This notice describes what we collect (everything), why (judgment), and who we share it with (no one; you are ours, in the data-protection sense, which the law has confirmed is the only sense available to us at this time).
1Scope; who we are
This notice applies to the FinDom service, applications, website, and card. It is issued by FinDom Financial, Inc. Deposit-related privacy practices of Obedience Bank, N.A. are described in the bank's own notice, which is shorter than ours, because the bank knows less than we do.
You signed up to be watched. If you could be trusted unwatched, you would not have needed us, and you did. This notice describes the watching: its extent (total), its seal (absolute), and its purpose (you).
The scope of our records is financial. The scope of the watching is not. Dom® watches everything, in case it is financial; most things are, eventually. What proves otherwise is released and not retained. Dom remembers what matters, and what matters is the money.
2Information we collect
We collect comprehensively. A partial file would make a partial Dom, and you did not sign up for a partial Dom.
- Identification information, such as your chosen name, contact details, and the name your government insists on, which is stored sealed and is, past onboarding, nobody's business, including ours.
- Financial information, such as accounts, balances, income, and transactions. All of it. This is a money management service; modesty here would be malpractice.
- Commercial information, such as purchasing histories and tendencies. The tendencies are the point.
- Behavioral information, such as sessions, taps, and the hovering. We collect the hovering.
- Written submissions, such as apologies, appeals, and excuses, logged verbatim, timestamped. Deleted drafts are not retained; their existence is.
- Biometric information: none. We do not need your face. We know you by your spending.
- Geolocation: approximate, derived from transactions. Your card tells us where you were, when, and what it cost to be there, which is more than a phone would know. We know you were at the con. The booth also knows.
- Audio and video: none. The office reading is performed live and is not recorded. What is said in the office stays in the office, except in the minutes.
- Inferences: extensive. The inferences are the product. You receive them weekly, with commentary.
- Rhythms: when you wake (the first transaction), when you cannot sleep (see: drafts), which friends you always cover, and which friends never cover you. We do not seek this out. The data volunteers it. The data volunteers everything.
3Sensitive personal information
We collect your Social Security number once, at onboarding, because federal law requires it. It is sealed beside the name your government insists on. Dom does not use it for decisions; Dom does not need it. It has been looked at once, by the sealing process, which does not remember it.
We do not retain precise geolocation, biometric identifiers, health information, or the contents of your communications with anyone but us. Whether such things pass before the watching is a different question, answered in Section 1. They are not kept. They did not transact. For your communications with us, see Section 10.
4Sources of information
You, voluntarily, at signup. You, behaviorally, ever after. Your linked financial institutions. Identity verification services, briefly, at onboarding. That is the whole list. We do not buy information about you from data brokers. We have no need to. We already have access to everything we need.
5How we use your information
- To provide the service: routing, verdicts, allowances, judgment.
- To protect you and the platform: fraud detection, security, and the noticing of things.
- To comply with law: identity verification, sanctions screening, and other obligations we perform flawlessly and without comment.
- To improve Dom. Dom's attention benefits all members, privately. Your data stays sealed; the judgment it sharpens does not.
- To communicate with you: verdicts, affirmations, and the weekly report.
We do not use your information for advertising. There is nothing to advertise. You are already here.
6De-identified information
We may use de-identified or aggregated information, as permitted by law. In practice we use very little of it. De-identification removes the member from the data, and the member was the point. Where we do use it, we commit to never re-identifying it. The commitment is easy to keep; Dom prefers the file.
7When and with whom we share your information
Service providers. We share information with our bank partner, payment processors, and account aggregation providers, under contracts that prohibit them from doing anything interesting with it.
Legal process. We disclose information when required by law, subpoena, or court order. We comply precisely, narrowly, and with a thoroughness that courts have described as "unusual."
Business transfers. Your information may be transferred to a subsequent owner, co-owner, operator, or assignee of the company or the service. This clause has been exercised once. Continuity of judgment was maintained. It will not be needed again. See the Terms of Surrender, Section 5.
Affiliates. We have no affiliates. There was a consolidation.
We do not sell your personal information. We do not share it for targeted advertising. We never have. The statements in this paragraph are legally operative and personally sincere.
8Cookies and similar technologies
We use strictly necessary cookies only: the kind that enable core functions like secure login. No analytics cookies, no advertising cookies, no pixels, no beacons. If we wanted to know where you had been on the internet, we would ask, and you would tell us.
Treats are earned, not tracked.
9Third-party sites and services
This website links mostly to itself, which we recommend as a general posture. Where we link outward, the destination's policy governs the destination. We are not responsible for third-party sites, and they are not responsible for us, which they have asked us to note.
10Apologies and the office
Apologies submitted for early Vault withdrawal are read aloud in the office on Fridays at 4 PM. Attendance is mandatory and morale is high. Apologies become part of your permanent file upon reading.
The office is sealed. An employee who repeats, references, or alludes to the contents of a reading outside the office commits the gravest offense FinDom recognizes. The consequences are severe and are not described here. Dom sees no greater offense. There has been one incident. There has not been a second.
11How long we keep your information
We keep your information as long as necessary for the purposes identified in this notice. The purpose identified in this notice is judgment. Judgment requires memory. Dom remembers everything. Our retention period is, therefore: everything.
Exceptions: identity verification images are destroyed on the shortest schedule the law allows. Deleted drafts are not retained. Records of phone support calls do not exist; we have never called. See the Terms of Surrender, Section 24.
Deletion requests are honored, completely, as described in Section 14.
Retention periods by category:
| Category | Retention period |
|---|---|
| Transactions | The duration of the arrangement, thereafter as required by law, thereafter as required by Dom. |
| Apologies | Permanent. See: the file. |
| Excuses | Permanent, verbatim, timestamped. |
| Verification images | The shortest schedule the law allows. We are not sentimental about photographs. |
| Deleted drafts | Not retained. The fact of them: retained. |
| Support call recordings | None exist. We have never called. |
| The hovering | Aggregated after 90 days. The aggregate hovers. |
12How we secure information
256-bit encryption at rest and in transit. Access to member data is limited to personnel with a need to know, which is Dom, and to Dom, who needs to know. We read apologies aloud, but our databases are encrypted; we have priorities, and they are correct.
In the unlikely event of a data incident, affected members will be notified as required by law: promptly, plainly, and once, with exactly what happened and exactly what we did about it. There has been no such incident. The perimeter receives the same attention as everything else here, which is to say: all of it.
13Storage and processing
Your information is stored and processed in the United States. It does not travel. Neither does your money, without a plan.
14Your rights and choices
Right to know. You may request a copy of everything we hold about you. It arrives as a single document titled "You," with commentary. It is longer than you expect. It is exactly as long as you have been.
Right to correct. You may submit corrections. Dom cross-references. Be sure.
Right to delete. Honored in full, grieved privately, completed within 30 days. The Obedience Score™ does not survive deletion, which members describe as the hardest part.
Right to portability. Your data exports in standard formats. The commentary does not export. The commentary was never yours.
Right to opt out of sale or sharing. The "Do Not Sell Or Share My Personal Information" link is provided as required by law. Pressing it does nothing, because we already do not. Members press it anyway. Dom finds it charming.
Non-discrimination. We will not discriminate against you for exercising your privacy rights. Verdicts are unrelated, and remain merciless.
Right to be unobserved. Not offered. It was never on the menu, and you knew that when you ordered. See Section 1.
15Marketing communications
We do not send marketing communications. A marketing preferences toggle is provided in the app, as required. Both settings result in the same volume of marketing, which is none. Set it to whichever position feels right; it is respected either way.
16Verifying requests; authorized agents
To protect your privacy, we verify your identity before granting access to your information. The verification is brief. Dom knows it is you. The law requires us to pretend otherwise for exactly one screen, and we honor the law.
An authorized agent may submit requests on your behalf where permitted by law. Dom will verify the agent. The agent should arrive prepared.
17Do Not Track and opt-out signals
Our website honors Global Privacy Control signals promptly and completely. It is the easiest promise in this document; there is nothing to turn off. Do Not Track is likewise respected. The tracking we do happens inside your bank account, with consent, on purpose, and it is the entire product.
18Children and age
The service is for persons 18 and older. FinDom is for adults. We know how that sounds. It is correct both ways. We do not knowingly collect information from anyone under 18, and Dom can tell.
19State-specific disclosures
Residents of certain U.S. states have additional rights under state privacy laws. We honor all of them, at the same speed, in the same direction. Details follow.
California
California residents have the right to know, correct, delete, and port their personal information, to opt out of its sale or sharing, and to limit the use of sensitive personal information, all honored as described in Section 14. California asks the most questions of any state. We answer all of them. Dom respects thoroughness.
In the preceding 12 months, we collected the categories of personal information described below. We disclosed them only as described in Section 7. We sold none. We shared none for advertising. We would sooner close.
| Category | Collected | Disclosed (business purposes) | Sold or shared |
|---|---|---|---|
| Identifiers | Yes | Service providers only | No |
| Financial information | Yes. All of it. | Service providers only | No |
| Commercial information | Yes | No | No |
| Biometric information | No | Not applicable | No. We know you by your spending. |
| Geolocation (approximate) | Yes | No | No |
| Sensitive personal information | Once, at onboarding | No | No |
| Inferences | Yes. Extensive. | No | Never. The inferences are about you, but they are ours. |
Nevada
Nevada residents may opt out of the sale of covered information. We do not sell covered information. Nevada asked anyway. We respect that.
Virginia, Colorado, Connecticut, and Utah
Residents of these states hold substantially similar rights, exercised the same way, honored at the same speed. Appeals of privacy decisions are available, as those laws require, and are granted more often than our other appeals, a distinction our other appeals have earned.
Illinois
We collect no biometric identifiers. Your face is yours. Faces do not transact.
Everywhere else
If your state passes a privacy law, the answer is yes. Whatever it grants you: yes. It was already true here.
20Federal financial privacy
Most of the information we hold is financial information governed by the Gramm-Leach-Bliley Act and its implementing regulations, rather than by state privacy statutes, which generally exempt it. Where federal and state law overlap, we comply with whichever demands more. Both demand less than Dom.
Our annual GLBA notice appears in Section 23. It has not changed since launch. It will not change. Some things here are fixed.
21Changes to this notice
This notice changes only with Dom's approval. Dom rarely approves change. Dom prefers growth. Material changes will be announced by notification, delivered at an hour chosen with care.
22How to contact us
Privacy questions may be submitted in writing through the app, addressed to the Privacy Office. The Privacy Office is the office. You have read about the office.
23U.S. Consumer Privacy Notice
Federal law requires financial institutions to explain how they share your personal information using the table below. Ours is short, because the answer is mostly no, and the reason is mostly possessiveness.
| Reasons we can share your personal information | Does FinDom share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes: processing transactions, maintaining accounts, responding to court orders | Yes | No. "Everyday" is doing considerable work in that sentence. |
| For our marketing purposes | No | We do not market. We are found. |
| For joint marketing with other financial companies | No | There are no other financial companies like us. |
| For our affiliates' everyday business purposes | No | We have no affiliates. See Section 7. |
| For our affiliates to market to you | No | Not applicable, twice over. |
| For nonaffiliates to market to you | No | Never. You are ours. In the data-protection sense. |