Lanyard Money LLC — Privacy Policy

Our Commitment to Your Privacy

At Lanyard, we built a Personal Trainer for Money because we believe everyone can improve their money management and live life to its fullest. That same clarity extends to how we handle your data. We are non-judgmental, and we embed earning your trust into everything we do and every decision we make.

This Privacy Policy explains what information we collect, why we collect it, how we use it, and how we protect it. This Privacy Policy applies to users of the Lanyard platform and visitors of our marketing website at lanyardmoney.com who are in the United States.

Our core privacy principles:

• We only collect data necessary to provide you with valuable insights.
• We do not sell your personal or financial data to anyone.
• We use encryption to protect your information.
• You can request deletion of your data at any time.
• We're transparent about our practices and will notify you of changes.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our platform or receive our services. By accessing or using our platform and services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. When we make changes to this Policy, we will post the updated Policy on our website and update the Privacy Policy's "last updated" date. Your continued use of our website, platform, and services after we make changes is deemed to be acceptance of those changes.

1. Information We Collect

1.1 Information You Provide Directly

When you create a Lanyard account, we collect the following information from you directly:

• Account Registration: (a) Name(s) (individual or, for household accounts, the names of both partners); (b) Email address; (c) Age range (for each adult on a household account); (d) Household composition: account type (individual or household) and number of dependents; (e) Income range (for personalized insights); (f) Estimated monthly spending (for personalized insights); (g) ZIP code (optional — used only to tailor coaching context); and (h) Financial goals and journey context, including: (i) Primary financial goals, (ii) Current life stage or circumstances, (iii) What would make you feel financially successful in the next 6 months, and (iv) Any other special circumstances you want us to know.
• Payment Information: (a) Credit card or payment method details; (b) Billing address; and (c) Subscription preferences.
• Communications: (a) Messages you send to our support team or other information you input through our website or platform; (b) Feedback and survey responses; and (c) Preferences for how you want to receive reports and alerts.

1.2 Financial Information from Connected Accounts

When you connect your bank accounts through our account connection provider, we collect the following information:

• Your Consent: Before connecting your bank accounts, you will be asked to provide your consent to the collection and processing of your financial data. This consent is separate from your acceptance of this Privacy Policy, and we record it with a timestamp for our records.
• Transaction Data: (a) Transaction amounts, dates, and descriptions; (b) Merchant names and categories; (c) Account balances (checking, savings, credit cards); and (d) Last four digits of account numbers (for display purposes only).
• Account Information: (a) Financial institution names; (b) Account types (checking, savings, credit card, etc.); and (c) Account holder names.

What We Don't Collect: (a) We cannot access your bank login credentials (these remain with our account connection provider); (b) We cannot initiate transactions or move money; (c) We cannot access safe deposit box contents or other non-transactional data; (d) We do not collect Social Security numbers, passport numbers, or government IDs; and (e) We do not store routing numbers.

1.3 Information We Collect Automatically

• Usage Data: (a) How you interact with the Lanyard platform (screens viewed, features used); (b) Device information (mobile device type, operating system, browser type); (c) IP address and approximate location (ZIP code level only); (d) Date and time of access; and (e) App performance and crash data.
• Cookies and Similar Technologies: (a) We use essential cookies to keep you logged in and remember your preferences; and (b) We use analytics cookies and other tracking technologies to understand how people use Lanyard and collect other technical information including traffic data, usage information, information about your equipment and device and operating system, configuration data and usage data ("Technical Information") for monitoring, operating, maintaining, and improving our website, platform, and services. We may use advertising cookies and other tracking technologies and other non-essential cookies as further described herein.

2. How We Use Your Information

We use your personal information solely to provide and improve the Lanyard service, as described below.

2.1 Service Delivery

• Generate the Baseline Report and the Playbook reports with personalized insights about your spending patterns
• Identify subscription services and potential savings opportunities
• Provide spending alerts based on unusual activity or patterns
• Create visualizations of your financial habits (the Highlight Reel, Scorecard, etc.)
• Create the Game Plan that estimates your spending for the next month based on prior transactions
• Deliver Coach's Orders with actionable recommendations

Note that we may use your data to develop and offer related financial wellness features, including new coaching tools, planning utilities, and insights that support our core mission of helping users improve their cash flow management. Additional or new features will be considered part of the platform and services.

2.2 Service Improvement and Support

• Improve our AI-powered insights and other products and services
• Troubleshoot technical issues and provide customer support
• Develop new features based on anonymized usage patterns
• Prevent fraud and ensure platform security
• Comply with legal obligations

2.3 AI-Powered Features

Lanyard uses artificial intelligence (AI) to generate personalized financial insights, including your Momentum Score, Coach's Orders recommendations, and Playbook reports. Our AI analyzes aggregated summaries of your spending patterns — we do not send your name, email address, account numbers, or raw transaction descriptions to our AI partners. AI-generated insights are informational and educational only; they are not financial, investment, tax, or legal advice, and do not constitute automated decisions with legal or similarly significant effects on you.

2.4 Communications

• Send your Playbook report via email
• Deliver important service updates and security alerts
• Respond to your support requests
• Send optional summaries, nudges, and feedback (if you opt-in)

2.5 Marketing Activities

We only maintain tracking technologies on our website for essential and functional purposes only to collect usage information about your use of our website and platform. We also do not send marketing emails. If we do, we will obtain your opt-in consent and provide you with the ability to unsubscribe or opt-out at any time.

We do not:

• Sell your data to third parties
• Share your spending habits with data brokers
• Send promotional emails from other companies
• Engage in tracking that involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze and store information on a user's behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions. Tracking information can be used to enable companies to make interest-based ("behavioral" or "personalized") advertising available to users on multiple sites that they visit. We do not currently collect personal information about your online activities over time and across third-party sites for tracking purposes when you use our website. We do not currently allow third parties to collect personal information through or using our website that could be used by them to analyze and store information about your online activities over time and across third-party sites for their own tracking purposes. Accordingly, our website does not respond to any "do not track" signals sent by your computer, browser or mobile device, and if your computer, browser or mobile device sends a "do not track" signal to our website, our website will not treat you differently from users who do not send such signals. For more information on how to disable certain tracking technologies, please visit the Network Advertising Initiative's Consumer Opt-Out page at thenai.org/how-to-opt-out and the Digital Advertising Alliance's Consumer Assistance page at optout.aboutads.info.

3. How We Share Your Information

3.1 Service Providers

We share limited information with carefully vetted service providers who help us operate Lanyard. The following describes the categories of service providers we use. You may request additional information about our service providers by emailing privacy@lanyardmoney.com.

• Account Connection Provider: We use this service provider to securely connect your bank accounts and retrieve transaction. We share the following information: Bank account credentials (handled entirely by the provider), account information.
• Payment Processor: We use this service provider to process subscription payments securely. We share the following information: Payment card information, billing address, email.
• AI Insights Provider: We use this service provider to generate personalized financial insights and recommendations. We share the following information: Transaction summaries, spending categories, financial goals. Note that we do not send your name, email address, or account numbers to our AI provider. Only anonymized transaction summaries, spending categories, and financial goals are shared for analysis.
• Email Delivery Provider: We use this service provider to deliver your Baseline & Playbook notification and service emails. We share the following information: Email address and name.
• Data Storage Provider: We use this service provider to securely store your account information and transaction data as our database and backend infrastructure provider. We share the following information: All data collected (encrypted at rest).
• Additional Service Providers: We also use error monitoring services (to identify and fix technical issues), product analytics services (to understand how users interact with our platform), and hosting services (to deliver our website and application). These providers process only the data necessary for their specific function.

3.2 Required Legal Disclosures

We may disclose your information when required by law, including in the following circumstances:

• In response to valid subpoenas, court orders, or legal processes
• To comply with regulatory requirements (e.g., anti-money laundering laws)
• To protect the rights, property, or safety of Lanyard, our users, or the public
• In connection with fraud prevention or security investigations

We will notify you of legal requests for your data unless prohibited by law.

3.3 Business Transfers

If Lanyard is acquired by or merged with another company or otherwise goes through a change in control or management, the following applies:

• Your data may be transferred to the new entity
• You will be notified of any material change to who controls your personal data
• The new entity will honor the commitments in this Privacy Policy

3.4 Service Discontinuation

If Lanyard discontinues operations, the following applies:

• You will be notified via email at least 60 days before shutdown
• You will have the option to export your data during the notice period
• You will have the option to delete your account at any time before or during the notice period
• On the shutdown date, all remaining user data will be permanently deleted — including revocation of any third-party access tokens (such as Plaid)
• User data will not be sold or transferred to a third party outside of a Business Transfer as described in §3.3

3.5 With Your Explicit Consent

We may share your information with other parties only with your explicit, informed consent. Examples include:

• If you choose to share a Highlight Reel achievement on social media
• If you explicitly request that we share data with a third-party service you use (such as a financial advisor, tax professional, accounting software, or personal budgeting tool), we may facilitate that transfer subject to your consent and the receiving party's privacy practices
• If you participate in research studies

4. Data Security

4.1 How We Protect Your Information

We take security seriously and implement industry-standard protections, including the following:

• Encryption: All data transmitted between your device and Lanyard is encrypted using TLS 1.3. Financial data is encrypted at rest using AES-256 encryption. We store only the last four digits of account numbers for display; full account numbers and routing numbers are never stored.
• Access Controls: We implement strict role-based access controls limit who can view your data. Multi-factor authentication required for all Lanyard team members. Code changes reviewed for security impact. We also implement automated monitoring for suspicious activity.
• Data Minimization: We only store data necessary to provide our service. Transaction data older than 24 months is archived or deleted. We do not store full account numbers (only last 4 digits for display).
• Third-Party Security: (a) All service providers must meet our security standards; (b) Regular vendor security assessments; and (c) Data processing agreements with all providers.

4.2 What You Can Do to Stay Safe

• Use a strong, unique password for your Lanyard account
• Enable two-factor authentication if/when we offer it
• Never share your login credentials with anyone
• Log out of Lanyard when using shared devices
• Keep your email account secure (password resets are sent there)
• Report suspicious activity to support@lanyardmoney.com immediately

4.3 Data Breach Notification

In the unlikely event of a data breach, we will take the following steps:

• We will notify affected users without undue delay, and in no event later than as required by applicable law, subject to any delays required for law enforcement cooperation or investigation integrity
• We will provide clear information about what data was compromised
• We will offer guidance on protective steps you can take
• We will report the breach to relevant authorities as required by law

5. Your Privacy Rights and Choices

5.1 Access and Portability

You have the right to access and obtain a portable copy of your data:

• Access all personal data we hold about you
• Download a copy of your data in a portable format (JSON or CSV)

How to exercise: Email privacy@lanyardmoney.com with your request. We will acknowledge your request within 15 business days and provide a full response within 45 days, consistent with applicable state law.

5.2 Correction and Updating

You have the right to correct and update your information:

• Update your account information at any time through Settings
• Correct inaccurate information we hold about you
• Update your communication preferences

How to exercise: Most updates can be made directly in the Lanyard site under Settings. For assistance, contact support@lanyardmoney.com.

5.3 Deletion and Account Closure

You have the right to delete your data and close your account:

• Delete your Lanyard account at any time
• Request deletion of all your personal data
• Disconnect bank accounts without deleting your account

How to exercise: (a) Delete your account: Settings → Manage My Settings → Delete Account; or (b) Email privacy@lanyardmoney.com for confirmed deletion.

What happens when you delete your account: (a) Your account is immediately deactivated; (b) All personal data is deleted from active systems within 60 days; (c) Transaction data is anonymized for aggregate analysis only; (d) Bank connections are permanently severed through our account connection provider; (e) Subscription is canceled and no further charges occur; and (f) Some data may be retained for legal/compliance purposes (e.g., fraud prevention).

5.4 Communication Preferences

You can control the following communication preferences in your Settings and Notification preferences in the Settings:

• Whether you receive the Playbook reports (required for service)
• Optional weekly summary emails (opt-in/opt-out in Settings)
• Spending alerts and notifications (customize frequency and thresholds)
• Marketing communications (optional, and you can opt out at any time)

How to exercise: Settings → Notifications

5.5 Do Not Sell My Personal Information

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising. Our website does not recognize or honor the global privacy control signals. Please contact us at privacy@lanyardmoney.com with any questions.

5.6 State-Specific Privacy Rights

The rights described in Sections 5.1 through 5.5 apply to all Lanyard users. Depending on where you live, you may have additional rights under state law.

6. Data Retention

We retain your data for the following periods:

After deletion: When you delete your account: (a) personal identifiers are removed immediately; (b) aggregated, anonymized data may be retained for statistical analysis and other permitted use as set forth herein; and (c) backup systems may retain data for a limited period before automatic purge.

7. Children's Privacy

Lanyard is intended for users 18 years of age and older in the United States. During account registration, we collect age range information to help ensure users meet this requirement. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will delete that information promptly and terminate the associated account. If you believe someone under 18 has created an account, please contact us immediately at privacy@lanyardmoney.com.

8. Geographic Scope

Lanyard is designed for use by residents of the United States only. We do not represent that our services are appropriate for, or available to, users outside the United States, and we do not offer services outside the United States and may restrict access from other jurisdictions. If you access Lanyard from outside the United States, you acknowledge that Lanyard's services and this Privacy Policy are governed by United States law, and you do so at your own risk.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Here is how we handle updates:

• We may update this Privacy Policy to reflect service changes or legal requirements
• Material changes will be communicated via email in advance of taking effect
• We will update the "Last Updated" date at the top of this policy
• Continued use of Lanyard after changes constitutes acceptance
• You can always delete your account if you disagree with changes

A "material change" includes: (a) changes to what data we collect; (b) changes to how we share or use your data; or (c) reduced privacy protections.

Version history: We maintain a public archive of previous policy versions which you can request copies of at privacy@lanyardmoney.com.

10. Contact Us

If you have questions about privacy, we are here to help.

Email: Privacy: privacy@lanyardmoney.com Support: support@lanyardmoney.com

Response time: We aim to acknowledge privacy inquiries within 15 business days and provide a full response within 45 days, consistent with applicable state law.

11. Additional Disclosures

11.1 Financial Privacy Notice

While Lanyard is not a financial institution as defined under the Gramm-Leach-Bliley Act (GLBA), we voluntarily align our data-handling practices with financial-services industry best practices for privacy and security. These include:

• We collect: (a) Information you provide (name, email, financial goals); (b) Transaction data from your connected accounts; and (c) Usage information from our app.
• We do not share: (a) Your personal financial information with non-service providers; (b) Financial data for marketing purposes; or (c) Account information with affiliates (we don't have any).
• How we protect your information: (a) Physical security: Secure data centers with restricted access; (b) Electronic security: Encryption, firewalls, access controls; and (c) Procedural security: Background checks, training, need-to-know access.

11.2 Aggregate and Anonymized Data

We may create aggregate, anonymized user data and develop insights and statistics about users for the following purposes: (a) product development and improvement; (b) industry research and benchmarking; (c) marketing materials (for example, "Lanyard users saved an average of $X"); (d) educational content such as whitepapers, blog posts, and industry reports; and (e) investor, fundraising, and business-development materials.

This data cannot be linked back to you, is not considered personal information, and may be used without restriction.

12. Third-Party Links and Services

Lanyard may contain links to third-party websites or services, such as merchant websites for canceling subscriptions or social media platforms for sharing achievements. This Privacy Policy does not apply to those third parties. We encourage you to read their privacy policies before sharing information with them.

We are not responsible for the following: (a) privacy practices of third-party websites; (b) content on external sites; or (c) data collection by services we link to.