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Privacy Policy

Into The Eye Enterprise Co. · ReFinEd

Last Updated: March 28, 2026  ·  Draft — pending counsel review (McKinney Law Clinic)

1. Introduction

This Privacy Policy explains how Into The Eye Enterprise Co. (“Company”, “we”, “us”, or “our”), an Indiana C-Corporation, collects and uses information in connection with the ReFinEd application and the intotheeye.work website.

We are committed to protecting your privacy and being transparent about how your data is handled.

2. Information We Collect

2.1 Account Information (via Google Sign-In)

ReFinEd uses Google Sign-In only for authentication. We do not collect or store passwords. When you sign in with Google, we receive:

  • Your Google email address
  • Your Google display name
  • Your Google profile photo (if provided by Google)
  • A unique Google user ID (used to identify your account)

We do not access your Gmail, Google Drive, Google Calendar, or any other Google services beyond the authentication data listed above.

2.2 On-Device Data (stays on your device)

The following data is stored locally on your device only using secure on-device storage. It is not transmitted to our servers or shared with third parties:

  • Lesson progress and completion history
  • Quiz scores and answers
  • Portfolio simulation holdings and virtual trading history (virtual money only — no real transactions)
  • App preferences and settings

2.3 AI Chat Data

When you use the InvestPro AI Mentor feature, the content of your messages is transmitted to our AI backend for processing. This involves:

  • Your message text is sent to our backend service (hosted on HuggingFace Spaces)
  • That backend uses Google's Gemini AI service to generate educational responses
  • We do not use your chat content for advertising purposes

2.4 Subscription and Billing Data

Subscription management is handled by RevenueCat. Payment processing is handled by Google Play Billing (Android) or the applicable web payment processor (PWA). We do not store payment card details — these are handled entirely by the payment processors and RevenueCat.

RevenueCat receives information necessary to manage your subscription entitlement, such as your app user ID and subscription status. See RevenueCat's privacy policy for details on their data handling.

2.5 Technical and Usage Data

  • Device type and operating system
  • App version
  • General usage patterns (to improve the Service)
  • Error reports and crash data

3. How We Use Your Information

  • Provide the Service: Account authentication, lesson access, subscription entitlement
  • AI Features: Process your educational questions to generate relevant responses via InvestPro AI Mentor
  • Improve the Service: Analyze usage patterns and fix technical issues
  • Communication: Send important service-related updates (opt-out available for promotional messages)
  • Security: Detect and prevent fraud, abuse, or unauthorized access

4. Third-Party Services

We use the following third-party services, each governed by their own privacy policies:

  • Google (Sign-In / Identity Services): Authentication — Google Privacy Policy
  • Google (Gemini AI): Powers the InvestPro AI Mentor feature
  • HuggingFace: Hosts our AI backend service
  • RevenueCat: Subscription and entitlement management — RevenueCat Privacy Policy
  • Cloudflare: Website hosting, CDN, and edge infrastructure
  • Google Play Billing: Payment processing on Android

4.1 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for marketing or advertising purposes.

4.2 Legal Requirements

We may disclose your information when required by law or to:

  • Comply with legal obligations or valid legal process
  • Protect our rights and property
  • Prevent fraud or security issues
  • Protect user safety

5. Data Storage and Security

Our infrastructure uses the following:

  • On-device storage (SQLite via Capacitor): User progress, portfolio simulation, and quiz data — stored on your device only
  • Cloudflare infrastructure: Website and PWA hosting, edge network
  • HuggingFace Spaces: AI backend hosting
  • Encryption in transit (HTTPS/TLS) for all server communication

No method of transmission over the Internet is 100% secure. We cannot guarantee absolute security, but we take reasonable measures to protect your information.

6. Your Rights and Choices

6.1 Access and Update

You can review and update your account display name through your profile settings within the app.

6.2 Account and Data Deletion

You can request deletion of your account and associated data by contacting us at [email protected]. We will process deletion requests within 30 days, except where we are required by law to retain data. On-device data can be cleared by uninstalling the app.

6.3 Opt-Out of Communications

You may opt out of promotional communications at any time. We will continue to send service-critical messages (such as account security notices) regardless.

7. Children's Privacy

ReFinEd is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13. If we learn that we have collected information from a child under 13 without appropriate consent, we will delete it promptly.

Users under 18 are encouraged to use ReFinEd with parental guidance, as the Service contains financial education content.

8. International Data Transfers

Our services and third-party providers may process data in the United States or other countries. By using ReFinEd, you consent to the transfer and processing of your information as described in this Policy.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes through the Service or by email. Continued use of the Service after changes constitutes acceptance of the updated Policy. The “Last Updated” date at the top of this page reflects the most recent revision.

10. Contact

For privacy-related questions or requests, contact us at: [email protected]

© 2026 Into The Eye Enterprise Co. All rights reserved.