Legal

Privacy Policy

Last updated: July 1, 2026

This Privacy Policy (“Policy”) describes how Inclusiv Finances, Inc. (“Inclusiv,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you visit www.carla.money, use Carla, our conversational banking platform, through WhatsApp or other channels, or access financial products we offer (including virtual accounts, money transfers, and related services).

If you are a U.S. consumer who obtains financial services from us primarily for personal, family, or household purposes, please also read our GLBA Consumer Privacy Notice, which explains how we share nonpublic personal information and your rights under federal law.

1. Who we are

Inclusiv Finances, Inc. provides AI-powered conversational banking infrastructure and financial services for individuals and financial institutions through the Carla platform. We operate from Guatemala and serve customers in the United States, Guatemala, and other regions where our services are available.

For privacy-related questions or requests, contact us at privacy@carla.money.

2. Information we collect

We may collect the following categories of personal information:

• Identity and contact information — name, date of birth, government-issued identification numbers, address, email address, and phone number (including WhatsApp number).
• Financial information — bank account numbers, routing numbers, transaction history, account balances, payment instructions, and remittance details.
• Verification data — selfies, biometric or liveness-check data, OTP verification records, and identity verification results from authorized providers.
• Communications and usage data — messages exchanged through our services, support interactions, device identifiers, IP address, browser type, and log data about how you use our website and services.
• Compliance data — information required for anti-money-laundering (AML), know-your-customer (KYC), sanctions screening (including PEP/OFAC), fraud prevention, and regulatory reporting.

We collect this information directly from you, from financial institutions and partners you choose to connect with, from identity verification providers, and automatically when you use our services.

3. How we use information

We use personal information to:

• Provide, operate, and improve our conversational banking and financial services.
• Open and maintain accounts, process transfers and payments, and deliver transaction confirmations.
• Verify your identity, authenticate transactions, and prevent fraud and unauthorized activity.
• Comply with applicable laws, regulations, court orders, and requests from regulators or law enforcement.
• Communicate with you about your account, service updates, and security alerts.
• Analyze and improve service performance, user experience, and security.
• Enforce our terms and protect the rights, property, and safety of Inclusiv, Carla, our users, and others.

4. How we share information

We may share personal information with:

• Payment and financial services partners — including Stripe and partner financial institutions that help us provide virtual accounts, payment processing, treasury services, and international transfers.
• Identity and compliance providers — to verify identity, perform sanctions screening, and meet regulatory obligations.
• Service providers — cloud hosting, analytics, customer support, and security vendors that process data on our behalf under contractual safeguards.
• Financial institution clients — when you use Carla through a bank, cooperative, or fintech that has integrated our platform, we may share information necessary to complete your requested transactions under their program.
• Legal and regulatory recipients — when required by law or to respond to valid legal process.
• Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections.

We do not sell your personal information. We do not share personal information with nonaffiliated third parties for their own marketing purposes without your consent, except as permitted by law.

Stripe and financial partners

We use Stripe for payments, treasury services, fraud prevention, analytics, and related financial infrastructure. Stripe may collect personal data, including via cookies and similar technologies. The personal data Stripe collects may include transactional data and identifying information about devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud prevention and detection, authentication, and analytics related to the performance of its services. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

When you use financial products issued or held in partnership with a bank, that institution’s privacy policy may also apply. We encourage you to review the privacy policies of our financial partners associated with your product.

5. Cookies and similar technologies

Our website may use cookies and similar technologies to operate the site, remember preferences, measure traffic, and improve security. You can control cookies through your browser settings. Disabling cookies may affect certain site features.

6. Data retention

We retain personal information for as long as needed to provide services, comply with legal and regulatory obligations (including financial recordkeeping requirements), resolve disputes, and enforce our agreements. Retention periods vary depending on the type of data and applicable law.

7. Security

We implement administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, monitoring, and contractual requirements for service providers. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

8. International transfers

Inclusiv operates globally. Your information may be processed in Guatemala, the United States, and other countries where we or our service providers maintain facilities. When we transfer personal information across borders, we use appropriate safeguards as required by applicable law.

9. Your rights and choices

Depending on where you live, you may have rights to access, correct, delete, or obtain a copy of your personal information; to object to or restrict certain processing; and to withdraw consent where processing is consent-based. U.S. residents may have additional rights under state privacy laws.

To exercise your rights, email privacy@carla.money. We may need to verify your identity before responding. If you are a U.S. consumer with a financial services relationship, certain sharing limits are described in our GLBA Consumer Privacy Notice.

10. Children

Our services are not directed to individuals under 18, and we do not knowingly collect personal information from children. If you believe we have collected information from a child, contact us and we will take appropriate steps to delete it.

11. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date at the top indicates when it was last revised. Material changes will be posted on this page. Your continued use of our services after an update constitutes acceptance of the revised Policy, to the extent permitted by law.

12. Contact us

Inclusiv Finances, Inc.
Email: privacy@carla.money
Website: https://www.carla.money