Plaid Authorization & Consent

OctoWealth is a mobile personal finance application that helps users view, organize, and understand their personal financial information.

OctoWealth uses Plaid to enable user-authorized access to financial account data from supported U.S. financial institutions. Plaid acts as a third-party financial data connectivity provider. When you connect an account, Plaid helps authenticate the connection and transmit authorized financial account data to OctoWealth.

OctoWealth uses Plaid for read-only account aggregation and personal finance visibility.

OctoWealth does not use Plaid to move money, initiate ACH transfers, initiate payments, execute securities trades, open accounts, issue credit, make lending decisions, or take financial action on your behalf.

OctoWealth is currently intended for users in the United States only.

OctoWealth’s Plaid connection flow is configured for supported U.S. financial institutions. You may only connect financial accounts that you own or are legally authorized to access.

You may not connect another person’s financial account unless you have lawful authority to do so.

When you connect a financial account through Plaid, you authorize:

• Plaid to access, collect, process, and transmit information from the financial institution accounts you choose to connect;
• your selected financial institution to provide authorized account information to Plaid;
• Plaid to provide authorized financial account information to OctoWealth;
• OctoWealth to receive, process, store, refresh, display, analyze, categorize, and use that information to provide OctoWealth’s app features;
• OctoWealth to maintain ongoing access to the connected account until you disconnect the account, delete your OctoWealth account, revoke access through Plaid or your financial institution, or the connection otherwise expires or becomes unavailable.

This authorization remains active until revoked, disconnected, expired, or terminated as described in this disclosure.

Depending on the accounts you connect, the financial institution, the Plaid products enabled, your consent choices, and the features you use, OctoWealth may access and process some or all of the following financial account information:

• financial institution name;
• account name;
• account type;
• account subtype;
• masked account number;
• account identifiers;
• Plaid item identifiers;
• Plaid account identifiers;
• account balances;
• available balances;
• current balances;
• credit limits, where available;
• transaction history;
• pending transactions;
• posted transactions;
• transaction dates;
• transaction amounts;
• transaction descriptions;
• merchant names;
• transaction categories;
• recurring transaction patterns;
• bill and subscription patterns;
• loan and liability information, where enabled and authorized;
• credit card liability information, where enabled and authorized;
• student loan, mortgage, auto loan, or other liability information, where enabled and authorized;
• investment account information, where enabled and authorized;
• investment holdings, where enabled and authorized;
• investment transactions, where enabled and authorized;
• securities names, symbols, or identifiers, where enabled and authorized;
• account owner information, where enabled and authorized;
• other financial account information made available through Plaid based on your authorization and the OctoWealth features you use.

OctoWealth does not receive or store your online banking password.

At launch, OctoWealth may use the following Plaid products or data categories:

• Transactions to retrieve transaction history, merchant information, amounts, dates, categories, pending transactions, and posted transactions.
• Liabilities, where enabled and authorized, to retrieve loan, credit card, mortgage, student loan, or other liability information.
• Investments, where enabled and authorized, to retrieve investment account, holdings, balances, and investment transaction information.
• Identity, where enabled and authorized, to retrieve account owner or identity-related information made available by Plaid and your financial institution.

At launch, OctoWealth does not use the following Plaid products:

• Auth;
• Transfer;
• Signal;
• Income;
• Assets;
• Statements;
• Processor Token;
• Employment;
• Payroll.

Because OctoWealth does not use Plaid Auth or Transfer at launch, OctoWealth does not use Plaid to retrieve bank account and routing numbers for ACH money movement, and OctoWealth does not use Plaid to initiate payments or transfers.

If OctoWealth’s Plaid product usage changes in the future, we will update this disclosure and provide any additional notice or consent required by applicable law, Plaid requirements, or platform requirements.

OctoWealth uses Plaid-connected financial data to provide personal finance features, including:

• displaying connected financial accounts;
• displaying balances;
• displaying transaction history;
• categorizing transactions;
• detecting recurring bills and subscriptions;
• tracking budgets;
• monitoring cash flow;
• calculating net worth;
• displaying debts and liabilities;
• supporting debt payoff strategies;
• displaying investment accounts and holdings, where enabled;
• generating financial dashboards;
• generating reports;
• supporting data exports;
• supporting financial simulators and what-if tools;
• providing account alerts and reminders;
• troubleshooting account connection issues;
• securing and maintaining the service;
• complying with legal, contractual, platform, and operational requirements.

OctoWealth uses Plaid-connected financial data only as reasonably necessary to provide, maintain, secure, support, and improve OctoWealth, as further described in our Privacy Policy.

OctoWealth does not sell your financial account data.

OctoWealth does not use your financial account data for third-party advertising.

OctoWealth does not share your financial account data with third-party advertising networks.

OctoWealth does not send your personal financial data to third-party large language model providers at launch.

When you connect a financial account, OctoWealth may continue to refresh or sync information from that account.

Ongoing sync allows OctoWealth to keep balances, transactions, liabilities, investments, and related app features more current.

Sync may occur:

• automatically;
• periodically;
• when you open the app;
• when you request a refresh;
• when Plaid or your financial institution sends an update;
• when needed to maintain account functionality, security, or data accuracy.

Financial account data may not always be current, complete, or accurate. Data availability depends on Plaid, your financial institution, network availability, connection status, account permissions, institution support, and other factors outside OctoWealth’s control.

When you connect a financial account, OctoWealth receives technical identifiers and tokens from Plaid that allow OctoWealth to maintain authorized access to the connected account.

Plaid access tokens are stored only on OctoWealth’s backend systems. They are not sent to the mobile app.

OctoWealth stores Plaid access tokens in encrypted form using AWS Key Management Service or comparable encryption controls.

OctoWealth may store related identifiers, such as Plaid item identifiers, Plaid account identifiers, and OctoWealth internal user identifiers, to maintain account connections, sync data, troubleshoot issues, and revoke access when appropriate.

OctoWealth’s Plaid integration is read-only at launch.

OctoWealth does not use Plaid to:

• move money;
• initiate ACH transfers;
• initiate payments;
• withdraw funds;
• deposit funds;
• execute trades;
• open financial accounts;
• issue cards;
• issue credit;
• make loans;
• make credit decisions;
• settle debt;
• negotiate debt;
• repair credit.

You remain responsible for monitoring your financial accounts directly with your financial institutions.

You may disconnect a financial institution from OctoWealth where the disconnect feature is available in the app.

If a per-institution disconnect feature is not yet available in the app, you may contact us at:

support@octowealthapp.com

When a financial institution is disconnected, OctoWealth will take reasonable steps to stop future syncing from that institution and revoke the applicable Plaid connection where technically available.

Disconnecting a financial institution generally means:

• future data syncing from that institution will stop;
• OctoWealth will remove the applicable Plaid access token from active use;
• OctoWealth will call Plaid’s item removal process where applicable;
• you may need to reconnect the institution through Plaid if you want to use it with OctoWealth again.

Disconnecting a financial institution does not automatically delete all financial data that was previously synced into OctoWealth. Previously synced data may remain in your OctoWealth account for historical reporting, budgeting, exports, user records, security, backup, legal, or operational purposes unless you delete it, request deletion, or delete your OctoWealth account, subject to retention limitations described in our Privacy Policy.

You may request deletion of your OctoWealth account and associated data through the app, where available, or by contacting us at:

support@octowealthapp.com

When your OctoWealth account deletion is executed, OctoWealth will take reasonable steps to:

• close or delete your OctoWealth account;
• revoke connected Plaid items through Plaid’s item removal process where applicable;
• remove Plaid access tokens from active use;
• stop future financial account syncing;
• delete or de-identify active account data associated with your account, subject to retention exceptions;
• delete or de-identify financial account data stored by OctoWealth, subject to retention exceptions;
• remove user artifacts, exports, receipts, and related records where applicable and technically feasible.

OctoWealth may use a scheduled deletion process with a grace period, such as 14 days, before account deletion is executed. During the grace period, you may be able to cancel deletion by signing back in or following the cancellation process provided in the app.

Some data may remain temporarily in logs, backups, disaster recovery systems, audit records, billing records, security records, or legally required records. For example, certain logs may be retained for approximately 14 days, DynamoDB point-in-time recovery may retain recoverable copies for up to approximately 35 days, and AWS Backup snapshots may persist for up to approximately 90 days, as described in our Privacy Policy.

You may also be able to manage or revoke connections through Plaid, your financial institution, or Plaid’s consumer tools.

Revoking access outside OctoWealth may stop or limit future data access through Plaid. However, revoking access through Plaid or your financial institution may not automatically delete data that OctoWealth already received and stored before revocation.

To request deletion of data stored by OctoWealth, you should delete your OctoWealth account where available or contact us at:

support@octowealthapp.com

If you disconnect a financial institution, revoke access, or if a connection becomes unavailable, OctoWealth may retain previously synced information as described in our Privacy Policy.

Retained information may include:

• account records;
• historical transactions;
• budgets;
• categories;
• transaction rules;
• reports;
• exports;
• debt strategies;
• investment snapshots;
• liability records;
• security logs;
• support records;
• audit records.

We retain this information only as reasonably necessary to provide OctoWealth, maintain user-requested records, support app functionality, comply with law or platform obligations, resolve disputes, enforce agreements, maintain security, prevent fraud, and meet operational needs.

You may request deletion of your account or certain data as described in our Privacy Policy.

You are responsible for:

• connecting only financial accounts that you own or are legally authorized to access;
• reviewing Plaid’s connection flow and disclosures before authorizing access;
• reviewing OctoWealth’s Privacy Policy and Terms of Service;
• keeping your OctoWealth credentials secure;
• securing your device;
• monitoring your financial accounts directly with your financial institutions;
• disconnecting accounts or requesting deletion if you no longer want OctoWealth to access or store your financial account data;
• ensuring that any information you provide to OctoWealth is accurate and lawful.

You may not use OctoWealth or Plaid-connected data access for fraud, unauthorized account access, identity theft, financial abuse, illegal activity, or violation of another person’s rights.

Plaid-connected financial data may be delayed, incomplete, inaccurate, unavailable, duplicated, or miscategorized.

Data availability and accuracy may depend on:

• your financial institution;
• Plaid;
• your account permissions;
• authentication status;
• network availability;
• institution support;
• account type;
• data refresh timing;
• system outages;
• changes by your financial institution or Plaid.

OctoWealth does not guarantee that Plaid-connected data will always be available, current, accurate, or complete.

You should verify important financial information directly with your financial institution before making financial decisions.

OctoWealth uses Plaid-connected financial data to provide informational personal finance tools.

OctoWealth does not provide legal, tax, accounting, investment, lending, credit, debt settlement, or professional financial advice.

OctoWealth does not act as your financial adviser, investment adviser, broker, lender, bank, money transmitter, or fiduciary.

Any budgets, reports, alerts, categories, projections, debt strategies, net worth calculations, investment views, recurring bill detections, subscription detections, or financial insights generated by OctoWealth are informational only.

You are responsible for your own financial decisions.

This Plaid Authorization Disclosure supplements OctoWealth’s Privacy Policy and Terms of Service.

You should review all three documents:

Privacy Policy: https://octowealthapp.com/privacy Terms of Service: https://octowealthapp.com/terms Plaid Authorization Disclosure: https://octowealthapp.com/plaid-authorization

If there is a conflict between this Plaid Authorization Disclosure and the Privacy Policy regarding privacy practices, the Privacy Policy controls. If there is a conflict between this Plaid Authorization Disclosure and the Terms of Service regarding your legal obligations or use of OctoWealth, the Terms of Service controls.

We may update this Plaid Authorization Disclosure from time to time.

If we make material changes to the financial data we access, the Plaid products we use, the purposes for which we use Plaid-connected data, or your rights to disconnect or delete data, we may provide notice by email, in-app notice, app update notice, posting an updated disclosure, or another reasonable method.

If required by law, Plaid requirements, platform rules, or the nature of the change, we may request renewed consent before continuing to access certain financial account data.

If you have questions about this Plaid Authorization Disclosure, your financial account connections, disconnection, revocation, or data deletion, contact us at:

OctoPath LLC d/b/a OctoWealth Email: support@octowealthapp.com Website: https://octowealthapp.com

The following short consent language may be shown in the app before or near the Plaid connection flow:

By continuing, you authorize OctoPath LLC d/b/a OctoWealth and Plaid to access, receive, process, store, and refresh information from the U.S. financial accounts you choose to connect. This may include account details, balances, transactions, liabilities, investments, and identity information where enabled and authorized. OctoWealth uses this information to provide personal finance features such as dashboards, budgets, transaction categorization, bills and subscription detection, debt strategies, investment views, reports, exports, and insights.

OctoWealth uses Plaid for read-only financial account aggregation. OctoWealth does not use Plaid to move money, initiate payments, initiate ACH transfers, execute trades, issue credit, or make financial decisions for you.

You may disconnect financial institutions where available, request assistance at support@octowealthapp.com , or delete your OctoWealth account. Disconnecting an institution stops future syncing but may not automatically delete data already stored by OctoWealth. See our Privacy Policy and Plaid Authorization Disclosure for details.