Privacy Policy

Introduction

This Privacy Policy describes how Regen Technology, Inc. (“Regen,” “we,” “our,” or “us”) collects, uses, and shares your personal information when you use the Regen mobile applications, websites, and related services (the “Service”). Capitalized terms not defined here have the meanings given in the Regen Program Agreement.

Regen is subject to the Gramm-Leach-Bliley Act (GLBA). The privacy notice it requires is in Section 5.

1. Information We Collect

1.1 Information you provide

• Identity details: name, date of birth, residential address, Social Security number, government-issued identification.
• Contact details: email address, phone number.
• Account preferences: your Savings Rules, your user-set floor (if any), and other settings.
• Communications you send to support.

1.2 Information from connected accounts

• From your Linked Bank Account, accessed through Plaid: account and routing numbers, balance, transaction history.
• From each Linked Sportsbook, accessed through SharpSports: bets, wins, losses, and related Sportsbook Activity events.

1.3 Information from service providers

• Identity verification and ongoing monitoring results from Plaid (as part of bank linking) and Priority Technologies, which operates the Sila platform (for opening your Wallet at the Banking Partner), including KYC and AML screening conducted on our behalf.

1.4 Information collected automatically

• Device and app information: device type, operating system, app version, IP address.
• Usage information: in-app events, collected via AppsFlyer (mobile attribution) and PostHog (product analytics). PostHog session replay is not enabled.
• Application errors and crashes: we may use PostHog or similar tools to capture application errors and crashes for diagnostic purposes.

1.5 Face ID

If you choose to use Face ID to log in to the Service, biometric authentication is performed on your device by your operating system. We do not receive or store your biometric information.

2. How We Use Your Information

We use your personal information to:

• Operate the Service: open and maintain your account, verify your identity, calculate savings, initiate ACH transfers, and process withdrawals.
• Comply with our legal and regulatory obligations, including KYC, AML, sanctions screening, tax, and recordkeeping requirements.
• Detect, investigate, and prevent fraud, security incidents, and prohibited activity.
• Communicate with you about your account, including service notifications and required disclosures.
• Improve the Service, including diagnosing issues and developing new features.
• Send you marketing communications about Regen, if you consent. We do not currently send marketing communications.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

3. How We Share Your Information

We share your personal information only as follows:

• Service providers under written contracts that limit their use of your information to operating the Service: Plaid (bank linking, identity verification, ongoing monitoring); Priority Technologies, which operates the Sila platform (payment processing, KYC for Wallet opening, ACH operations, and the banking-partner relationship); SharpSports (sportsbook activity data); the Banking Partner (custody of Wallet balances); AppsFlyer (mobile attribution); and PostHog (product analytics).
• Legal and regulatory requirements: with regulators, law enforcement, or other parties when we are required to do so by law, subpoena, or court order, or when we reasonably believe disclosure is necessary to protect Regen, our users, or others.
• Business transfers: with successors or acquirers in connection with a merger, acquisition, financing, reorganization, or sale of assets.
• With your consent or at your direction.

4. Cookies and Tracking

Our website regeninvest.co does not run analytics, advertising pixels, or tracking technologies. We use only essential cookies necessary for the site to function. Our mobile applications use AppsFlyer for attribution and PostHog for product analytics, as described in Section 1.4. If we change either of these practices, we will update this Privacy Policy.

5. Gramm-Leach-Bliley Act Privacy Notice

This section is the privacy notice required by the Gramm-Leach-Bliley Act and Regulation P. It describes how we collect, share, and protect nonpublic personal information about you.

5.1 What we collect

As described in Section 1, we collect financial information from you and from third parties, including identity details, bank account and transaction information, and Sportsbook Activity.

5.2 Reasons we can share, and whether you can limit sharing

5.3 How we protect your information

We maintain physical, electronic, and procedural safeguards designed to protect your information. See Section 9.

5.4 Definitions

“Affiliates” means companies related by common ownership or control. We have no affiliates today. “Non-affiliates” means companies not related by common ownership or control.

6. Your California Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). These rights apply only to personal information that is not subject to the GLBA exemption, which covers the majority of the information we collect.

• Know what personal information we have collected, used, and shared about you.
• Delete the personal information we have collected from you, subject to legal retention obligations.
• Correct inaccurate personal information.
• Opt out of sale or sharing of your personal information. We do not sell or share your personal information.
• Limit use of sensitive personal information. We use sensitive personal information only as needed to provide the Service and as permitted by law.
• Non-discrimination for exercising your rights.

To exercise these rights, email hello@regeninvest.co with the subject “California Privacy Request.” We may need to verify your identity before responding. You may designate an authorized agent to make a request on your behalf.

7. Other US State Privacy Rights

If you reside in a state with a comprehensive privacy law (currently including, without limitation, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Tennessee, Iowa, Indiana, Delaware, New Hampshire, New Jersey, Maryland, Minnesota, Rhode Island, and Kentucky), you may have some or all of the following rights, subject to your state’s specific provisions and applicable exemptions, including for data covered by the GLBA:

• Access the personal information we hold about you.
• Correct inaccurate personal information.
• Delete personal information, subject to legal retention obligations.
• Receive a copy of your personal information in a portable format.
• Opt out of targeted advertising, sale of personal information, or profiling. We do not engage in any of these.
• Appeal a denial of your request.

To exercise these rights, email hello@regeninvest.co with the subject “Privacy Request.”

8. Your Choices and Controls

8.1 Marketing

We do not currently send marketing communications. If we begin sending marketing emails, we will send them only to users who have opted in, and you can unsubscribe at any time via the link in any marketing email or by emailing hello@regeninvest.co. If we begin sending marketing SMS, we will obtain separate express consent as required by the Telephone Consumer Protection Act.

8.2 Account closure

You can close your Regen account at any time, as described in the Program Agreement. After closure, we retain the records required by law and delete the rest as described in Section 10.

8.3 Face ID

You can enable or disable Face ID at any time from your device settings. This affects only how you log in and does not change any information we already hold.

9. Data Security

We maintain administrative, technical, and physical safeguards designed to protect your personal information, including encryption in transit and at rest, role-based access controls, and security monitoring. No method of transmission or storage is perfectly secure.

10. Data Retention

We retain personal information for as long as is necessary to operate the Service and to comply with our legal and regulatory obligations:

• Identity verification records, transaction records, and other Bank Secrecy Act records: at least five (5) years after the closure of your account, as required by federal law.
• Tax-related records: retained for the period required by IRS rules.
• Support communications: up to three (3) years.
• Other personal information: deleted once no longer needed for the purpose for which it was collected.

11. Children’s Privacy

The Service is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18.

12. Changes to this Policy

We may update this Privacy Policy from time to time. When we make a material change, we will give you reasonable advance notice by email or in-app notification before the change takes effect, and update the “Last Updated” date at the top of this policy.