Privacy Policy

Last updated 19 August 2026

1. Who we are

Fivo, Inc.(“Fivo”, “we”, “us”) provides a consumer service that uses software agents to apply for credit, negotiate with lenders, and respond to debt collectors on your instructions. Our mailing address is 2 Embarcadero Center, San Francisco, CA 94111. This policy explains what personal information we collect through heyfivo.com, our mobile applications, and our messaging and support channels (together, the “Services”), and what we do with it.

Some of what we do makes us a financial institution under the Gramm-Leach-Bliley Act (“GLBA”). Where GLBA applies to information we collect about you, we handle it under our GLBA privacy notice, which we deliver separately when you open an account, and which controls over this policy to the extent the two conflict.

2. Information we collect

We collect the following categories of personal information.

• Identifiers you give us. Name, mobile phone number, email address, postal address, and the state you live in.
• What you are trying to do. Whether you are seeking a loan or responding to a collector, the purpose of the borrowing, the collection agencies contacting you, employment status, and the device you use.
• Financial information. If you proceed past intake: income, obligations, account balances, account and routing numbers, and the terms of credit you hold or are offered. This is sensitive information and we treat it as such.
• Identity verification information. Date of birth and government identification numbers, where the law requires us or a partner to verify who you are.
• Communications. Messages you exchange with us or with an agent acting for you, including SMS and support correspondence, and records of what your agent sent and received on your behalf.
• Device and usage information. IP address, browser and device type, pages viewed, referring page, and timestamps, collected automatically.
• Inferences. Conclusions we draw from the above, such as which lenders are likely to fit your profile.

The game on our home page stores your progress in your own browser using local storage. That progress is never transmitted to us, and clearing it removes it entirely.

3. Where the information comes from

Directly from you; automatically from your device when you use the Services; from lenders, banks, credit unions, collection agencies and debt buyers we contact on your instruction; and from consumer reporting agencies and identity verification providers, where you have authorised us to obtain it.

4. How we use it

• To provide the Services, including acting on your instructions with third parties.
• To determine whether Fivo is available where you live and whether you are eligible.
• To verify your identity and to prevent fraud, abuse and unauthorised access.
• To communicate with you about your file, including by text message where you have given us express written consent to do so.
• To send you marketing about Fivo, where you have consented and until you tell us to stop.
• To improve, test and secure the Services, and to produce aggregated statistics.
• To meet legal, regulatory, licensing, audit and recordkeeping obligations, and to establish, exercise or defend legal claims.

We use automated systems, including large language models, to draft correspondence, summarize your position and prepare applications. A human reviews any decision that produces legal or similarly significant effects for you, and no offer is accepted, no agreement signed and no debt settled without your explicit approval.

We do not use the content of your financial records to train general-purpose models, and we do not permit our model providers to do so.

5. Text messages

We send text messages only to a number you gave us together with your express written consent. Message frequency varies. Message and data rates may apply. You can reply STOP at any time to stop, and HELP for help.

We do not sell, rent, or share mobile phone numbers or SMS consent with any third party for that party's own marketing or promotional purposes. Numbers collected for text messaging are disclosed only to the communications providers who transmit messages for us, and, where you consented to it, to our affiliates so that they can message you about Fivo. Revoking consent to text messages does not withdraw consent for the other processing described in this policy.

6. Who we disclose it to

• Service providers and processors who host our systems, transmit our messages, verify identity, process payments and provide analytics and support tooling, under contracts that limit them to acting on our instructions.
• The institutions you asked us to deal with: the specific lenders, banks, credit unions, collection agencies and debt buyers relevant to your file, and only what is necessary for the task you approved.
• Affiliates under common control with us, for the purposes described in this policy.
• Professional advisers such as auditors, insurers and lawyers.
• Authorities and other parties where we are required by law, subpoena or court order, or where disclosure is necessary to investigate fraud or protect someone from harm.
• An acquirer in a merger, financing, reorganization or sale of assets, subject to this policy continuing to apply to the information transferred.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under California law.

7. Cookies and similar technologies

We use cookies and local storage that are necessary to operate the site and to remember your session, and analytics cookies that tell us how the Services are used. You can refuse non-essential cookies through the controls we present and through your browser settings. We do not respond to Do Not Track headers, but we honour Global Privacy Control signals as opt-out requests where state law requires it.

8. How long we keep it

We keep personal information for as long as we provide the Services to you, and afterwards only as long as we need it for the purpose it was collected or as long as the law requires. Records relating to consumer financial products are generally retained for a minimum of five years, and records of your consent to be contacted for at least four years, after which we delete or de-identify them.

9. Security

We encrypt personal information in transit and at rest, restrict access to staff who need it, log access to sensitive records, and maintain a written information security programme. No system is perfectly secure, and we cannot guarantee that a determined attacker will never succeed. If a breach affects your information we will notify you as the law requires.

10. Your rights and choices

Wherever you live in the United States, you can ask us to:

• tell you what personal information we hold about you and where it came from;
• give you a copy of it in a portable format;
• correct it if it is wrong;
• delete it, subject to the records we are required to keep;
• stop sending you marketing, by email or by text; and
• limit our use of sensitive personal information to what the service requires.

We will not discriminate against you for exercising any of these rights. Residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia have these rights by statute, including a right to appeal if we refuse a request. Some of these rights do not apply to information covered by the GLBA or the Fair Credit Reporting Act.

To make a request, write to privacy@heyfivo.com. We will verify your identity before we act, and we will respond within 45 days, or tell you why we need a further 45. An authorised agent may make a request for you with written permission we can verify.

11. Children

The Services are for adults. We do not knowingly collect personal information from anyone under 18. If you believe a minor has given us information, write to privacy@heyfivo.com and we will delete it.

12. Where we operate

The Services are offered in the United States and are not directed to people outside it. Information we collect is stored and processed in the United States.

13. Changes

We may update this policy. If we make a material change we will post the revised policy here with a new date and, where the law requires it or the change is significant, notify you directly before it takes effect.

14. Contact

privacy@heyfivo.com, or write to Fivo, Inc., 2 Embarcadero Center, San Francisco, CA 94111. A person will answer. See also our Terms of Use.