CoSeed Privacy Policy

Pharos Ventures, Inc.  ·  Effective: May 10, 2026  ·  Last updated: May 10, 2026

1. What we collect

Information you provide

• Account details: full name, email address, password (hashed by Firebase Authentication, never stored in plaintext on our servers).
• Profile information: optional display name, phone number, mailing address, household income (used for prudent-pod sizing).
• Identity verification (KYC): when required by law for money-movement features, government-issued ID and a selfie collected via Plaid’s Identity Verification flow. Plaid hosts and processes this data; we receive only an approval/denial decision and a session identifier.

Information from your bank

• Bank account details: institution name, account masked number, account type, available and current balances. Collected via Plaid when you connect an account through “Connect with Plaid.”
• Transaction risk signals from Plaid’s ACH authorization service, used solely to evaluate whether a specific pod payment is safe to initiate.

Information collected automatically

• Device and usage: app version, device model and OS version, crash reports, performance metrics. Used to fix bugs and improve reliability.
• Audit log: a hash-chained record of significant actions (sign-in, pod creation, payment initiation, etc.) used for fraud detection and regulatory compliance.

2. How we use information

• Operate and secure your account, including login and password recovery.
• Run the savings-pod features you choose to participate in: pod creation, member matching, contribution scheduling, and payouts.
• Initiate ACH transfers between your bank account and the pod recipient’s account, exclusively when triggered by you (or your pod admin for a scheduled round you opted into).
• Verify your identity to satisfy Bank Secrecy Act, OFAC screening, and similar regulatory obligations.
• Detect and prevent fraud, abuse, and money-laundering risk across the platform.
• If you opt in via the Credit Reporting setting, furnish your on-time-payment history to consumer credit bureaus through a licensed aggregator.
• Communicate with you about your account, pods, payments, and material policy changes.
• Improve the product through aggregated, de-identified analytics. We do not sell or rent your personal information to anyone.

3. Who we share information with

We share specific data with vetted service providers (“processors”) strictly to deliver the service you requested:

• Plaid Inc. — bank linking, balance lookup, ACH transfers, and identity verification. Plaid’s privacy policy: https://plaid.com/legal/#consumers.
• Google LLC (Firebase & Google Cloud Platform) — user authentication, application hosting, and database infrastructure.
• Sentry — aggregated crash reports and error telemetry. We disable PII-bearing fields in Sentry transmission.
• Your pod members — only the information you explicitly post (username, message text, voting choices). Risk scores, bank account details, balances, income, and address are never shown to other users.
• Credit bureaus (only if you opt in) — on-time pod-payment data, furnished through an aggregator such as Bloom Credit, to Experian, Equifax, and/or TransUnion.
• Law-enforcement and regulators — only when legally compelled (e.g., a valid subpoena), and only the data actually responsive to the request.

4. How we protect information

• Sensitive PII (mailing address, phone, ID document references) is encrypted at rest with Fernet (AES-128-CBC + HMAC-SHA-256).
• Plaid access tokens are encrypted at rest before storage.
• All client↔server traffic is encrypted in transit with TLS 1.2+.
• An immutable, hash-chained audit log records every privileged action; tampering breaks the chain and is detectable.
• Database access is gated to a least-privilege service account inside a private VPC; production secrets live in Google Secret Manager and are never checked into source.

5. How long we keep information

Account and transaction records are retained for at least seven (7) years, as required by federal banking and tax-record regulations, even after you close your CoSeed account. Operational logs and crash reports are retained for thirty (30) days. Audit-log entries are retained for the lifetime of the service.

6. Your rights

Subject to applicable law, you may:

• Access the information we hold about you.
• Correct or update inaccurate information.
• Request deletion of your account; we will erase your personal profile within thirty (30) days, except for transaction and audit records we are legally required to keep.
• Opt out of optional features (credit-bureau furnishing, marketing communications, contacts integration) at any time in your Profile settings.
• If you are a California resident, exercise your rights under the California Consumer Privacy Act and California Privacy Rights Act, including the right to know, delete, correct, and not be discriminated against for exercising your rights.

To exercise any right, email privacy@pharosventures.io.

7. Children’s privacy

CoSeed is not directed to children under 18. We do not knowingly collect information from anyone under 18. If you believe a minor has created an account, contact privacy@pharosventures.io and we will delete it.

8. International users

CoSeed is currently available only in the United States. Bank-linking and money-movement features require a U.S.-based bank account. If you access CoSeed from outside the U.S., your information will be transferred to and processed in the United States.

9. Changes to this policy

If we make a material change, we will notify you by email and via an in-app banner at least 14 days before the change takes effect. Non-material changes (e.g., clarification, typo) are effective on posting; the “Last updated” date at the top will reflect any revision.

10. Contact

Pharos Ventures, Inc.
Privacy questions: privacy@pharosventures.io
Support: support@pharosventures.io