1. Scope of This Privacy Policy

This Privacy Policy applies to:

• users of Pension Beyond, and

• users of Finspire’s supporting features, including financial literacy tools, personal financial management features, and technology-assisted insights.

Where product-specific terms apply, they will be disclosed clearly at the point of use.

2. Pension Beyond – Primary Data Flows

2.1 Data Collected for Pension Beyond

To operate Pension Beyond, Finspire may collect and process the following categories of data:

• Identification data: name, email address, contact details, employer (where applicable)

• Eligibility and onboarding data: information required to assess eligibility or enable participation

• User-provided financial inputs: contribution preferences, planning parameters, and non-transactional information

• Account reference data: identifiers required to integrate with partner financial institutions

• Consent records: authorizations, opt-ins, and permissions provided by you

Finspire collects only data that is necessary to provide Pension Beyond and related disclosures.

2.2 How Pension Beyond Data Is Used

Your data is used to:

• facilitate onboarding and participation in Pension Beyond;

• enable technology integration with licensed financial institutions;

• display balances or progress information (including via read-only integrations, where applicable);

• provide visibility, planning tools, and educational insights related to long-term financial security;

• meet legal, regulatory, and compliance obligations.

Finspire does not use Pension Beyond data to make investment decisions on your behalf.

2.3 Custody and Financial Data Clarification

• Finspire does not receive, hold, or custody user funds.

• All financial assets remain under the custody and responsibility of licensed banks or financial institutions.

• Any transaction or account terms are governed by the relevant partner institution’s agreements.

3. Supporting Features – Additional Data Processing

3.1 Financial Literacy & Personal Financial Management

Where you use supporting tools (such as budgeting or goal-setting), Finspire may process:

• spending categories or summaries you input,

• planning notes or goals,

• interaction data related to educational content.

These features are informational and educational and support your engagement with Pension Beyond.

3.2 Technology-Assisted Insights (Including AI)

Finspire may use technology-assisted analysis to:

• categorize data,

• summarize financial behaviour,

• generate educational insights.

Such outputs:

• are not personalized advice,

• may not always be complete or accurate,

• are provided to support understanding, not decision-making.

4. Lawful Basis and Consent

Finspire processes personal data only where:

• you have provided explicit, informed consent, or

• processing is required to provide requested services or meet legal obligations.

You may withdraw consent at any time, subject to legal or regulatory retention requirements.

5. Data Minimization and Accuracy

Finspire ensures that personal data:

• is adequate, relevant, and limited to stated purposes;

• is kept accurate and up to date;

• is not retained longer than necessary.
  
  
  

6. Data Sharing and Third Parties

Finspire may share personal data only:

• with licensed financial institutions involved in Pension Beyond (where applicable);

• with trusted service providers (e.g. hosting, analytics), under strict contractual safeguards;
  
  
  

• where required by law or regulatory instruction.

Finspire does not sell personal data.

Cross-border data transfers, if any, are conducted only in compliance with applicable laws and safeguards.

7. Data Security and Confidentiality

Finspire implements appropriate administrative, technical, and organizational measures, including:

• secure storage and encrypted transmission,

• access controls and monitoring,

• regular security reviews and testing.

Third-party processors are required to meet equivalent security standards.

8. Data Breach Notification

In the event of a personal data breach that may cause harm, Finspire will:

• notify affected users without undue delay,

• provide information on the nature and impact of the breach,

• outline mitigation steps and recommended actions.

9. Your Rights

You have the right to:

• access your personal data;

• request correction or update of inaccurate data;

• withdraw consent for processing;

• request deletion or erasure where legally permitted;

• object to unfair or excessive processing.

Requests may be submitted via email to support@finspireapp.com

10. Marketing Communications

Finspire will not send marketing communications without your explicit consent.
You may opt out at any time using the mechanisms provided.

11. Complaints and Privacy Inquiries

Privacy-related complaints or concerns may be submitted to  support@finspireapp.com

All complaints are handled fairly, confidentially, and within reasonable timeframes.

12. Updates to This Privacy Policy

Finspire may update this Privacy Policy to reflect:

• regulatory developments,

• changes to Pension Beyond or supporting features,

• operational or technological updates.

Material changes will be communicated clearly before taking effect.

13. Contact Information

For questions, complaints, or requests related to these Terms, contact support@finspireapp.com