Privacy Policy — PILLAR Momentum App V1.2

Effective Date: October 1, 2026

PILLAR AI Inc. (“PILLAR,” “we,” “our,” or “us”) operates the PILLAR Momentum mobile application (“PILLAR Momentum” or the “App”), a personal financial planning application designed to help users understand their financial position, plan ahead, and make informed financial decisions.

Privacy is a core part of how PILLAR Momentum is designed. The App can be used in Private Mode, where manually entered financial planning information is primarily stored on your device, or with Connected Banking, where you choose to connect financial accounts and certain financial information is processed and stored using our service providers and cloud infrastructure.

This Privacy Policy explains what information we collect or process, how and why we use it, when it may be shared with service providers, how long it may be retained, and the choices and privacy rights available to you.

1. Information You Provide in Private Mode

PILLAR Momentum allows you to manually enter financial and planning information such as:

  • income;

  • expenses and budgets;

  • assets and net worth;

  • debts and mortgages;

  • savings information;

  • financial goals;

  • notes and planning information; and

  • other information used to generate financial scores, forecasts, insights and planning tools.

Your manually entered financial planning information is primarily stored locally on your device and is not routinely uploaded to PILLAR's servers simply because you use the App in Private Mode.

Some information may leave your device in specific circumstances described in this Policy, including when you use Connected Banking, create or sign in to an account, use subscription services, submit feedback or request support, use features involving analytics or attribution, or intentionally export or share information.

Private Mode should therefore not be understood to mean that no information ever leaves your device.

2. Connected Banking

Connected Banking is optional. You can use PILLAR Momentum's Private Mode without connecting a financial institution.

If you choose to use Connected Banking, PILLAR uses third-party financial-data services, including Plaid, to connect PILLAR with supported financial institutions.

Depending on the accounts and features you authorize, Connected Banking may process information such as:

  • financial institution and account information;

  • account names, types and identifiers;

  • account balances;

  • transaction information, including merchant, amount and date;

  • investment-account information and summarized investment data;

  • liability information, such as balances, payment information or due dates;

  • account currency;

  • synchronization and connection status information; and

  • information necessary to maintain, secure and troubleshoot your connection.

By choosing to connect a financial account, you authorize PILLAR and its financial-data provider to access and process the financial information you select or authorize through the connection process for the purposes described in this Policy and presented to you when you connect or enable the applicable feature.

Connected Banking information may be stored in PILLAR's cloud infrastructure so that connected features can operate, synchronize and remain available to you.

PILLAR does not ask you to provide your online banking username or password directly to PILLAR. Authentication with your financial institution is handled through the financial-data provider and your financial institution.

Connecting an account does not give PILLAR the ability to move money, initiate payments, purchase or sell securities, or conduct financial transactions on your behalf.

Where transaction importing is enabled, imported transactions are presented for your review. Imported transactions do not automatically change your PILLAR planning information unless you choose to review and apply them through the App's supported workflows.

Financial information received from financial institutions or financial-data providers may be delayed, incomplete or temporarily unavailable. Connected Banking information should not be assumed to represent a real-time financial institution balance or record unless expressly stated otherwise.

3. Account and Authentication Information

Some PILLAR features can be used without creating a PILLAR account.

Features that depend on cloud services, including Connected Banking, may require you to create or sign in to an account.

When you create or use an account, we may process information such as:

  • your email address;

  • your PILLAR account or Supabase user identifier;

  • authentication and session information;

  • account-security information; and

  • information necessary to provide authenticated features.

We use third-party authentication and cloud infrastructure to provide these services.

4. Usage Analytics and App Performance

PILLAR uses analytics tools to understand how the App is used, identify problems and improve the product.

Depending on your use of PILLAR and whether you are signed in, analytics information may include:

  • features or screens used;

  • App version and device or platform information;

  • subscription tier or application mode;

  • interactions with certain App features;

  • limited counts or categories related to feature usage;

  • a generalized or bounded Financial Health Score range or similar derived information; and

  • a PILLAR user identifier when you are signed in.

PILLAR is designed to avoid sending raw financial amounts—such as your individual income, account balances or transaction amounts—through its standard product-analytics events.

Analytics information should not be understood as universally anonymous. When you are signed in, certain analytics information may be associated with your PILLAR user identifier.

PILLAR currently uses PostHog for product analytics.

Session replay is not enabled in PILLAR's current analytics implementation.

5. App Attribution and Tracking Permissions

PILLAR may use attribution technology, including AppsFlyer, to understand how users discover and install the App and to measure marketing effectiveness.

On Apple devices, PILLAR may request permission through Apple's App Tracking Transparency framework where required.

Depending on your device settings, permissions and the operation of third-party software development kits, attribution services may process device or App identifiers and information associated with installation or marketing attribution.

Where Apple's permission is required for tracking, your choice is controlled through Apple's App Tracking Transparency framework and device settings.

Apple requires developers to disclose applicable data collection and tracking practices in App Store Connect and to use App Tracking Transparency where Apple's definition of tracking applies.

6. Subscriptions and Purchases

PILLAR uses Apple's App Store and RevenueCat to manage subscription purchases and subscription entitlements.

These services may process information such as:

  • subscription status;

  • purchase and renewal information;

  • App Store transaction or receipt information;

  • subscription product information;

  • RevenueCat customer identifiers; and

  • your PILLAR user identifier when subscription information is associated with a signed-in account.

PILLAR does not directly process your App Store payment-card information.

Deleting your PILLAR account or resetting the App does not automatically cancel an Apple App Store subscription. App Store subscriptions must be managed separately through Apple.

7. Feedback and Support

If you contact PILLAR, submit feedback or request support, we may receive information you choose to provide, such as:

  • your name;

  • email address;

  • feedback or support message;

  • App or device diagnostic information; and

  • information included with your feedback to help us understand the issue.

Please avoid including financial information or other sensitive information in free-form support messages unless it is necessary for us to assist you.

8. Exports, Receipts and User-Generated Information

PILLAR provides features that allow you to create, store or export information.

Depending on the feature you use, exports may contain financial information, transaction information, planning information, notes, scores, receipts or other information stored in PILLAR.

Exports are created at your request and may be saved or shared to locations you choose.

Once information has been exported, copied or shared outside PILLAR, those copies are under your control and cannot necessarily be deleted or recalled by PILLAR.

Receipt images and certain other information may be stored locally on your device.

You are responsible for protecting exported files and choosing appropriate destinations when sharing financial or other sensitive information.

9. How We Use Information

We use information processed through PILLAR for purposes including:

  • providing and operating the App;

  • authenticating users;

  • providing Connected Banking;

  • synchronizing connected financial information;

  • displaying balances, transactions and other connected information;

  • providing financial planning calculations, scores, forecasts and insights;

  • managing subscriptions and feature access;

  • maintaining security and preventing misuse;

  • troubleshooting errors and providing support;

  • understanding App usage and improving PILLAR;

  • maintaining the reliability and integrity of our services; and

  • complying with applicable legal obligations.

We limit the collection and use of personal information to purposes reasonably necessary to provide and operate PILLAR and for the other purposes described in this Policy.

PILLAR does not use Connected Banking to initiate financial transactions or move money on your behalf.

10. Service Providers

PILLAR relies on third-party service providers to operate portions of the App.

These include or may include:

Plaid — financial-account connectivity and financial-data access.

Supabase — authentication, database and cloud infrastructure.

RevenueCat — subscription and entitlement management.

Apple — App Store purchases, subscription billing and platform services.

PostHog — product analytics.

AppsFlyer — App attribution and marketing measurement.

Other infrastructure, communications or support providers may also process information where reasonably necessary to operate and support PILLAR.

These service providers may process information on PILLAR's behalf or in connection with services you choose to use, subject to their respective services, contractual arrangements and privacy practices.

PILLAR does not sell your personal financial information.

11. International and Cross-Border Processing

PILLAR and its service providers may process or store personal information in Canada, the United States, or other jurisdictions in which our service providers operate.

As a result, personal information may be subject to the laws of those jurisdictions and may be accessible to courts, law-enforcement authorities, regulatory bodies or other government authorities where permitted or required by applicable law.

PILLAR remains responsible for personal information under its control and uses third-party service providers to process information for the purposes described in this Policy.

12. Private Mode and Connected Banking

The privacy characteristics of PILLAR depend on how you choose to use the App.

Private Mode: Your manually entered financial planning information is primarily maintained on your device. Supporting services—including analytics, attribution, subscription management, authentication when used, support, and user-requested exports—may still process information as described in this Policy.

Connected Banking: Financial information required for connected functionality is processed through PILLAR's financial-data provider and cloud infrastructure. Connected information may remain stored on PILLAR's systems until it is removed through the appropriate connection or account-deletion process or otherwise deleted in accordance with our retention practices.

Switching the App back to Private Mode, signing out, or resetting local application data does not necessarily delete previously stored Connected Banking information or revoke an existing financial institution connection.

13. Resetting, Disconnecting, Removing and Deleting Data

PILLAR provides different controls for different purposes.

Resetting App Data

Resetting App data resets some or all local PILLAR application information, depending on the reset option selected.

A local reset does not necessarily:

  • delete your PILLAR account;

  • delete Connected Banking information stored in the cloud;

  • revoke a financial institution or Plaid connection;

  • sign you out of your account; or

  • cancel an App Store subscription.

Disconnecting Connected Banking

Disconnecting a connected account or institution may stop or change how that connection is used within PILLAR.

Disconnecting should not necessarily be understood as deleting all historical information associated with that connection or as deleting your PILLAR account.

Removing a Financial Connection

Removing a financial connection may revoke the active provider connection. Certain historical information may remain where reasonably necessary for App functionality, records, security, integrity, or other legitimate purposes.

Deleting Your PILLAR Account

Account deletion is a separate process.

Account deletion initiates PILLAR's process for deleting your account, deleting or de-identifying associated user-owned cloud information as applicable, and revoking connected financial-provider access associated with your account.

Some limited information may be retained where reasonably necessary or permitted by law for purposes such as security, deletion coordination, fraud prevention, legal compliance, backup management, dispute resolution or system integrity.

Deleting your PILLAR account does not delete copies of information you previously exported or shared outside PILLAR.

Deleting your PILLAR account also does not automatically cancel an App Store subscription.

14. Data Retention

PILLAR retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, provide applicable services, maintain security and system integrity, satisfy legal or regulatory requirements, resolve disputes, and complete authorized deletion processes.

Different categories of information may therefore have different retention periods.

Connected Banking information may remain while your account or financial connection remains active and may also be retained where reasonably necessary to preserve user-approved history or complete connection, security, provider or account-lifecycle operations.

Information processed by third-party service providers may also be subject to their retention, security, logging and backup practices.

When personal information is no longer required, PILLAR will take reasonable steps to delete, de-identify or otherwise dispose of it as appropriate and subject to applicable legal requirements.

15. Security

PILLAR uses technical and organizational safeguards intended to protect personal information appropriate to the sensitivity of the information and the services PILLAR provides.

These measures include, where applicable:

  • authentication controls;

  • database access controls;

  • row-level access protections;

  • restricted server-side operations;

  • separation between client-facing and trusted server operations; and

  • security controls supporting Connected Banking and account management.

No method of electronic storage or transmission is completely secure. PILLAR therefore cannot guarantee absolute security.

You are responsible for maintaining the security of your device, account credentials and any files you export from PILLAR.

16. Your Choices and Consent

You control whether to use several optional PILLAR features.

Depending on the features available to you, you may:

  • use PILLAR without enabling Connected Banking;

  • choose whether to connect supported financial accounts;

  • choose whether to enable transaction importing;

  • review imported transactions before applying them to your planning information;

  • disconnect or remove supported financial connections;

  • reset local App information;

  • request deletion of your PILLAR account;

  • manage Apple tracking permissions through your device settings;

  • manage or cancel subscriptions through Apple; and

  • choose whether and where to export information.

Where we rely on your consent to collect, use or disclose personal information, you may withdraw that consent, subject to legal or contractual restrictions and reasonable notice.

Withdrawing consent may affect our ability to provide features that require the applicable information. For example, withdrawing authorization for financial-account access may prevent Connected Banking from functioning.

The Office of the Privacy Commissioner of Canada states that individuals should be able to withdraw consent, subject to appropriate restrictions, and should be informed of the consequences of doing so.

17. Your Privacy Rights

Subject to applicable law, you may request information about personal information PILLAR holds about you and how that information has been used or disclosed.

You may also ask us to:

  • provide access to personal information we hold about you;

  • correct inaccurate or incomplete personal information;

  • answer questions about our collection, use or disclosure of personal information;

  • address a concern or complaint regarding our privacy practices; or

  • process an applicable request concerning deletion or withdrawal of consent.

We may need to verify your identity before fulfilling a privacy request. Certain information may be subject to legal exceptions or retention requirements.

To exercise a privacy right or raise a privacy concern, contact our Privacy Officer using the contact information below.

Canadian privacy principles provide individuals with rights concerning access to personal information, correction of inaccuracies and challenging an organization's privacy compliance.

18. Children's Privacy

PILLAR is not directed to children under 13, and we do not knowingly seek to collect personal information from children under 13.

If we learn that we have collected personal information from a child under 13 without appropriate authorization, we will take reasonable steps to delete the information where required.

Additional age or eligibility requirements may apply to PILLAR accounts, subscriptions, Connected Banking, financial institutions or third-party services. These requirements may also be addressed in our Terms of Use.

19. Changes to This Privacy Policy

We may update this Privacy Policy as PILLAR, our services or applicable requirements change.

When we make material changes, we may update the version and effective date and, where appropriate, require you to review and accept the updated Privacy Policy through the App.

The current version of this Privacy Policy will be made available through PILLAR and on the PILLAR website.

20. Privacy Questions, Requests and Complaints

PILLAR AI Inc. has designated responsibility for overseeing its privacy practices.

Questions, access or correction requests, withdrawal-of-consent requests, or complaints concerning this Privacy Policy or PILLAR's handling of personal information may be directed to:

Privacy Officer
PILLAR AI Inc.
Email: Info@PillarMobileApp.com