Privacy Policy

⚠ DRAFT — pending legal review. This document is not yet effective and does not constitute final legal terms.

Crosby, operated by Kernel Foundry · Last updated: June 19, 2026 · Effective date: pending

This Privacy Policy explains how Kernel Foundry ("we," "us," "Kernel Foundry") collects, uses, protects, and shares information through the Crosby mobile application (the "App"). Crosby is a personal-finance app that helps you understand your money by securely connecting to your financial accounts. We designed Crosby to collect only what the App needs to function, and we do not sell your personal information or track you across other companies' apps or websites.

1. Information We Collect

We collect the following categories of data, all linked to your account and used solely to operate the App (we do not use any of it to track you):

CategoryExamplesPurpose
Contact infoEmail address, nameAccount creation, authentication, support
IdentifiersAccount user IDApp functionality, authentication
Payment & financial infoConnected account names, types, masked account/routing numbers, balances, transactions, net-worth history, recurring streamsApp functionality, financial-information analysis

We also collect diagnostics not linked to your identity:

Tracking: Crosby does not track you. We do not use data to follow you across other companies' apps or websites, and we do not share data with data brokers for advertising. (App Tracking Transparency: "No.")

Bank account connections (Plaid)

To show your financial picture, Crosby connects to your bank and brokerage accounts through Plaid Inc., a regulated financial-data provider. When you link an account, you authenticate directly with your institution inside Plaid's secure flow. Crosby's servers, not your device, handle all Plaid API access, and the App never stores your bank login credentials or your Plaid access token on your device. Plaid's handling of your data is governed by Plaid's own privacy policy at plaid.com/legal.

2. How We Use Your Information

We do not sell your personal information, and we do not use your financial data for third-party advertising.

3. How We Share Information

We share data only with service providers that help us run the App, each bound by contract to protect it:

We may also disclose information if required by law, to enforce our Terms, or to protect the rights, safety, and security of our users or the public. We do not sell or rent your personal information to anyone.

4. AI-Assisted Insights

Crosby offers optional AI features powered by Anthropic's Claude models. These are off until you consent, and consent is requested at the moment you first use an AI feature — not at sign-up. Before any data is sent for AI processing, we sanitize personally identifying details from the prompt. Anthropic is configured for zero data retention on our account, and AI-generated insights are automatically purged after 90 days. You can turn AI features off at any time in the App's settings.

5. Data Security

6. Data Retention

We keep data only as long as needed, then delete or purge it automatically:

DataRetention
Profile & account informationLife of your account + 30 days
Plaid access tokensUntil you disconnect the account (+ up to 24 hours)
Balances, transactions, net-worth history24 months (rolling automatic purge)
AI insights90 days
Authentication logs90 days
Error logs30 days
Audit & consent records3 years (regulatory minimum)

Within these legal limits, you can shorten certain retention windows in Settings → Privacy. When you delete your account, we begin a 30-day grace period and then cascade-delete your data.

7. Your Rights and Choices

Depending on where you live (including under the California Consumer Privacy Act / CPRA), you have the right to:

To exercise a right that isn't available directly in the App, contact us at privacy@crosbymoney.com.

8. Children's Privacy

Crosby is not directed to children under 13 and we do not knowingly collect personal information from anyone under 13, consistent with the Children's Online Privacy Protection Act (COPPA, 15 U.S.C. §§6501–6506; 16 CFR Part 312). We confirm age during onboarding, on the device and on our servers. If we learn that an account belongs to someone under 13, we delete the session immediately and store no data. If you believe a child under 13 has provided us information, contact privacy@crosbymoney.com.

9. International Users

Crosby is operated from the United States and intended for U.S. users. If you access it from elsewhere, you understand your information is processed in the United States.

10. Changes to This Policy

We may update this Policy from time to time. We will revise the "Last updated" date above and, for material changes, provide notice in the App. Continued use after an update means you accept the revised Policy.

11. Contact Us

Kernel Foundry — Crosby
Email: privacy@crosbymoney.com
Web: crosbymoney.com