Privacy Policy

2.1 Information You Provide

When you create an account, participate in a cohort, join a pilot program, request SMS verification, or communicate with us, we may collect:

• Full legal name
• Email address
• Mobile phone number
• Date of birth
• Residential address
• Government identification information, such as the last four digits of a Social Security number when required for verification
• Account login information
• Bank account connection information provided through secure third party providers
• Contribution amounts
• Payout schedule information
• Cohort participation history
• Support messages and communications
• Program eligibility information
• Participant feedback, testimonials, or survey responses
• SMS opt in and consent information
• Any other information you choose to provide

2.2 Information Collected Automatically

When you use the website, application, or related services, we may collect technical and usage information, including:

• IP address
• Device type
• Browser type
• Operating system
• App version
• Pages or screens viewed
• Time spent using the Service
• Login events
• Authentication attempts
• Error logs
• Crash reports
• Security events

We may use cookies, pixels, session tools, analytics tools, and similar technologies to improve security, understand usage, maintain sessions, and improve platform performance.

2.3 Information From Third Parties

We may receive information from third party providers that support the Service, including:

• Identity verification providers
• Payment processors
• Bank account connection providers
• Messaging and authentication providers
• Fraud prevention providers
• Hosting and infrastructure providers
• Analytics and performance providers
• Institutional partners involved in pilot programs or sponsored cohorts

This may include verification status, linked account status, payment success or failure information, transaction metadata, risk flags, account confirmation information, authentication information, or program participation details.

3.1 To Operate the Service

We use information to:

• Create and manage accounts
• Verify identity
• Authenticate users
• Determine eligibility
• Support participant onboarding
• Coordinate structured contribution cohorts
• Track contributions
• Manage payout schedules
• Process payments through third party providers
• Provide participant notifications
• Support institutional reporting
• Respond to support requests
• Maintain accurate participant and cohort records

3.2 To Support Payments and Bank Connections

inara may use third party financial infrastructure providers, including Stripe and Plaid, to support payment processing, bank account connection, account verification, contribution collection, and payout related workflows.

Sensitive financial information is processed through third party infrastructure providers and is not stored directly on inara application servers where possible.

inara may receive limited information from these providers, such as account connection status, payment status, transaction confirmation, failed payment notices, or limited bank account metadata.

3.2A Plaid Financial Account Connectivity

Plaid Services

inara uses Plaid Inc. (“Plaid”) to enable users to securely connect financial accounts to the Service.

By using Plaid through the Service, you authorize Plaid to access and transmit financial information from your selected financial institution on your behalf.

Information obtained through Plaid may include:

• Financial institution name
• Account name
• Account type
• Account ownership information
• Account balances
• Account verification information
• Transaction history where applicable
• Account identifiers necessary to support payment processing and account verification

How Plaid Data Is Used

Information received through Plaid may be used to:

• Verify account ownership
• Confirm linked account status
• Support payment processing
• Support contribution collection
• Support participant payouts
• Prevent fraud
• Detect unauthorized activity
• Comply with legal obligations
• Improve platform security

Plaid’s Use of Information

Information collected and processed by Plaid is subject to Plaid’s own privacy practices.

Users can learn more by reviewing Plaid’s Privacy Policy.

Consent

By linking a financial account through Plaid, users authorize inara and Plaid to access, retrieve, and use financial account information as described in this Privacy Policy and as necessary to provide the Service.

Revoking Access

Users may disconnect linked financial accounts through the Service where available or by contacting inara support.

Revoking access may affect certain platform features and participation in active cohorts.

3.3 To Manage Risk, Trust, and Safety

We use information to:

• Prevent fraud
• Detect suspicious activity
• Verify participant identity
• Monitor failed payments
• Manage access to cohorts
• Apply trust and eligibility rules
• Investigate disputes
• Protect participants
• Protect institutional partners
• Maintain platform stability
• Support completion of active cohorts

3.4 To Communicate With You

We may use information to send:

• Account verification notices
• SMS verification codes
• Authentication messages
• Payment reminders
• Contribution confirmations
• Failed payment alerts
• Payout updates
• Cohort updates
• Security notices
• Policy updates
• Support responses
• Program related messages
• Institutional pilot communications

3.5 SMS Verification and Mobile Messaging

inara may use SMS messaging to verify mobile phone numbers and authenticate access to inara accounts.

When you provide your mobile phone number and request verification by SMS, we may send a one time verification code to the mobile number you provide.

SMS verification messages are transactional and are used for account verification, authentication, or security purposes. Requesting SMS verification does not constitute consent to receive marketing or promotional text messages.

For the current verification program, users receive one SMS message per verification request . Additional verification messages are sent only when another verification code is requested.

Message and data rates may apply.

Where applicable, users may reply STOP to stop receiving SMS messages from inara and HELP for assistance.

inara may use messaging service providers, including Twilio, to transmit SMS messages and support authentication infrastructure.

We may maintain records associated with SMS consent and verification requests, including the mobile number provided, consent status, date and time of the request, and information reasonably necessary to document and operate the verification process.

Mobile information, including mobile phone numbers, SMS opt in data, and messaging consent, will not be sold, rented, transferred, or shared with third parties or affiliates for their marketing or promotional purposes.

SMS opt in data and consent are specific to inara and will not be transferred to another business or used to authorize messaging by another sender.

We may provide information to service providers that perform services on our behalf, such as messaging, authentication, security, hosting, or customer support, only as reasonably necessary for them to provide those services to inara. These providers do not receive SMS opt in information or consent for their own marketing or promotional purposes.

3.6 To Improve the Service

We may use information to:

• Improve product design
• Improve onboarding
• Improve reporting tools
• Improve engagement systems
• Improve payment workflows
• Improve trust and safety rules
• Analyze usage patterns
• Debug errors
• Develop new features

We may use aggregated or de identified information for research, reporting, product improvement, and institutional program analysis.

4.1 Service Providers

We may share information with service providers that help us operate the Service, including:

• Payment processors
• Bank account connection providers
• Identity verification providers
• Messaging and authentication providers
• Fraud prevention providers
• Cloud hosting providers
• Analytics providers
• Customer support tools
• Security monitoring providers
• Legal, accounting, or compliance advisors

These providers may process information only as necessary to perform services for inara or as otherwise permitted or required by law.

Service providers supporting SMS messaging, authentication, or communications may process mobile information as necessary to deliver those services. They are not authorized by inara to use SMS opt in data or consent for their own marketing or promotional purposes.

4.2 Institutional Partners

For sponsored pilots, institutional cohorts, or Community Capital Access Program deployments, inara may share limited participant and cohort information with the sponsoring or operating institution when reasonably necessary to administer or evaluate the program.

This may include:

• Enrollment status
• Participation status
• Contribution completion status
• Cohort progress
• Program engagement information
• Completion rates
• Aggregated outcome reporting
• Support or escalation status when needed

We do not share unnecessary sensitive financial information with institutional partners.

Mobile phone numbers, SMS opt in information, and messaging consent are not shared with institutional partners for marketing or promotional purposes and do not authorize an institutional partner to send SMS messages to participants.

4.3 Other Cohort Participants

To operate cohorts transparently, limited information may be visible to other participants in the same cohort.

This may include:

• Name or display name
• Cohort participation status
• Payout position or payout timing
• General cohort schedule information

We do not display full bank account information, government identification information, sensitive verification information, mobile messaging consent, or SMS opt in information to other participants.

4.4 Legal and Safety Reasons

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with applicable law
• Respond to legal process
• Cooperate with regulators or authorities
• Enforce our Terms of Service
• Investigate fraud or abuse
• Protect inara
• Protect users
• Protect institutional partners
• Prevent harm
• Maintain platform integrity

Nothing in this Privacy Policy prevents disclosure when required by applicable law, court order, or valid legal process.

4.5 Business Transfers

If inara is involved in a merger, acquisition, reorganization, financing, sale of assets, or similar transaction, information may be transferred as part of that process subject to applicable law.

SMS opt in consent is not treated as transferable authorization for another entity to send marketing or promotional SMS messages. Any messaging consent must remain subject to applicable consent requirements.

SMS Choices

Participation in SMS verification is limited to the verification or authentication purposes disclosed when consent is requested.

Where applicable, you may reply STOP to stop receiving SMS messages from inara.

For assistance with the inara SMS verification program, reply HELP to an inara SMS message or contact: support@inarapool.com.

Withdrawal of SMS consent does not affect the lawfulness of processing that occurred before consent was withdrawn.