Privacy Policy

Summary

We collect personal information to provide and operate the Services, support account creation and security, connect financial data, personalize features, prevent fraud, comply with law, communicate with you, and improve Athlon.

Athlon offers optional Financial AI features. When you use them after providing the required consent, your prompt and the financial context needed to answer it are processed by a third-party AI service provider. AI processing is consent-based, and you can withdraw that consent for future processing without closing your account. See Section 13 and our AI & Data Processing Notice.

We do not sell personal information for money. We also do not share personal information for cross-context behavioral advertising.

Your privacy rights depend on where you live and the type of information involved. You can review your options on our Privacy Choices and Requests page and our Account Deletion page. To contact us about privacy, email privacy@athlon.finance.

1. Scope

This Privacy Policy applies to personal information we collect when you:

• use the Services;
• visit our website;
• join our waitlist;
• communicate with us;
• or otherwise interact with Athlon.

This Policy does not apply to:

• third-party websites, apps, or services we do not control;
• information handled solely under a third party's own privacy policy;
• or employment-related data governed by a separate notice, if applicable.

2. Information We Collect

Depending on how you use the Services, we may collect the following categories of personal information.

Identifiers and contact information

This may include your name, email address, phone number, mailing address, username, date of birth, and government-issued identification information where needed for verification or regulated features.

Account and profile information

This may include athlete profile information, school, team, sport, class year, preferences, profile image, and other account details.

Minor and guardian information

If and when we support accounts for users ages 13–17, we may collect a parent or legal guardian's name, contact information, relationship to the user, consent status, verification details, permissions settings, and related account-supervision records. Minor accounts are not currently offered. See Section 10.

Financial and transaction information

This may include linked account information, masked account details, balances, transactions, merchants, categories, recurring payments, payouts, refunds, disputes, card-related activity, and tax-related records or summaries generated through the Services.

Identity verification, fraud, and compliance information

This may include identity verification results, sanctions or watchlist screening results, fraud indicators, account ownership verification, device and behavioral risk signals, and other information needed for legal, security, or partner requirements.

Content you provide

This may include forms, support messages, uploaded documents, receipts, contracts, tax forms, attachments, notes, survey responses, and other information you choose to provide.

Communications information

This may include emails, chat messages, customer support communications, message delivery data, and call recordings where permitted and where notice is provided when required.

Device, usage, and technical information

This may include IP address, device identifiers, browser type, operating system, app version, user agent, log data, crash data, session data, pages or screens viewed, taps, clicks, navigation events, referring URLs, and approximate location derived from device or network information.

Cookies and similar technologies

We and our service providers may use cookies, SDKs, pixels, local storage, and similar technologies to keep you signed in, remember settings, measure usage, detect fraud, improve performance, and support analytics and communications.

AI feature information

If you use optional Financial AI features, we may process the prompts you submit, the responses generated for you, and the minimum financial context reasonably needed to answer your prompt. If you consent to saved history, we also store your saved conversations. Temporary Chat conversations are not retained by Athlon as conversation history after the session. See Section 13.

Inferences and derived data

We may generate or infer data such as budgeting patterns, likely recurring expenses, transaction classifications, feature eligibility, fraud indicators, and product usage insights.

3. Sources of Information

We may collect personal information from:

• you directly;
• your devices and browser;
• your use of the Services;
• linked accounts and connected financial sources;
• account connectivity providers such as Plaid;
• banks, card issuers, processors, sponsor banks, and other financial partners;
• identity, fraud, sanctions, and compliance vendors;
• analytics, communications, infrastructure, and support providers;
• guardians, family members, or authorized representatives where applicable;
• publicly available sources;
• and other third parties you authorize or direct to share information with us.

How we use Plaid

We use Plaid Inc. ("Plaid") to connect your financial accounts to Athlon. When you link an account, you enter your credentials directly with Plaid. Athlon never sees, receives, or stores your bank username or password. By connecting an account, you grant Athlon and Plaid the right to access and transmit your personal and financial information from your financial institution, in accordance with Plaid's terms.

Plaid handles your information in accordance with the Plaid End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy. We encourage you to read it. You can also review and manage the connections you have made through Plaid at https://my.plaid.com.

4. How We Use Information

We may use personal information to:

Provide and operate the Services

Including to create and manage accounts, authenticate users, connect accounts, organize financial information, process product features, and provide support.

Provide automated and AI-assisted features

Including to categorize transactions, generate budgeting and savings insights, produce tax and accounting summaries, and surface anomalies.

If you use optional Financial AI features and have provided the required consent, we also use your prompts and the minimum relevant financial context to generate responses for you, and, where you have consented to saved history, to store and display your saved conversations. See Section 13.

Personalize and improve the Services

Including to tailor dashboards and insights, improve usability and performance, develop new features, troubleshoot issues, measure engagement, and improve internal systems and workflows.

Protect users and the platform

Including to detect, investigate, and prevent fraud, abuse, unauthorized access, and security incidents; verify identities and linked accounts; conduct KYC, AML, sanctions, and compliance-related reviews where applicable; and enforce our Terms and partner requirements.

Communicate with you

Including to send alerts, confirmations, service messages, waitlist and onboarding messages, customer support responses, product updates, and, where permitted, promotional communications.

Comply with legal obligations

Including to comply with law, regulation, legal process, audits, investigations, and recordkeeping obligations, and to exercise or defend legal claims.

Support corporate transactions

Including in connection with an actual or proposed merger, acquisition, financing, bankruptcy, reorganization, or sale of assets.

5. How We Disclose Information

We may disclose personal information in the following circumstances.

Service providers

We may disclose information to vendors and service providers that help us operate the Services, including hosting, infrastructure, database, authentication, analytics, error monitoring, communications, customer support, security, document storage, and software tooling providers.

AI service provider

When you use an optional Financial AI feature after providing the required consent, we transmit your prompt and the minimum financial context needed to answer it to Athlon's active third-party AI service provider, which returns a response. Athlon selects and controls that provider for all users; you do not select it. We plan to launch Financial AI using OpenAI as our planned initial provider. OpenAI is not yet configured in production.

We contract for business use and seek terms and configuration settings that restrict use of Athlon data to train the provider's models. Whether training use is permitted, and how long requests may be retained or logged, depends on the provider's contract, configuration, and security and abuse-prevention practices. A provider may temporarily retain or log requests on that basis. We do not claim that every provider retains nothing. Our training, retention, privacy, and security statements depend on the active provider's approved contract and configuration.

We may replace OpenAI with another reviewed provider, such as Google Gemini or Anthropic, based on privacy, security, quality, availability, or business considerations, and only providers approved through our privacy, security, and legal review process should be activated. A provider change is made through our backend configuration and should not materially alter the app experience. The current active provider and its training and retention status are identified in the AI & Data Processing Notice, which is updated when the provider changes. Where a material change in processing legally requires it, we will provide additional notice or seek renewed consent. See also Section 13.

Financial and regulated partners

We may disclose information to banks, card issuers, processors, sponsor banks, connectivity providers, KYC and fraud vendors, tax or bookkeeping partners, and similar providers where needed to enable a feature, meet partner requirements, process transactions, or comply with law.

User-directed disclosures

We may disclose information when you direct us to do so, such as when you connect an account, share information with an advisor or representative, or use a partner-enabled feature.

Legal, security, and safety disclosures

We may disclose information if we believe in good faith that doing so is necessary to comply with law, respond to legal process, enforce our agreements, detect or prevent fraud or security issues, or protect the rights, property, or safety of Athlon, our users, partners, or others.

Corporate transactions

We may disclose information in connection with an actual or proposed merger, acquisition, financing, bankruptcy, reorganization, sale of assets, or similar transaction.

De-identified and aggregated information

We may use and disclose information that has been de-identified, anonymized, or aggregated so that it cannot reasonably be used to identify you, subject to applicable law. We do not sell or otherwise commercialize de-identified or aggregated information derived from data we receive through Plaid or any other account connectivity provider.

6. Cookies, Analytics, and Similar Technologies

We and our service providers may use cookies, SDKs, pixels, and similar technologies to:

• keep you logged in;
• remember preferences;
• understand usage and engagement;
• improve performance and design;
• detect fraud and abuse;
• measure campaign effectiveness;
• and support communications.

You can control certain browser-based cookies through your browser settings. Mobile devices may also provide controls for some permissions and tracking settings. Some features may not work properly if certain technologies are disabled.

If we use a separate Cookie Notice or consent tool, that will supplement this section.

7. Marketing and Communications Choices

You may opt out of promotional emails by using the unsubscribe link in the email. You may still receive transactional or service-related messages.

If you receive text messages from us, you may be able to opt out by replying STOP where supported. Opting out of certain non-promotional texts may limit functionality such as login verification or fraud alerts.

8. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain accounts, comply with legal and regulatory obligations, resolve disputes, enforce agreements, prevent fraud, and protect our business and users.

Retention periods may vary based on the type of information, the feature used, partner requirements, and applicable law. When we no longer need personal information, we will delete it, de-identify it, or securely dispose of it unless retention is required or permitted by law.

Saved Financial AI conversations are retained while saved history is enabled and until you delete them or delete your account. You can delete saved conversations individually or in bulk. Temporary Chat conversations are not retained by Athlon as conversation history after the session.

Deleting saved history or your account is subject to legally required retention and our approved backup procedures, and to fraud, security, legal-hold, dispute, and regulatory exceptions. Where an external AI service provider processed a request, that provider may have temporarily retained or logged it under its own contract and security terms. See Account Deletion.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information. These may include encryption in transit, access controls, authentication measures, monitoring, vendor review, and role-based permissions.

No method of transmission or storage is completely secure. You are responsible for maintaining the security of your devices and credentials and for notifying us promptly if you suspect unauthorized access.

10. Children and Minor Accounts

The Services are currently available only to users who are 18 years of age or older. Minor accounts are not currently offered.

The Services are not directed to children under 13.

If and when we allow users ages 13–17 to access certain Services, we will require verified parent or guardian consent, guardian account supervision, and additional controls, permissions, or disclosures, and we will update this Policy before doing so. If we learn that personal information was collected in a manner inconsistent with applicable law, we will take appropriate action.

11. U.S. State Privacy Rights

Residents of certain U.S. states may have privacy rights, subject to exceptions and limitations. Depending on your state and the information involved, these rights may include:

• access;
• correction;
• deletion;
• portability;
• opting out of certain sales, targeted advertising, or profiling activities;
• appealing a denied request;
• and, in some states, limiting certain uses of sensitive personal information.

We may need to verify your identity before processing a request. We may deny requests where permitted by law, including where an exemption applies, or where retention is necessary for fraud prevention, security, legal holds, disputes, or regulatory obligations.

Regardless of where you live, you may withdraw your consent to external AI processing for future processing while keeping access to non-AI parts of your account, disable saved AI history, and export or delete saved AI conversations individually or in bulk.

To submit a privacy request, use Athlon's in-app privacy controls or email privacy@athlon.finance. If you are an authorized agent acting for someone else, we may require proof of your authority. Where required by law, you may appeal a denied request. For details, see Privacy Choices and Requests.

12. Financial Privacy

Certain information may be subject to federal financial privacy laws, including the Gramm-Leach-Bliley Act, depending on the Services involved and our role in providing them.

Where required, financial privacy disclosures may be provided separately by Athlon, a financial partner, or both.

13. Automated Decision-Making and AI

Athlon uses automated systems, rules, and models to categorize transactions, generate budgeting and savings insights, produce tax and accounting summaries, detect fraud, verify identity, flag suspicious activity, personalize features, and support internal reviews and customer support.

Athlon also offers optional Financial AI features. External processing by a third-party AI service provider occurs only when you use an AI feature after providing the required consent. What is transmitted is your prompt, the minimum financial context needed to answer it, and the response generated for you. We do not intentionally transmit bank credentials, authentication secrets, complete account numbers, internal identifiers, or unrestricted raw copies of your records.

Saved Chat and Temporary Chat are separate modes. Saved Chat stores conversations in your account and requires a separate history consent; you can export saved conversations and delete them individually or in bulk. Temporary Chat is not stored by Athlon as conversation history after the session, but it still requires consent to external processing where an external provider is used, and that provider may temporarily retain or log the request under its approved contract, security, and abuse-prevention terms.

You may withdraw your consent to external AI processing at any time. Withdrawal applies to future processing, does not require you to close your account, and non-AI features may remain available. See Privacy Choices and Requests.

These systems may not always be accurate, current, or complete. Our automated and AI features produce suggestions and summaries for your consideration. We do not use AI output to approve or deny you credit or any other financial product, or to determine your access to a service. Where required by law, you may request human review of certain decisions that produce legal or similarly significant effects.

For full details, see our AI & Data Processing Notice.

14. International Users

Athlon currently intends the Services for users in the United States. If we expand internationally, we may update this Privacy Policy and provide additional region-specific disclosures and rights as required by law.

15. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date and provide notice as appropriate, including by posting the revised Policy, notifying you in the app, or emailing you.

16. Contact

Athlon, LLC
28 W Flagler St Ste 300B, Miami, FL 33130 US
privacy@athlon.finance

For privacy requests and consent changes, see Privacy Choices and Requests. To delete your account, see Account Deletion. For details on Financial AI, see the AI & Data Processing Notice. For general help, visit Support.