Comodo

Privacy Policy

Last updated: June 15, 2026

This Privacy Policy explains how Billi, Inc. (“Comodo,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you use the Comodo mobile application and related services (the “Service”). Comodo is a group-expense platform: groups link their bank accounts, set up shared expenses, and Comodo splits those expenses and collects each member’s share by ACH bank transfer.

Comodo is a financial technology company, not a bank. Banking services and the deposit accounts used to hold and move funds are provided by our partner bank, [CONFIRM — Unit partner bank, e.g. “Thread Bank, Member FDIC”], through our banking-platform provider, Unit. Bank-account linking is powered by Plaid. Because we handle sensitive financial and identity information, we treat its protection as a core part of the Service.

1. Who this policy covers

This policy applies to people who create a Comodo account and use the Service. You must be at least 18 years old and a U.S. resident to use Comodo. The Service is not directed to children, and we do not knowingly collect personal information from anyone under 18.

2. Information we collect

2.1 Information you provide

• Account information: your email address, password, full name, and phone number. (Your password is stored only in salted, hashed form; we never see it in plain text.)
• Identity-verification information (KYC): to comply with U.S. federal law (the Bank Secrecy Act / USA PATRIOT Act customer identification requirements), we and our banking partners must verify your identity before you can move money. This includes your legal name, date of birth, residential address, and government identifiers — your Social Security number (for U.S. persons) or passport number and issuing country (for non-U.S. persons) — and, where required, images of an identity or address-verification document that you upload.
• Group and expense information: the groups you create or join, group billing address, the expenses you add (such as rent, insurance, subscriptions, or internet), amounts, schedules, and how each expense is split among members.
• Authorizations: records of the consents and authorizations you give, including your NACHA ACH debit authorization for each shared expense.
• Communications: information you provide when you contact support.

2.2 Information from connecting your bank (Plaid)

When you link a bank account, you do so through Plaid Inc. You enter your bank credentials directly into Plaid’s interface — Comodo never sees or stores your online-banking username or password. Plaid provides us with a limited-access token and information needed to operate the Service, which may include your account and routing numbers, account name and type, account balances, the financial institution’s name, and transaction information (including recurring-transaction “streams” we use to help you set up shared expenses). Plaid’s handling of your information is governed by the Plaid End User Privacy Policy.

2.3 Information from operating your accounts and payments

To provide deposit accounts and move money, our banking partners (Unit and [CONFIRM — Unit partner bank, e.g. “Thread Bank, Member FDIC”]) and our payments processors create and share with us information such as virtual account and routing numbers, account status, transfers, obligations, settlement status, and the results of identity and fraud checks.

2.4 Information collected automatically

• Device and diagnostic data: app version, device type and operating system, and crash and error diagnostics. We use Sentry for error monitoring and configure it to scrub personal and financial identifiers from reports.
• Push notification token: if you enable notifications, a device push token so we can send you transaction and group updates. Push notifications never contain full financial account numbers.

Comodo is a native mobile app and does not use advertising cookies or third-party advertising trackers.

3. How we use your information

• To create and operate your account and the Service;
• To verify your identity and comply with “know your customer,” anti-money-laundering, and other legal obligations;
• To link your bank account and initiate, process, and settle the ACH transfers that fund your shared expenses;
• To calculate and collect each member’s share of group expenses;
• To detect, prevent, and investigate fraud, unauthorized transactions, and other prohibited or unsafe activity;
• To provide customer support and respond to your requests;
• To send you service-related communications and, if enabled, push notifications;
• To maintain the security and integrity of the Service; and
• To comply with applicable law and enforce our Terms of Service.

We do not use your bank-account or transaction information for advertising, and we do not sell it.

4. How we share your information

We share personal information only as described here:

• Banking and payments partners. With Unit (banking platform) and [CONFIRM — Unit partner bank, e.g. “Thread Bank, Member FDIC”] (partner bank) to open and operate deposit accounts and move funds; and with Plaid to link your bank account. These partners process your information under their own privacy policies and the agreements that govern your accounts.
• Service providers. With vendors who process information on our behalf and under contract — for example, cloud hosting and database infrastructure (including Supabase, which we use for authentication), and error monitoring (Sentry). They may use the information only to provide services to us.
• Identity and fraud checks. With identity-verification and fraud-prevention providers used by us or our banking partners.
• Legal and safety. When we believe it is required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Comodo, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to this policy.
• With your direction. When you ask us to share information or otherwise direct us to do so (for example, members of a group can see the group’s expenses, the split allocation, each member’s name, and payment status).

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

5. Other group members

Comodo is a shared, group-based product. When you join a group, other members of that group can see your name, your share of each shared expense, and the status of your payments toward those expenses. They cannot see your Social Security number, full bank-account number, or KYC documents.

6. Data retention

We keep personal information for as long as your account is active and as needed to provide the Service. We retain identity-verification and transaction records for longer where the law requires it — for example, U.S. financial recordkeeping rules generally require customer-identification and certain transaction records to be retained for at least five years after an account is closed. After applicable retention periods expire, we delete or de-identify the information.

7. How we protect your information

We use technical and organizational safeguards designed to protect your information, including encryption of data in transit, encrypted device storage of authentication tokens (using the iOS Keychain / Android Keystore), masking of account numbers in the app, and access controls. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

8. Your rights and choices

• Access and correction. You can view and update certain profile information in the app, and you can contact us to request access to or correction of your personal information.
• Account deletion. You can delete your account from within the app (Settings) or by contacting us at privacy@billi.solutions. Some information must be retained after deletion where the law requires (see “Data retention”), and outstanding obligations must be settled before an account can be closed.
• Push notifications. You can turn off push notifications in your device settings.
• State privacy rights. Depending on where you live (for example, California and certain other U.S. states), you may have rights to know, access, correct, delete, and obtain a portable copy of your personal information, and to be free from discrimination for exercising these rights. Because much of the financial data we handle is regulated by the federal Gramm-Leach-Bliley Act, some state-law rights may not apply to that data. To exercise a right, contact us at privacy@billi.solutions; we will verify your request before acting on it. [CONFIRM with counsel which state privacy laws apply and finalize this section.]

9. Where your information is processed

Comodo is intended for users in the United States, and we process and store information in the United States.

10. Third-party services and links

The Service relies on third parties (such as Plaid, Unit, [CONFIRM — Unit partner bank, e.g. “Thread Bank, Member FDIC”], and Apple) and may link to their interfaces or terms. Their handling of your information is governed by their own privacy policies, which we encourage you to review.

11. Changes to this policy

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

12. Contact us

If you have questions about this policy or our privacy practices, contact us at:

Billi, Inc.
Privacy: privacy@billi.solutions
Support: support@billi.solutions
[CONFIRM — company mailing address]