Privacy Policy

1. Information We Collect

We may collect the following categories of information:

Account and Contact Information

We may collect information such as name, email address, organization, role, account settings, and related account details. We use this information to create accounts, provide support, administer services, communicate with users and customers, and operate our products.

Consumer-Authorized Financial Data

When a user chooses to connect a financial account through Plaid, we may receive consumer-authorized financial data such as account metadata, balances, transaction data, account identifiers, Plaid item references, and financial institution metadata. We use this information only for authorized Wings functionality, reporting, reconciliation, financial workflows, fraud/security review, and customer-requested services.

Closson Investments does not collect or store consumer financial institution login credentials.

Health-Related or Wellness Information

Depending on the services used, we may process wellness check-ins, ABA workforce support data, provider-entered notes, operational healthcare information, and health-related information. Where protected health information or regulated healthcare data is involved, use of that information is subject to applicable customer agreements, business associate agreements where applicable, and applicable privacy requirements.

Usage and Device Information

We may collect login activity, IP address, browser type, device type, pages or features used, and security events. We use this information for security, troubleshooting, analytics, service improvement, and audit logging.

Support and Communications

We may collect emails, chat messages, support requests, feedback, and related communications so we can respond to requests, resolve issues, and maintain appropriate records.

AI Interaction Data

Where AI-assisted features are used, we may process prompts, generated recommendations, review notes, and quality feedback. AI-assisted features are intended to support human workflows and do not replace human judgment in sensitive clinical, financial, compliance, employment, or material user decisions.

2. How We Use Information

We use information to:

• Provide, operate, secure, maintain, and improve CalmBody.me, Wings, and related services.
• Connect user-authorized financial accounts through Plaid and provide authorized financial workflows.
• Support customer-requested reporting, reconciliation, operational, financial, or wellness features.
• Authenticate users, protect accounts, prevent misuse, investigate security issues, and troubleshoot errors.
• Communicate with users and customers about support, security, service updates, and administrative matters.
• Comply with legal, regulatory, accounting, tax, security, vendor, contractual, or dispute-resolution obligations.

3. Plaid and Consumer Financial Data

Wings may use Plaid to allow users to securely connect their financial institution accounts. Before Plaid Link is presented or before consumer-authorized financial data is collected, Wings will provide notice and obtain appropriate user consent.

Users should understand that:

• Plaid will be used to connect to the user’s financial institution or account data.
• Wings may access only the categories of financial data described at the time of consent.
• Financial data is used only for the disclosed and authorized Wings functionality.
• Users may revoke, disconnect, or request deletion of financial data through supported account, support, or Plaid-related mechanisms where available.

Closson Investments does not sell consumer financial data.

4. Consent

We collect, process, and store consumer financial data and other sensitive information only with appropriate authorization or consent. If information will be used for a materially different purpose than originally disclosed, we will obtain additional consent or authorization where required.

5. How We Share Information

Closson Investments may share information with approved vendors and service providers only as needed to provide, secure, support, or administer services.

These providers may include cloud hosting, database, analytics, communications, support, security, accounting, development, and financial technology providers.

Plaid may process user information to support account linking and consumer-authorized financial data access.

We may disclose information when required by law, subpoena, legal process, regulatory request, security investigation, or to protect rights and safety.

We may share information with customers or administrators according to the customer’s configuration and authorized service scope.

Closson Investments does not sell personal information, consumer financial data, or health-related data.

6. Security

Closson Investments uses administrative, technical, and organizational safeguards designed to protect information. These safeguards may include:

• TLS 1.2 or better for data in transit.
• Encryption at rest for sensitive data using approved cloud, database, or application controls.
• Multi-factor authentication for critical administrative, production, source code, password manager, and financial systems.
• Role-based access control, least privilege, access reviews, and timely de-provisioning.
• Vulnerability management, patching, dependency review, and end-of-life software monitoring.
• Logging, monitoring, incident response, and vendor review appropriate to system and data risk.

No system can guarantee absolute security, but Closson Investments is committed to maintaining reasonable safeguards appropriate to the sensitivity of the information processed.

7. Data Retention and Deletion

We retain information only as long as needed for the authorized purpose, business relationship, security requirement, legal obligation, accounting requirement, dispute resolution, backup cycle, or customer instruction.

Consumer-authorized financial data is retained only as necessary for the authorized Wings service or other disclosed purpose.

Users may request disconnection or deletion through approved product or support channels where supported.

Certain records may be retained where required for legal, accounting, security, audit, contractual, or dispute-resolution purposes.

Backups expire according to backup retention cycles unless a legal hold, security issue, or investigation requires preservation.

8. AI Governance and Sensitive Data

AI tools may assist users and internal teams, but they do not replace human accountability. Sensitive data must not be submitted to unapproved AI tools. AI recommendations that affect clinical, financial, compliance, employment, or material user outcomes require appropriate human review before action.

AI-assisted outputs should be reviewed for accuracy, bias, privacy, security, and appropriateness before being used in production or customer-facing workflows.

9. Children and Sensitive Populations

Wings and CalmBody features may relate to ABA, healthcare, wellness, or provider-support workflows. The products are not intended to intentionally collect information from children or sensitive populations unless the specific feature, customer agreement, parental or guardian authorization where required, and applicable legal obligations support that use case.

10. User and Customer Rights

Subject to applicable law, customer agreements, identity verification, and technical feasibility, users or customers may request access, correction, deletion, restriction, or disconnection of information.

Requests may be submitted using the contact information below.

11. Changes to This Privacy Policy

Closson Investments may update this Privacy Policy from time to time. When we make material changes, we will update the effective date and provide notice where appropriate.

12. Contact

Privacy and security questions may be directed to: