Privacy Policy

Ordino Technologies Inc. | Effective July 1, 2026 | support@ordino.ca

1. Who We Are

2. What Personal Information We Collect

We collect the minimum information needed to provide the Service.

3. How We Use Your Information

• Providing the Ordino app and all its features — transaction display, budgeting, savings tracking.
• Powering the Vero AI assistant — Vero has read-only access to your transactions, balances, budgets, savings, and recurring expenses.
• Sending transactional messages: email verification, 2FA codes, password resets, billing receipts.
• Processing your subscription and managing your billing through RevenueCat. Depending on your platform, payment is processed by Stripe (web), Apple (iOS), or Google (Android).
• Detecting and preventing fraud and unauthorized account access.
• Responding to your support requests.
• Improving the app through aggregate, anonymized usage analytics.
• Creating anonymized, aggregated statistical data (data that cannot identify you individually) to understand usage patterns, improve the Service, and develop new features. This aggregate data is not your personal information and may be shared with third parties in that form.
• Improving merchant categorization — merchant names may be used in anonymized form. No amounts, dates, or account information are used for this purpose.
• Processing receipt photos using AWS Textract (OCR) and Claude AI models via AWS Bedrock to extract and categorize receipt data.

We do not sell your financial data.

We will never sell your financial data. Ordino does not sell, rent, trade, or share your personal or financial data with any third party for their own marketing or commercial purposes. Ordino may, from time to time, present offers or content from third-party partners within the app — any such features will be clearly identified as third-party content, and your personal or financial data will never be shared with a third-party partner without your express consent.

4. Third-Party Service Providers

We share your information only with the service providers we need to operate Ordino.

Each third-party service provider operates under its own privacy policy and maintains industry-standard security practices. Ordino selects providers that demonstrate a commitment to data protection consistent with Canadian privacy principles. You can review each provider's privacy practices at the following links: Plaid — plaid.com/legal; Stripe — stripe.com/privacy; Amazon Web Services — aws.amazon.com/privacy; Resend — resend.com/legal/privacy-policy; PostHog — posthog.com/privacy; Google Analytics — policies.google.com/privacy; RevenueCat — revenuecat.com/privacy.

Law Enforcement and Legal Disclosures

We may disclose your personal information to law enforcement agencies, government authorities, courts, regulators, or other authorized third parties when we are required to do so by applicable law, subpoena, court order, or other legally enforceable demand, or when we reasonably believe such disclosure is necessary to: (a) comply with applicable law or our legal obligations; (b) protect the rights, property, or safety of Ordino, its employees, users, or the public; or (c) detect, prevent, or investigate fraud, security incidents, or illegal activity. Where legally permitted, we will make reasonable efforts to notify you before disclosing your personal information in response to a legal demand. We may also cooperate with law enforcement agencies and courts in any investigation related to your use of the Service.

Professional Advisors

We may disclose your personal information to Ordino's own professional advisors (lawyers, accountants, auditors, etc.) where reasonably necessary in the course of professional services. All such advisors are subject to confidentiality obligations.

Business Transfers

If Ordino undergoes a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified of any material changes to this Privacy Policy before they take effect.

5. Cross-Border Processing

Certain features of the Service use artificial intelligence models accessed through AWS Bedrock via a Canadian endpoint (ca-central-1). Because these models use AWS cross-region inference profiles, the actual model execution is routed by AWS to United States regions (us-east-1 or us-west-2). As a result, some of your data is temporarily transmitted to and processed in the United States, including:

• Transaction categorization: transaction data and our categorization criteria are sent for AI-based categorization, then the result is returned and stored only in our Canadian database.
• Receipt processing: after your receipt image is scanned in Canada (AWS Textract), the extracted text is sent for AI-based structuring, then the result is returned and stored only in our Canadian database.
• Vero AI assistant: your query, along with relevant financial data context, is sent for AI-generated responses.

This cross-border transmission is temporary and stateless — your data is not stored in the United States. The AI model processes your data only for the duration needed to generate a response; as soon as the response is returned, the data is erased from the AI server, typically within seconds. AWS Bedrock does not retain your data, and does not use it to train, fine-tune, or improve any AI model.

Ordino remains accountable for your personal information at all times, including while it is processed outside Canada. We require AWS, through our enterprise agreement, to maintain a level of protection for your data comparable to what is required under Canadian privacy law. While your data is in the United States, even temporarily, it may be subject to US law, including lawful access by US authorities.

Transaction categorization and receipt processing are core, automated features of the Service and occur regardless of your settings, as they are necessary to provide the Service to you. Vero AI is different: because it involves direct, conversational use of your financial data, we offer a dedicated control. You may disable Vero AI at any time via Settings > Privacy > Cross-Border Processing. This disables Vero only — transaction categorization and receipt processing will continue as normal.

By creating an Ordino account and using the Service, you acknowledge and consent to the cross-border processing described in this section.

All other app data — your transactions, account details, receipts, and Vero conversation history — remains stored in Canada.

6. Automated Processing — Vero AI Assistant

Vero is not a financial advisor. Nothing Vero says is financial advice. Vero may make mistakes — always verify important financial information.

• Vero uses AWS Bedrock Claude models to process your questions. Your data is stored in Canada; inference requests may transit US AWS servers — see Section 5.
• Vero has read-only access to your transactions, budgets, account balances, savings, recurring expenses, and income summaries. Vero cannot modify or move your data.
• Vero conversations are encrypted at rest using AES-256 (AWS KMS) in our Canadian RDS database. Ordino staff do not review your conversations.
• Vero uses AI for specific functions: transaction categorization, merchant name clarification, recurring expense identification, spending pattern analysis, budget progress insights, and answering questions about your financial data. All AI-generated suggestions are user-overridable.
• We do not use automated decision-making that produces legal or significant financial effects on your account. Transaction categorization suggestions are always user-overridable.
• AWS Bedrock does not use your personal or financial data to train its AI models. Your data is used only to generate a response to your query.
• Ordino does not use your Vero conversation data, financial information, or personal information to train, fine-tune, or improve any AI model.
• Every Vero tool call is logged in a tamper-evident audit log.
• Ordino may use automated systems to monitor Vero conversations to detect and prevent abuse or policy violations. In rare circumstances, designated personnel may review flagged conversations strictly for enforcement purposes.
• AI-assisted support tools: Ordino may use AI-assisted tools to help our support team triage and prioritize support inquiries more efficiently. Any AI tools used in a support context are not permitted to train on your personal information, financial data, or Vero conversation history. Support correspondence is retained in accordance with Section 8.

7. Your Rights Under PIPEDA

Access

You may request access to the personal information we hold about you at any time. You can export all your data in JSON format at Settings > Data Export. For a formal written request, email support@ordino.ca. We will acknowledge receipt within 5 business days and respond within: British Columbia: 30 business days; Alberta: 45 calendar days; All other provinces: 30 calendar days.

Data Portability

You have the right to receive a copy of your personal information in a structured, commonly used, machine-readable format via Settings > Data Export (JSON). For Vero conversation history or receipt metadata requests, email support@ordino.ca.

Correction

You may request correction of inaccurate information at support@ordino.ca.

Withdrawal of Consent / Account Deletion

You may withdraw your consent by deleting your account (Settings > Account > Delete Account or by emailing support@ordino.ca). A 30-day export window applies before all personal information is permanently deleted.

Non-Discrimination

Ordino will not discriminate against you for exercising any of your privacy rights under PIPEDA or this Policy.

Complaints

If you believe we have not handled your personal information appropriately, you may file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca or 1-800-282-1376.

8. How Long We Keep Your Information

We retain your personal information for the duration of your account. When you delete your account, all personal data is permanently deleted after a 30-day grace period.

What Happens When You Delete Your Account

• A 30-day grace period begins — you can export your data at any time during this window (Settings > Data Export).
• After 30 days: your account, Vero conversations, receipt photos, and transaction data are permanently and irreversibly deleted from our systems.
• Upon account deletion, Ordino will disconnect your linked financial institution connections and revoke access tokens with Plaid so that no further data retrieval occurs.
• Disconnecting a bank account in Ordino does not delete historical transaction data — you may permanently delete specific data at any time through the app or by contacting support@ordino.ca.
• Data Destruction: Upon expiry of each applicable retention period, Ordino will permanently destroy or irreversibly anonymize that information within 90 days. Destruction methods include cryptographic erasure for encrypted data stores and secure deletion for unencrypted records.

9. Cookies and Tracking

We use cookies on ordino.ca. A cookie consent banner appears on your first visit — essential cookies are set automatically; all others require your consent. You can update your preferences at any time using the Cookie Preferences link in the website footer.

Essential Cookies (always active)

• Session authentication — keeping you logged in to ordino.ca/home
• CSRF security tokens — protecting you from cross-site request forgery
• Stripe.js — fraud detection and payment processing
• Plaid Link SDK — bank account connection interface

Analytics Cookies (with consent)

We use PostHog and Google Analytics to understand how the app is used so we can improve it. Analytics data is aggregate and not sold to third parties. PostHog captures feature interactions, session data, onboarding funnel steps, and product telemetry. PostHog does not receive your financial data, Vero conversation history, or banking credentials. Google Analytics captures website and app traffic metrics including page views, acquisition channels, and session duration. Google Analytics does not receive your financial data, Vero conversation history, or banking credentials.

Session Replay: We may use PostHog's session replay functionality to identify and resolve user experience issues. It captures interactions with the app interface (clicks, scrolls, navigation) but not your Vero conversations, banking credentials, or financial data. Session replay data is used solely for improving the Service and is not sold to third parties.

Marketing Cookies

We do not serve advertising inside the Ordino app. On ordino.ca, we may use marketing cookies with your consent to measure campaign effectiveness. Your financial data — including transaction history, account balances, and budget data — is never used to generate, target, or influence any advertising, whether inside or outside the Ordino platform.

Push Notifications

The Ordino mobile application may send push notifications regarding account activity, billing reminders, security alerts, and feature updates. Some push notifications may be enabled by default upon installation. You can disable or manage push notifications at any time through your mobile device's notification settings. Disabling push notifications does not affect Ordino's ability to send you email notifications for important account and billing matters.

Do Not Track

We do not currently respond to browser Do Not Track (DNT) signals. Our cookie consent banner gives you meaningful control over all non-essential tracking.

10. Security

• AES-256-GCM application-layer encryption for financial data and transaction amounts.
• AWS Key Management Service (KMS) for encryption key management.
• All data stored in AWS Canada (ca-central-1, Montreal).
• Vero conversation data encrypted at rest (AES-256 / KMS) in AWS RDS PostgreSQL.
• Personal information redacted from server logs.
• Banking credentials are never stored by Ordino — handled entirely by Plaid.
• Payment card data handled by Stripe (web, PCI-DSS compliant), Apple (iOS), or Google (Android). Ordino never sees your full card number.
• Your Ordino account password is never stored in readable form — passwords are one-way hashed using a key derivation function (KDF).

Ordino monitors for unusual login activity and may temporarily limit or suspend login attempts if our systems detect potential unauthorized access. No security system is impenetrable. You are responsible for maintaining the confidentiality of your account password. To report a security vulnerability, email support@ordino.ca with "Security Vulnerability" in the subject line.

Social Engineering Warning

No Ordino staff member will ever contact you to ask for your password, banking credentials, or full payment card number. If you receive such a message, do not respond — contact us directly at support@ordino.ca.

11. Security Breach Notification

In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm, Ordino will:

• Report the breach to the Office of the Privacy Commissioner of Canada as soon as feasible and no later than 72 hours after becoming aware of the breach.
• For users located in Alberta, report the breach to the Office of the Information and Privacy Commissioner of Alberta, who will determine whether and how individual notification must occur.
• For all other affected users, notify individuals directly as soon as feasible, describing the nature of the breach, the personal information involved, steps taken to reduce risk of harm, and steps individuals can take to protect themselves.
• Maintain a record of all breaches of security safeguards for a minimum of 24 months, regardless of whether the breach met the threshold for reporting.

12. Children's Privacy

Ordino is for users 18 and older. We do not knowingly collect personal information from anyone under 18. By creating an account, you confirm you are 18 or older.

13. Changes to This Policy

We will post material changes to this Policy on our website and notify you by email or in-app notification at least 30 days before they take effect. Your continued use of the Service after the effective date means you accept the updated Policy.

14. Contact