Privacy Policy

Effective date: [To be set at publication]
Last updated: [To be set at publication]

1. Controller Identity

The data controller for the personal data described in this policy is [Operator name and contact to be specified, e.g. Arnstein Banking Systems]. You can contact us at [contact email or form] for privacy-related requests.

2. Data We Collect

We collect the following data in connection with the CornerStone Agentic Score Service:

• Wallet addresses that you register on the allowlist (EVM and/or Aptos). These can be associated with you or with an agent you control.
• Banking application / compliance information (optional), if you provide it during onboarding: full name, email address, and optionally physical address. This is stored in our submissions file (e.g. last 100 entries) for demo and compliance workflow purposes.
• Plaid connection metadata: when you link a bank account via Plaid, we store a record that associates a Plaid access token and item identifier with an agent wallet and timestamp. We do not store your bank account numbers, balances, or transaction history in our databases; that data remains with Plaid and your financial institution.
• Attestation data (if you use wallet attestation): we may store that an attestation was received for a given address and when, for compliance and audit purposes.

We do not collect: raw bank account or transaction data, social security numbers, or payment card numbers in our systems. Plaid Link is used to connect your bank; Plaid’s own terms and privacy policy apply to the data Plaid collects and processes.

3. Purpose and Legal Basis

We use the data above to:

• Operate the Service (allowlist, scoring, bank-linked borrower signal).
• Provide and improve the MCP tools (predictions, backtests, bank linking, scores).
• Comply with legal and regulatory obligations and to defend our rights.
• Fulfill our contract with you (e.g. to provide the features you request).

Legal basis: performance of our contract with you; our legitimate interests in operating and securing the Service; and, where required, your consent (e.g. for bank linking and optional compliance information).

4. How We Use Data

• Allowlist and agent wallets: Used to determine which addresses can call paid MCP tools and to associate Plaid-linked accounts with an agent for borrower scoring.
• Banking application / submissions: Used for identity and compliance workflows and for demo purposes; may be retained as part of application history.
• Plaid connection data: Used only to indicate that a given agent wallet has a linked bank account (e.g. to return a borrower score component). We do not pull or store your transaction or balance data in our schema.
• Attestations: Used to verify that you control the wallet addresses you register and for audit/compliance records.

5. Sharing

We may share data with:

• Plaid: When you link a bank account, Plaid receives and processes data per their terms and privacy policy. We send only what is necessary to create and exchange the link (e.g. client user id, products, country).
• Infrastructure and service providers: Hosting, databases, and other technical services that process data on our behalf, under appropriate agreements.
• Legal and regulatory: When required by law, court order, or to protect our rights, safety, or property.

We do not sell your personal data.

6. Retention

• Plaid connections: Retained until you revoke the connection or we no longer need it for the Service (e.g. scoring). We may retain connection metadata for a longer period if required for legal or audit purposes (e.g. up to 7 years where applicable).
• Submissions (banking application): We retain the last 100 entries; older entries may be overwritten. Specific retention may be extended for legal or compliance reasons.
• Allowlist: Retained until you remove addresses or we terminate the Service for that data.
• Attestations: Retained for the period needed for compliance and audit (e.g. up to 7 years if required by counsel).

7. Security

We take reasonable technical and organizational measures to protect your data, including securing databases (e.g. file permissions, environment-based credentials), using HTTPS, and not logging sensitive tokens or full wallet addresses in production where avoidable. No system is completely secure; you use the Service at your own risk.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you.
• Correct inaccurate data.
• Delete your data, subject to legal and operational constraints (e.g. we may need to retain some data for legal or audit purposes).
• Portability of your data in a structured format where technically feasible.
• Object or restrict certain processing.
• Withdraw consent where processing is based on consent (e.g. you can revoke bank linking via Plaid or by contacting us).

To exercise these rights:

• Export your data (access/portability): Request a copy of the data we hold about you by calling GET /privacy/export?email=YOUR_EMAIL or GET /privacy/export?wallet=YOUR_WALLET_ADDRESS on this application’s onboarding site (e.g. https://your-onboarding-site.example/privacy/export?email=you@example.com). You can use a browser or a tool like curl. The response is JSON describing submissions, allowlist entries, and Plaid connection metadata for the given email or wallet.
• Delete your data (erasure): You must prove you control the wallet by signing a deletion-authorization message. (1) Request a message: GET /privacy/delete-message?wallet=0x.... (2) Sign that message with your wallet (e.g. MetaMask for EVM, or the Aptos attestation script). (3) Send POST /privacy/delete with JSON: wallet, message, signature, and chain ("evm" or "aptos"); for Aptos include public_key_hex. Optionally include email to also remove submissions that match that email and this wallet. The server verifies your signature before deleting. Some data may be retained where required by law.

You can also contact us at [contact email]. You may have the right to lodge a complaint with a supervisory authority.

9. Cookies and Analytics

The onboarding site may use minimal technical cookies or similar technologies necessary for the operation of the site (e.g. session or security). If we add analytics or non-essential cookies in the future, we will update this policy and, where required, obtain consent.

10. Changes and Contact

We may update this Privacy Policy from time to time. We will post the updated policy and, where appropriate, notify you. Continued use of the Service after the effective date of changes constitutes acceptance of the updated policy.

Contact: For privacy questions or to exercise your rights, contact us at [contact email or form to be specified].