Privacy Policy

This Privacy Policy explains how Spero Financial Group LLC, a Utah limited liability company doing business as Spero CFO (“Spero,” “we,” “us,” or “our”), collects, uses, shares, and protects information in connection with Spero Intelligence, our personal-finance and family-office bookkeeping application and related websites and services (collectively, the “Service”). By using the Service, you agree to this Policy and to our Terms of Service.

1. Who this Policy covers

This Policy applies to individuals who create an account or otherwise use Spero Intelligence, including clients we serve under a separate engagement and the client’s authorized portal users. Where Spero processes information on behalf of a client engagement, we act as that client’s service provider and handle the information consistent with our agreement with them and this Policy.

2. Information we collect

Information you provide

• Account & profile information: your name, email address, and the credentials you use to sign in (including via Google or Microsoft single sign-on, where the provider shares your email and name with us).
• Documents and inputs you upload: budgets, transaction reports, personal financial statements, asset and entity details, notes, and other financial records you choose to add.
• Communications: messages, support requests, and feedback you send us.

Financial account information from your linked connections

When you connect a bank, card, or investment account, you authorize our aggregation partners to provide us read-onlyaccess to that account’s information. Depending on the account, this includes account names and balances, transaction history (dates, amounts, merchant/description, and category data), investment holdings and positions, and account/routing identifiers as masked by the provider. We do not receive or store your online-banking login credentials. Those are handled by the aggregation provider.

Information collected automatically

• Usage and device data: log data, IP address, browser and device type, pages and features used, and timestamps.
• Cookies and similar technologies: used to keep you signed in, remember preferences, secure the Service, and understand usage. See “Cookies” below.

3. How we use your information

• Provide, operate, and maintain the Service and your account.
• Aggregate your connected accounts, categorize transactions, and generate net worth, cash flow, budget, and family-office reporting.
• Personalize the Service and remember your settings.
• Provide customer support and communicate with you about the Service, including service, security, and transactional messages.
• Maintain security, prevent fraud and abuse, debug, and keep audit and activity logs.
• Improve and develop features and the categorization engine.
• Comply with legal obligations and enforce our Terms.

4. Automated processing and AI

Spero Intelligence uses a multi-layer categorization engine (deterministic rules, patterns learned from your prior categorizations, and, on demand, an AI model) to suggest how transactions should be filed. AI assistance runs through Amazon Bedrock using an Anthropic model within our cloud environment. Your transaction data is used only to produce suggestions for your account; it is not used to train third-party foundation models. You and your advisor remain in control: categorizations can always be reviewed and corrected, and a human decision overrides the engine.

5. How we share information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share information only as described here:

Service providers (subprocessors)

We use trusted vendors to run the Service. They may process your information only to provide services to us and are bound by confidentiality and security obligations:

When you link an account, the aggregation provider (Plaid or SnapTrade) collects and processes your information under its own privacy policy as well. We encourage you to review those policies, linked above.

Your advisor and engagement

If you are served under a Spero engagement, the Spero team members assigned to your account, and any third-party advisor firm you have authorized, may access your information to provide the agreed services. Access is scoped to the clients each person is assigned to.

Legal, safety, and business transfers

• To comply with applicable law, legal process, or governmental request, and to protect the rights, property, or safety of Spero, our users, or others.
• In connection with a merger, acquisition, financing, or sale of assets, in which case we will continue to protect your information consistent with this Policy.
• With your direction or consent.

6. How we protect your information

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest, row-level access controls that scope data to authorized users, least-privilege access for our team, audit logging of sensitive actions, and use of read-only account connections so the Service cannot move money. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

7. Data retention

We retain your information for as long as your account is active and as needed to provide the Service, and thereafter as required to comply with our legal, accounting, audit, and recordkeeping obligations, resolve disputes, and enforce our agreements. You may disconnect a linked account at any time; you may request deletion of your account information as described below, subject to records we are required or permitted to retain.

8. Your choices and rights

• Access and correction: view and update much of your information within the Service, or contact us for help.
• Disconnect accounts: unlink any connected financial account at any time from the Connections area.
• Deletion: request deletion of your account and associated personal information, subject to information we are legally required or permitted to retain.
• Communications: opt out of non-essential emails using the unsubscribe link or by contacting us; we may still send service and security messages.

Depending on where you live, you may have additional rights under applicable law (for example, to know, access, correct, delete, or limit certain uses of your information, and not to be discriminated against for exercising those rights). To exercise any right, email us at [email protected]. We will verify your request and respond as required by law.

9. Financial information notice

Because Spero provides financial services, certain information we handle may be subject to financial-privacy laws such as the Gramm-Leach-Bliley Act. We collect and use nonpublic personal financial information only to provide and support the Service and as described in this Policy, and we maintain safeguards to protect it. We do not sell this information.

10. Cookies

We use cookies and similar technologies that are strictly necessary to sign you in, keep your session secure, and remember your preferences, along with limited analytics to understand and improve usage. You can control cookies through your browser settings, but disabling necessary cookies may prevent the Service from working.

11. Children’s privacy

The Service is intended for adults and is not directed to children under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, please contact us and we will delete it.

12. Third-party links

The Service may link to third-party websites and services that we do not control. Their privacy practices are governed by their own policies, and we are not responsible for them.

13. Where your information is processed

We are based in the United States and process and store information in the United States. If you access the Service from outside the U.S., you understand your information will be processed in the U.S.

14. Spero Amazon Sync browser extension

Spero Amazon Syncis an optional browser extension that helps you categorize your Amazon purchases by what you actually bought, instead of an opaque “AMAZON.COM” bank charge. This section describes how the extension handles your information and supplements the rest of this Policy.

What it accesses

• Your Amazon order detail, read from your own logged-in amazon.com session in your own browser: item names, quantities, prices, order dates, and the recipient (“ship to”) name shown on your order pages.
• Your Spero Intelligence session, so it can send that order detail to your own Spero account. You sign in through the normal Spero login (Microsoft single sign-on); the extension captures the resulting session token.

What it does not do

• It never reads, stores, or transmits your Amazon username, password, or payment details. Your Amazon login never leaves your browser.
• It does not sell or share your data, serve advertising, or track your browsing.

What leaves your browser

The only data the extension sends is the item detail described above, and it is sent only to your own Spero Intelligence instance, over HTTPS, authenticated with your Spero session. Spero uses it to match each Amazon order to the corresponding bank transaction and categorize it by its contents. The extension stores your Spero session token and a few preferences locally in your browser and clears them when you sign out. It also displays which amazon.com account is signed in (the name shown in Amazon’s own greeting); that name stays in your browser and is never transmitted.

Extension permissions

• Cookies & site access(amazon.com, sperocfo.com, and supabase.co — Spero’s authentication backend): read your Amazon session to fetch your orders, your Spero session to send them, and refresh your own Spero session token so syncs stay signed in.
• Tabs: manage the extension’s own tabs only — open a background tab to read your Amazon order pages during sync (then close it) and open the Spero connect page when you sign in. It never reads your other tabs or browsing.
• Scripting: read the rendered order pages in a background tab.
• Storage: remember your session and preferences (cleared on sign-out).
• Alarms: run the optional daily automatic sync.
• Notifications: tell you when sign-in is captured or a sync needs attention.

15. Changes to this Policy

We may update this Policy from time to time. When we do, we will revise the “Last updated” date above and, for material changes, provide additional notice as appropriate. Your continued use of the Service after an update means you accept the revised Policy.

16. Contact us

Questions or requests about this Policy or your information? Contact us at [email protected].

Spero Financial Group LLC (d/b/a Spero CFO)
Email: [email protected]