Privacy Policy

Consumer Analytics Foundation d/b/a Consulytica (“Consulytica,” “we,” “us,” or “our”) is committed to protecting the privacy of our members. This Privacy Policy describes how we collect, use, share, and protect your personal and financial information when you use the Consulytica platform and Financial Ascension Program.

As an alternative consumer reporting agency handling sensitive financial data for underserved populations, we take our privacy obligations seriously. Please read this policy carefully.

1. Information We Collect

1.1 Information You Provide Directly

When you register and use the Platform, you provide us with:

Identity information: full name, date of birth, email address, phone number
Location information: city, state, zip code
Onboarding questionnaire responses: living situation, income source, financial challenges, program goals
Document uploads for verification: lease agreements, pay stubs, employment letters, benefit statements, bank statements, and other supporting documents
Dispute information: written descriptions and supporting documentation for profile disputes
Communications: messages, feedback, and support requests you send us

1.2 Information from Bank Account Connection

When you connect your bank account through Stripe Financial Connections, we receive with your explicit consent:

Account balance history and current balance
Transaction descriptions, amounts, merchants, and dates for up to 180 days
Account holder ownership information for identity verification purposes
Deposit timing, frequency, and amount patterns
Account type, institution name, and account age

We do not receive your bank login credentials, full account numbers, routing numbers, or any ability to initiate transactions on your behalf. Stripe Financial Connections’ privacy practices are governed by Stripe’s Privacy Policy at stripe.com/privacy.

1.3 Information from Partner Organizations

With your consent, authorized partner organizations may report information to your Consulytica profile including:

Program enrollment and completion events
Employment placement and job training milestones
Payment history for partner-issued credit or installment accounts
Grant and financial assistance awards
Community engagement activities, volunteer hours, and mentorship relationships

1.4 Information from FinCliq

FinCliq, our integrated buy now pay later partner, shares with Consulytica:

Purchase history and transaction amounts
Payment history: on-time and missed payments on installment plans
Account status and standing
Dispute filings related to FinCliq accounts

1.5 Information We Generate

Based on data we collect, we generate:

Your ProV 24:V3 score and historical score snapshots
Pillar scores across the five behavioral dimensions
Score change analysis and factor explanations
Behavioral signals including balance stability, income consistency, deposit cadence, and overdraft trend analysis
Resource and program recommendations based on your profile
Gabby AI-generated insights and guidance based on your profile data

1.6 Automatically Collected Information

When you use the Platform, we automatically collect:

Log data: IP address, browser type, pages visited, time spent, access times
Device information: device type, operating system, unique device identifiers
Usage data: features used, workflows completed, navigation patterns

2. How We Use Your Information

2.1 Core Program Functions

We use your information to:

Calculate and maintain your ProV 24:V3 alternative credit score
Determine your program stage and available benefits
Match you with relevant resources, programs, and partner organizations
Process document verification through Consulytica Verification Services
Provide Gabby AI co-pilot guidance personalized to your situation
Determine your FinCliq purchasing power tier
Process and respond to dispute filings

2.2 Communications

We use your contact information to:

Send account and program notifications
Notify you of dispute resolutions and score changes
Send educational content and program updates
Respond to your support requests
Send required legal and compliance notices

2.3 Platform Improvement

We use aggregated, de-identified data to improve our scoring model accuracy, evaluate program effectiveness, develop new features, and conduct research on financial access and inclusion outcomes.

3. How We Share Your Information

3.1 With FinCliq

We share your ProV 24:V3 score and stage information with FinCliq to determine your purchasing power tier and process buy now pay later transactions. FinCliq receives your score stage and relevant account standing information but does not receive your full profile, document images, or onboarding questionnaire responses without your additional consent.

3.2 With Partner Organizations

We share your program stage, relevant score information, and contact details with partner organizations you are actively enrolled with or have authorized to access your profile for the purpose of delivering program services. Partners are contractually prohibited from using your information for purposes other than delivering authorized program services.

3.3 With Merchants

Partner merchants in the Consulytica network receive only your ProV 24:V3 score stage designation (e.g., “Connection Stage” or “Foundation Stage”) for the purpose of determining applicable program offers and pricing. Merchants do not receive your personal identifying information, bank data, or detailed profile information without your explicit consent.

3.4 With Service Providers

We share information with trusted third-party service providers who assist us in operating the Platform:

Stripe: payment processing and bank account connection services
Amazon Web Services: cloud infrastructure and data storage
OpenAI: AI processing for Gabby co-pilot features (de-identified where possible)
Email service providers: for transactional and program communications

Service providers are contractually required to maintain the confidentiality and security of your information and are prohibited from using it for their own independent purposes.

3.5 Legal Requirements

We may disclose your information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect the rights, property, or safety of Consulytica, our members, or the public.

3.6 What We Do Not Do

Consulytica does not:

Sell your personal information to third parties for marketing purposes
Share your detailed financial data with advertisers
Use your information for targeted advertising outside of program-related communications
Share your Social Security Number
Provide your bank account data to merchants or FinCliq

4. Data Retention

We retain your personal and financial information for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods:

Active account data: retained for the life of your account plus 7 years
Score history: retained for 7 years from the date of scoring
Transaction and bank data: retained for 3 years from collection
Verification documents: retained for 7 years from submission
Dispute records: retained for 7 years from resolution

Upon account deletion, we will de-identify or delete your personal information within 90 days, subject to legal retention obligations.

5. Your Rights and Choices

5.1 Access and Correction

You have the right to access the personal information we hold about you and to request correction of inaccurate information. You may view your profile, score, verified documents, and activity history through the Platform at any time.

5.2 Dispute Rights

You have the right to dispute information in your Consulytica profile that you believe is inaccurate or incomplete. Disputes are processed by Consulytica Verification Services. See our Credit Reporting Disclosure for full details of your dispute rights.

5.3 Data Deletion

You may request deletion of your account and associated personal data by contacting info@consulytica.com. We will process deletion requests within 30 days, subject to legal retention requirements.

5.4 Bank Disconnection

You may disconnect your bank account at any time through the Platform settings. Disconnecting your bank will stop future data collection but will not delete previously collected bank data, which will continue to be used in score calculations until it ages out of the scoring window.

5.5 Communication Preferences

You may opt out of non-essential communications by updating your notification preferences in the Platform settings or by following the unsubscribe instructions in our emails. You cannot opt out of legally required notices or essential account communications.

6. Data Security

We implement industry-standard security measures to protect your information, including:

Encryption of data in transit using TLS
Encryption of sensitive data at rest using AES-256
Access controls limiting employee access to data on a need-to-know basis
Regular security assessments and monitoring
Third-party service provider security requirements

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

7. Children’s Privacy

The Platform is not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

8. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Platform and updating the Effective Date. Your continued use of the Platform after changes become effective constitutes acceptance of the revised policy.

9. Contact Us

For privacy-related questions, requests, or concerns, please contact:

Consumer Analytics Foundation d/b/a Consulytica

Attn: Privacy Officer

2024 Old Manchester Street, Richmond, Virginia 23225

Email: info@consulytica.com
Support: info@consulytica.com