Privacy Policy
Product: Money Compass (The FinCoachHub Ltd)
URL (publish to): https://www.thefincoachhub.com/privacy
Version: 2026-09-27-SOFT-BETA
Status: Soft beta — solicitor review pending; do not present as final counsel sign-off.
1. Who we are
The FinCoachHub Ltd (“TFCH”, “we”, “us”) provides the Money Compass mobile app and related partner portal tools.
Contact for privacy queries: privacy@thefincoachhub.com (or the address published on thefincoachhub.com).
This policy covers the consumer Money Compass app and explains how partner handoffs work. The broker portal has its own operational access controls; partners become independent controllers of any data you choose to share with them.
2. What Money Compass does
Money Compass helps you form lender-visible money habits under friction, with your agency. It is a coaching / educational tool. It is not regulated financial advice and does not guarantee mortgage approval or any product outcome.
3. Local-first vault (what stays on your device)
By design, the following stay in an encrypted on-device vault (SQLCipher) on your phone unless you take an explicit action that shares a sanitised summary:
- Raw bank statement PDFs / uploads
- Transaction-level detail, balances, merchants
- Coaching conversation content with Monet (on-device SLM)
- Habit and readiness scores computed locally
We do not sell raw bank data.
4. What we may process or sync (with context / consent)
Depending on product mode and your choices, limited metadata may leave the device, for example:
| Data | Why |
|---|---|
Client Match Code (e.g. MC-GB-**) | Uniquely identify the incubation file without a name form |
| Broker / firm attribution from invite QR | Return you to the originating partner |
| Readiness / milestone signals (sanitised) | Portal pings when habits move — not statement dumps |
| Anonymous telemetry themes | Product improvement (counts/slugs only; no balances or PII) |
| Crash / diagnostics (if enabled) | Keep the app stable |
Cloud metadata, if any, is minimised. Recovery handles refer to metadata only — never raw statements.
5. Partner handoff (independent controller)
When you consent to share a privacy-safe readiness summary with your mortgage partner:
- You control the decision to share
- The partner receives a sanitised handoff (Match Code, display name if available, readiness band / stress signals as designed) — not your full statement vault
- After handoff, the partner is an independent controller of what they hold in their own systems
- TFCH keeps an immutable handoff hash / audit trail for integrity, not a copy of your vault
6. Lawful bases (UK GDPR)
We rely on a mix of:
- Contract / steps prior to contract — providing the app you chose to use
- Consent — partner handoff; optional marketing or optional cloud features if introduced
- Legitimate interests — security, fraud/abuse prevention, sanitised product analytics (balanced against your rights)
- Legal obligation — where applicable
7. Retention
- On-device vault: retained until you delete the app data / use in-app reset, or wipe the device
- Cloud metadata (if any): retained only as long as needed for the purpose (broker attribution, audit, support), then deleted or anonymised
- Crisis / safety holds may pause coaching features for a fixed period while keeping evidence uploads available
8. Your rights
Under UK GDPR you may have rights to access, rectification, erasure, restriction, objection, and data portability where applicable.
Because the vault is local-first: erasing cloud metadata alone does not wipe your phone — delete app data or use the in-app reset for a full local wipe.
To exercise rights: email privacy@thefincoachhub.com. We may need to verify the request.
9. Children
Money Compass is intended for adults. We do not knowingly onboard children.
10. International transfers
If we use processors outside the UK, we will use appropriate safeguards (e.g. UK IDTA / SCCs) and name material processors in an updated version of this page.
11. Automated decision-making
Readiness scores and coaching prompts are hygiene heuristics to support your habits. They are not underwriting decisions and must not be treated as lender approval.
12. Changes
We will update this page and bump the version date when material changes land. Continued use after notice constitutes awareness of the updated policy where permitted by law.
13. Store listing deep links
App Store / Play Console “Privacy Policy” URL must point to:
https://www.thefincoachhub.com/privacy
In-app Settings → Legal opens the same URL via src/constants/legal-links.ts.