• Financial Inputs: Budgets, income data, expenses, transaction descriptions, financial goals, investment holdings, and the stocks on your Stock Tracker watchlist (entered by you voluntarily)
• Communications: Messages you send us, support requests, feedback

2.2 Automatically Collected Information

When you use our service, we automatically collect:

• Device Information: Device type, operating system, browser type and version
• Usage Data: Features used, pages visited, time spent, click patterns
• Technical Data: IP address, timestamps, error logs, performance metrics
• Cookies: Session identifiers, authentication tokens, preferences (see 11. Cookies and Tracking Technologies)

This data helps us improve security, detect abuse, and enhance user experience.

2.3 AI Interaction Data

When you use AI-powered features, such as financial advisor and analysis tools:

• Your prompts and questions sent to the AI are processed
• So the AI can answer with your real numbers, most messages also carry a summary of your Pilot Wealth data: account names and balances, debts, income sources, assets, stock holdings, your budget, the names and amounts of your bills and subscriptions (including those still to come this month), repeat charges found in your bank history that are not yet a bill, your spending by category and pace for the month, how that spending was categorized (how many transactions and how many dollars got their category from your bank, a keyword rule, our categorizer model, or you, and how many still need review), and your 25 most recent transactions with their descriptions and amounts. On paid plans the summary also carries your Pilot Score and the seven parts it is built from, each with its points and the main figure behind them (for example, months of emergency savings) and, for five of the seven, a short status word such as "Good". The two parts that measure net worth carry no status word, because those words compare your net worth with people your age and your age is never sent. Simple general questions, such as asking what a TFSA is, are sent without this summary. The summary does not include your name, email address, user ID, province, or age. A transaction description that looks like a person-to-person transfer, such as an Interac e-Transfer memo, is replaced with a neutral label before it is sent, because it can name someone else; its date, amount, and category are still included
• The most recent messages of your conversation are sent along with each new message so the AI can follow it
• We have asked xAI not to keep your requests or its responses. With that setting on, xAI processes each request and does not store it, and states that it does not use this data to train its models without permission
• AI-generated responses are logged temporarily
• Token usage is tracked for plan enforcement and billing
• Your conversation history is stored, encrypted, so the chat is there when you return. Each saved reply also keeps the sources, chart, and links it showed, as described in section 2.8. If you rate a reply, we may read it, also as described in section 2.8

2.4 Bank Connection Data (via Plaid)

If you use our PRO or PREMIUM features to connect bank accounts, we use Plaid Inc. to establish that connection. Before Plaid Link opens, you are asked to check a box authorizing this; we record the date and version of that authorization.

• Plaid securely handles your bank credentials. We never see or store them.
• From Plaid we receive account balances, transaction history, and account names, and on the PREMIUM plan your investment holdings.
• For credit cards, lines of credit, loans, and mortgages, we also receive the minimum payment, interest rate or APR, and next payment due date wherever your bank reports them. We do not store other liability details Plaid may provide, such as statement history, loan servicer details, or a mortgage's property address.
• Balances and the details above refresh automatically when your bank reports a change through Plaid, as well as whenever you choose to sync.
• Plaid itself will access, transfer, store, and use your financial data in accordance with the Plaid End User Privacy Policy.
• Data is encrypted in transit and at rest, and Plaid access tokens are additionally encrypted at the application layer.
• You can disconnect an account at any time. When you do, or when you delete your account, we call Plaid to revoke the connection before deleting the stored token.

Plaid's own privacy policy for end users applies to the data Plaid processes: https://plaid.com/legal/#end-user-privacy-policy

2.5 Province and Age

During setup, and later in Settings, we ask for your province or territory and your age. Both questions are optional, and you can answer "Prefer not to say" to either one. We store your age as a birth year calculated from the age you enter, so it stays current over time. Both values are encrypted in our database with a key used for nothing else.

• Your province is used to fill in the province on new income sources, which sets the starting point for your tax estimate. You can still change it on each income source.
• Your age is used by Pilot Score to compare your net worth with published benchmarks for people your age, based on Statistics Canada data and a widely used savings guideline. Without an age, Pilot Score uses the same benchmark for everyone.
• Neither value is shown to other members, sold, shared with third parties, or used for advertising.

You can change or clear either answer in Settings at any time. Both are included in your data export and are deleted when you delete your account.

2.6 Stock Tracker and Watchlist

Stock Tracker is part of the PREMIUM plan. If you use it, we store the tickers you add to your watchlist, which are stocks and funds you follow without owning, along with the date you added each one. A watchlist can hold up to 25 tickers.

• To show prices, we look up every ticker you hold or watch from Yahoo Finance, and we convert prices listed in other currencies to Canadian dollars using the Bank of Canada's daily exchange rates. These lookups come from our servers and contain only a ticker symbol or a currency code. They do not include your name, email address, or user ID, so neither provider can tell which member a lookup is for.
• If stock alerts are on, we send you a single email that lists every stock you hold or watch that moved by at least the percentage you chose (2, 3, 5, or 10) in their latest trading session. The email shows each stock's name, price, and daily move, and your overall return on any stock you hold. It is sent through our email provider, Resend.
• To run those alerts, we store your chosen percentage and, for each stock, the trading day we last emailed you about it, so the same day's move is not sent twice.

You can turn stock alerts off, change how often they are sent, or change the percentage in Settings at any time. Your watchlist and alert settings are included in your data export and are deleted when you delete your account. They are not shown to other members, sold, or used for advertising.

2.7 Repeat Charge Detection

Pilot Wealth looks through your own transaction history for charges that repeat on a regular schedule, such as a gym membership or a phone plan paid from your bank, and suggests them as bills on the Recurring Payments page. It reads the description, amount, and date of your transactions from roughly the last four months. The detection runs on our servers, uses only your own transactions, and is never combined with other members' data. A charge it counts as a bill, either because you confirmed it or because it repeats very consistently, is treated like a bill you entered yourself, including in the summary the AI coach receives, as described in section 2.3. The coach also receives the repeat charges it has found that are not yet a bill, other than ones you dismissed: the merchant name, the usual amount, how often it repeats, and the date it was last charged.

When you confirm or dismiss a suggestion, we store your answer together with a simplified form of the charge's name so we remember it. These answers are part of your budget settings, are included in your data export, and are deleted when you delete your account.

2.8 AI Reply Sources, Charts, and Ratings

AI tutor replies show where their figures came from. A reply can cite a section of your own Pilot Wealth data, such as your debts or your spending this month, and can link to an official Canadian page for a published limit or rule. Those pages are on canada.ca, cmhc-schl.gc.ca, and osfi-bsif.gc.ca. A reply can also include one chart drawn from your own spending, debt, or net worth figures, and buttons that open a section of your dashboard.

• So these show again when you reopen the chat, we save the sources, chart, and dashboard links with each reply, together with the reasoning setting and model that produced it. This is encrypted with the same dedicated key as your chat messages.
• An official link opens in a new tab only when you click it. We send nothing to those sites, and they handle your visit under their own privacy policies.
• Each reply has a thumbs up and a thumbs down. When you give a thumbs down, you can pick a reason: wrong numbers, wrong source, not helpful, or other. We store the rating, the reason, the reasoning setting, the model, the identifiers of the sources and chart the reply used, and the date. The rating itself does not contain the reply's text, your question, or any of your figures, though it points to the reply it rates, and a new rating replaces your earlier one for the same reply.
• We count ratings across all members to see which sources and reasoning settings lead to poor answers. The counts are not sent to xAI or anyone else.
• When you rate a reply, we may also read that reply together with the question it answered, to find and fix mistakes in the tutor. A thumbs down is the rating most likely to be read. Only the founder of Pilot Wealth does this review. It uses the same encrypted chat messages we already store for you, so it takes no new information from you. The messages are not sent to xAI and are not shared with anyone other than the hosting providers that already store your data, listed in section 6.1. This use ends when you clear your chat history or delete your account, because both delete the messages.

Saved replies, their sources and charts, and your ratings are included in your data export. Clearing your chat history in the AI chat page deletes all of them at once, and deleting your account does the same. The app does not remove a single reply or rating on its own, so contact us if you want one removed.

3. How We Use Your Information

We use collected information to:

• Provide the Service: Enable core features, process transactions, sync data
• Authenticate Users: Verify identity, manage sessions, prevent unauthorized access
• Personalization: Customize dashboards, recommendations, and insights
• Province and Age: Fill in tax estimate defaults and tailor Pilot Score benchmarks, as described in section 2.5
• Stock Tracker: Show prices for the stocks you hold or watch and email you alerts when they move, as described in section 2.6
• Repeat Charge Detection: Find charges that repeat in your own transaction history and suggest them as bills, as described in section 2.7
• AI Reply Ratings and Quality Review: Count thumbs up and thumbs down on AI tutor replies, and read a rated reply with its question, to find and fix mistakes in the tutor, as described in section 2.8. We do not use this to train an AI model
• Billing and Payments: Process subscriptions, enforce plan limits, manage upgrades
• Analytics and Improvement: Understand usage patterns, identify bugs, improve features
• Security: Detect fraud, prevent abuse, monitor for suspicious activity
• Communications: Send service updates, notifications, marketing (with consent)
• Legal Compliance: Comply with federal, provincial, and territorial laws, respond to legal requests, enforce Terms

4. AI and Automated Processing

Pilot Wealth uses artificial intelligence (AI) systems provided by xAI to generate financial insights, recommendations, and analysis.

You acknowledge and agree that:

• AI outputs are probabilistic and may be inaccurate
• AI-generated content is not financial, legal, or professional advice
• Decisions based on AI outputs are solely your responsibility
• Your prompts may be processed by third-party AI providers subject to their privacy policies
• We do not guarantee accuracy, completeness, or reliability of AI responses

4.1 Automated Transaction Categorization

Separately from the AI features above, Pilot Wealth assigns a spending category (such as "Groceries" or "Dining") to your transactions using an automated system that we build and operate ourselves, on our own infrastructure. This system combines category information provided by Plaid, keyword matching, and a machine learning model trained by Pilot Wealth.

To improve accuracy for all users, this machine learning model is trained on a combined, de-identified dataset of transaction descriptions and their categories drawn from across our user base, not only your own transactions. When building this training dataset:

• Your name, user ID, account number, and transaction amount are never included. Only the transaction's description text and its assigned category are used.
• Transactions that appear to be a transfer between two people (for example, an Interac e-Transfer memo, which commonly includes a name) are excluded, since a memo like this can identify a specific individual who may not even be a Pilot Wealth user.
• The model learns general word-to-category patterns from this combined dataset. It does not retain a retrievable copy of any individual transaction, and it is not possible to query the model to recover a specific person's data.

Because the trained model reflects patterns learned from many users' data in combination, deleting your account removes your own transaction records going forward and stops them from being used in any future training, but does not retroactively alter a model that was already trained using data that existed at the time. See our Data Retention Policy for more detail.

5. Data Storage and Security

We implement industry-standard security measures to protect your data:

• Encryption: Data encrypted in transit (TLS/SSL) and at rest (AES-256)
• Authentication: Secure login via Clerk with multi-factor authentication available
• Access Controls: Role-based permissions, principle of least privilege
• Monitoring: Real-time threat detection, rate limiting, abuse prevention
• Regular Audits: Security reviews, vulnerability scanning, penetration testing

6. Third-Party Services

We use trusted third-party providers to operate our service. These partners may access your data:

6.1 Essential Service Providers

• Clerk (Authentication and User Management): Privacy Policy
• Stripe (Payment Processing): Privacy Policy
• Plaid (Bank Connections, PRO/PREMIUM): End User Privacy Policy
• Supabase (Database and Backend): Privacy Policy
• Render.com (Web Hosting): Privacy Policy
• Resend (Email Delivery): Privacy Policy

6.2 AI Service Providers

• xAI (AI Processing): subject to xAI's privacy policy

6.3 Analytics and Monitoring

• We may use analytics services to understand usage patterns, such as Google Analytics where applicable
• You can opt out of analytics tracking through browser settings or extensions

6.4 Market Data

• Yahoo Finance (Stock Quotes, Stock Tracker). Our servers request prices for the tickers you hold or watch. Each request contains a ticker symbol and nothing that identifies you.
• Bank of Canada (Exchange Rates, Stock Tracker). Our servers request the Bank's daily exchange rate for each currency a stock you hold or watch is listed in. Each request contains only a currency code. These rates are available free of charge at bankofcanada.ca.

These third parties process data under their own privacy policies. We encourage you to review them. We are not responsible for their privacy practices.

7. Data Retention

We retain your personal data:

• Active Accounts: As long as your account is active and in good standing
• After Deletion: We do not run automated backups. Before a major change to our database, we may take a one-off encrypted snapshot and delete it within 14 days, so data you delete can remain in such a snapshot for up to 14 days
• Legal Requirements: As required by federal, provincial, or territorial law for tax, accounting, or legal purposes
• Security Logs: May be retained longer for fraud prevention and security analysis

You may request account deletion at any time through your account settings or by contacting us. Deletion is subject to legal retention requirements and may take up to 30 days to complete.

8. Your Privacy Rights

Depending on your location in Canada, you may have the following rights:

8.1 Rights Under PIPEDA (Federal)

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Withdrawal of Consent: Withdraw consent for certain data processing activities
• Complaint: File a complaint with the Privacy Commissioner of Canada

8.2 Provincial Privacy Rights

If you reside in Alberta, British Columbia, or Quebec, you may have additional rights under provincial privacy legislation (PIPA, PIPA-BC, or Law 25):

• Enhanced Access: Additional rights to access and understand how your data is used
• Deletion: Request deletion of your personal data (subject to exceptions)
• Portability: Receive your data in a structured, machine-readable format (Quebec)
• De-indexing: Request removal from search engine results in certain circumstances (Quebec)

8.3 Additional Rights Under GDPR, CCPA, and Similar Frameworks

If you are in the EU, California, or other jurisdictions with enhanced privacy laws:

• Restriction: Restrict certain processing activities
• Objection: Object to processing based on legitimate interests
• Opt-Out: Opt out of the sale of personal information. Pilot Wealth does not sell personal information.

8.4 How to Exercise Your Rights

To exercise any of these rights, contact us at:

Email: support@pilotwealth.ca

We will respond to verified requests within 30 days (or as required by applicable provincial law). We may require identity verification to prevent unauthorized access.

9. Minor Users (Ages 14 to 17)

9.1 Minimum Age and Consent

Pilot Wealth is intended for users aged 14 and older. Users between the ages of 14 and 17 may consent to this Privacy Policy on their own behalf under PIPEDA and applicable Canadian provincial privacy legislation. By registering, you confirm that you are at least 14 years old and that you understand how your personal information is collected and used.

We do not knowingly collect personal information from individuals under the age of 14. If we become aware that a user is under 14, we will delete their account and associated data promptly.

9.2 How We Handle Minor Users' Data

For users we know or reasonably believe to be under 18:

• We collect only the personal information necessary to provide the service
• We do not use their data for targeted advertising or share it with third parties for marketing purposes
• AI-generated financial insights are provided for educational and informational purposes only and are not financial advice

9.3 Bank Connection Features (Plaid)

Bank account sync via Plaid (available on PRO/PREMIUM plans) requires that you are the authorized account holder of the connected bank account. In Canada, most bank accounts require the holder to be of the age of majority in their province or territory (18 in most provinces; 19 in BC, NS, NB, NL, NT, YT, and NU). Users under the age of majority may still use all manual budgeting, expense tracking, and financial coaching features without connecting a bank account.

10. International Data Transfers

Your data may be processed and stored in countries outside of Canada, including the United States, where our service providers operate.

These countries may have different data protection laws than Canada. By using our service, you consent to the transfer of your data to these jurisdictions.

We ensure that third-party providers implement appropriate safeguards to protect your data in accordance with this Privacy Policy, PIPEDA, and applicable provincial/territorial laws.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and keep you logged in
• Remember your preferences and settings
• Analyze usage patterns and improve the service
• Detect and prevent fraud

Types of Cookies We Use:

• Essential Cookies: Required for authentication and core functionality
• Analytics Cookies: Help us understand how users interact with the service
• Preference Cookies: Store your settings and customizations

You can control cookies through your browser settings. However, disabling essential cookies may prevent you from using certain features.

12. Legal Disclosure and Law Enforcement

We may disclose your information if required to:

• Comply with federal, provincial, or territorial laws, regulations, or legal processes, such as subpoenas or court orders
• Enforce our Terms and Conditions
• Protect the rights, safety, or property of Pilot Wealth, our users, or others
• Prevent fraud, abuse, or illegal activity
• Respond to government or regulatory requests

We will notify you of legal requests unless prohibited by law or if notification would compromise an investigation.

13. Marketing Communications

With your consent, we may send you:

• Product updates and new feature announcements
• Tips and educational content
• Promotional offers and discounts

You can opt out of marketing emails at any time by clicking "Unsubscribe" in the email or updating your communication preferences in your account settings.

Note: You cannot opt out of essential service communications such as security alerts and billing notifications.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification (for significant changes)
• Displaying an in-app notification

Your continued use of the service after changes become effective constitutes acceptance of the updated Privacy Policy.

15. Contact Us