Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

I. Types of Nonpublic Personal Information (NPI) We Collect

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This includes your name, email address, month and year of birth, current and historic account balances, income and tax filing information, and any other financial or demographic information you choose to share.

When you choose to connect a financial account in Tobi, we use a service called Plaid to securely connect your account. By proceeding, you authorize Tobi and Plaid to transmit, collect, and process your information from your financial institution to provide the Services you request. Your data is handled under both Tobi's Privacy Policy and Plaid's End‑User Privacy Policy. You may manage or revoke your connections at any time in the Tobi app or by visiting the Plaid Portal at my.plaid.com.

What we request: Only the data necessary for the requested feature (e.g., account and routing numbers, selected accounts, and related metadata). We do not receive or store your bank credentials.
Your choices: You can disconnect a linked account at any time; upon disconnection, we stop receiving new data from that account. Previously stored transaction and balance data is retained while your account is active to support ongoing financial guidance and historical analysis, but is excluded from active features. You may also revoke Plaid's access at any time via my.plaid.com. Upon account termination, your account enters a 7-day grace period during which you may cancel the request by signing back in. After the grace period expires, all personal data — including your profile, linked account data, financial history, and authentication record — is permanently deleted.
No sale of data: Tobi does not sell your personal information.

To protect your privacy, we will only ask you to provide the month and year of your birth, which will be used to estimate your retirement readiness and provide related financial guidance.

We use cookies, pixels, and similar technologies to understand how you use our services, improve performance, and personalize your experience. For more details, and to adjust your preferences at any time, please see our Cookie Policy page.

AI Sharing

Tobi uses AI services provided by OpenAI in limited ways to support certain features in the app. This section describes when Tobi shares information with OpenAI, what information may be shared, and how that information is used.

By creating an account, linking financial accounts, and using AI-powered features, you acknowledge and consent to the data sharing described in this section.

Tobi sends only the information reasonably necessary to support the specific feature described below. Tobi does not provide OpenAI with direct access to your Tobi account, linked financial accounts, or Tobi's database. Tobi does not send bank login credentials, passwords, or other account access credentials to OpenAI. Tobi also does not send full financial account numbers or full card numbers to OpenAI. Any third party with whom Tobi shares your data provides the same or equal protection for that data.

OpenAI is contractually prohibited from using your data, including inputs, outputs, evaluation data, and feedback, to train or improve its models.

1. Transaction Categorization and Financial Classification

Tobi may use OpenAI to help classify and organize transaction-related financial information, particularly where Plaid data is incomplete, broad, or ambiguous. This includes improving the accuracy of spending categorization, helping identify merchants or transaction types, distinguishing transfers from true spending or income, classifying inflows by income type, and identifying debt-related payments.

For this purpose, Tobi may send OpenAI limited transaction and account context, such as:

transaction descriptions or merchant names
transaction amounts
transaction dates
Plaid-provided category hints
institution names
account display names, account types, or account subtypes
limited examples from prior categorizations used to improve consistency
limited related financial context needed to distinguish spending, transfers, income, or debt payments

In limited cases, Tobi may also send contextual information already available within Tobi, such as known employer names, loan servicer names, or other linked financial context, when needed to improve classification accuracy. For example, employer-name context may be used to help distinguish employment income from transfers, refunds, gifts, government benefits, business income, rental income, investment income, or other sources.

2. Ask Tobi

When you use Ask Tobi, Tobi sends limited information to OpenAI to generate a response to your request and support related chat features.

All financial calculations, projections, and analyses are performed by Tobi's own systems. OpenAI is used only to help interpret your question, format a response, and support related chat features.

For this purpose, Tobi may send OpenAI limited information such as:

the text of your message
recent chat context needed to respond coherently
relevant financial data, summaries, or computed results needed to answer your question accurately, such as balances, spending totals, transaction summaries, contribution totals, or similar outputs from Tobi's internal systems
limited profile or account context needed to determine which tools or calculations are relevant
limited recent chat history used to suggest follow-up questions or tailor responses to your interaction style

Tobi sends this information to OpenAI only to provide the Ask Tobi experience you request, such as answering questions, explaining Tobi features, presenting personalized financial guidance in conversational form, and suggesting relevant follow-up questions.

If you do not want information shared with OpenAI for Ask Tobi, do not use Ask Tobi.

3. AI-Generated Explanations and Contextual Help

In some parts of the app, Tobi may use OpenAI to generate contextual explanations or educational help content, such as explanations shown through info buttons or similar in-app guidance features.

For this purpose, Tobi may send OpenAI limited context such as:

the topic or metric being explained
the card, screen, or feature where the explanation appears
limited data points shown on that screen, such as percentages, balances, totals, or other summary values relevant to the explanation
relevant documentation or educational context used to improve the explanation

Tobi uses this information only to generate concise, contextual explanations and related educational prompts relevant to what you are viewing in the app.

4. Credit Card Rewards and Points Features

Tobi may use OpenAI in limited ways to support credit card rewards and points features.

For example, Tobi may use OpenAI to help identify which specific credit card product a linked credit card account most likely represents, based on information such as:

the institution or bank name
the card or account name provided by the linked account
a list of known card products already in Tobi's systems

This helps Tobi match a linked card to the correct rewards profile so that rewards rates, points information, category bonuses, and similar card benefits can be shown more accurately.

In limited cases, Tobi may also use OpenAI to help interpret publicly available rewards information, such as rotating reward categories or estimated point or mile valuations.

If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information only as described in this notice.

II. Protecting Confidentiality of Current and Former Client's Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and buildings.

Definitions

Affiliates – companies related by common ownership or control. They can be financial and non-financial companies.
Non-affiliates – companies not related by common ownership or control. They can be financial and non-financial companies.
Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.

Reasons We Can Share Your Personal Information (and You Cannot Limit)

For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations.
For our marketing purposes — to offer our products and services to you.

Reasons We Will NOT Share Your Personal Information

For joint marketing with other financial companies.
For our affiliates’ everyday business purposes — information about your transactions and experiences.
For our affiliates’ everyday business purposes — information about your creditworthiness.
For our affiliates to market to you.
For nonaffiliates to market to you.

Contact Us

For questions, please contact us at support@tobiwealth.com.