Privacy Policy

1. Introduction
Jenna Digital Inc. (“Jenna”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you use our mobile app (the “App”), web portal located at hellojenna.ai (the “Website”), or related services (collectively, the “Services”).

2. Information We Collect
We may collect the following types of information:
1. Personal Identifiers: Name, email address, phone number, account credentials (username and password), address, date of birth, family status, occupation, income
2. Financial Data: Bank account information, transaction details (date of transaction, transaction type and amount, payee information, goods/services purchased), income and spending patterns, goal and budget inputs
3. Usage Data: AI chat interactions, feature usage, navigation behavior
4. Device & Technical Information: IP address, browser type, operating system, device identifiers, app version
5. Usage Data: Interactions with the Services, preferences, navigation behavior

3. How We Use Your Information
Your information is used to:
1. Create and administer your account
2. Connect your bank account to our App using our third-party technology service provider, Plaid, to receive transaction details
3. Deliver real-time, personalized financial guidance via our conversational AI
4. Provide, maintain, and improve Jenna’s features and functionality
5. Analyze behavior to personalize your journey and improve recommendations
6. Send service-related updates, and security alerts
7. Comply with applicable legal, regulatory, and contractual obligations
8. Respond to comments, questions or complaints

4. How We Share Your Information
We do not sell, disclose or share your personal data without your consent, except for in the following ways or as required or permitted by applicable law:
1. Trusted Vendors: We work with secure, vetted providers (e.g., hosting, analytics, data aggregation) to power core features on our behalf. These vendors are required to protect your data and are not authorized to use or disclose personal information for their own marketing or other purposes.
2. Aggregated & De-Identified Insights: We may use and share anonymized data to improve Jenna or contribute to financial wellness research.
3. Financial Partners: With your consent, we may surface offers or tools through trusted partners to help you meet your goals (e.g., savings, debt payoff)—without sharing personally identifiable info.
4. Legal Compliance: We and our Canadian, US and other foreign service providers may disclose data as required by law or to protect our rights and users.
5. Sale of Business: We may transfer any personal information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Jenna or as part of a corporate reorganization or other change in corporate control.

5. Data Security and Retention
We use appropriate technical, administrative, and physical safeguards to protect your personal information. However, no system can guarantee complete security.

Our record retention and destruction processes are designed to retain personal information for no longer than necessary for the purposes set out in this Privacy Policy or as otherwise required to meet legal or business requirements.

6. Your Choices (Canada)
As a Canadian user, subject to applicable law and depending on the jurisdiction in which you are based, you may have the right to:
1. Access your personal data
2. Request corrections to inaccurate information
3. Withdraw consent for the use of your personal data

To exercise your rights, please contact us using the details provided below.

7. International Data Transfers
While Jenna is a Canadian company, we may access, store or process data outside of Canada (including outside of Quebec) and in other countries (e.g., U.S., UK, Australia) using secure third-party vendors.

We ensure that any international data transfers comply with Canadian privacy laws and include safeguards such as Standard Contractual Clauses or equivalent protections.

8. Information About Our Website
In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website’s activity and to monitor and improve our Website.

9. Cookies and Tracking
Our web portal uses cookies and similar technologies to enhance user experience and deliver insights. You can manage cookie settings in your browser.

10. Third-Party Links
Our Services may contain links to third-party sites or tools. We are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

11. Information About Our App
When you install or use our App, we may collect and use the following additional information:
1. App Usage Information and Analytics: When you access and use the App, we may automatically collect certain details of your access to and use of the App, including information about the type of device hardware and operating system, unique device identifier, IP address, and language settings of your device. We also collect information about the date and time the App access our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
2. Geolocation Data: If you have consented by enabling location access, we may receive and store your precise location information, including when our App is running in the foreground (our App is open and on screen) or background (our App is open, not on screen) of your device. You may use our services without enabling the collection of precise location information from your device; however, this may impact your experience including the accuracy of certain features and functionality. If you have not allowed us to receive your precise location, we can only determine your approximate location. You can opt-out at any time by turning off your location services for the App either within the App or in the settings of your mobile device.
3. Push Notifications: If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with App updates and other relevant information. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App either within the App or in the settings of your mobile device.

12. Updates to This Policy
We may revise this policy occasionally. Updates will be posted in-app or on our website, with the revised date.

13. Contact Us
For questions about this Privacy Policy or to exercise your rights:
Jenna Digital Inc.
407 Iroquois Shore Rd Unit 8, V33, Oakville, ON L6H 1M3
Email: team@hellojenna.ai