Privacy Policy
Last Updated: April 2026
ProCap Financial, Inc. and its subsidiaries
1. Introduction and Scope
This Privacy Policy (“Policy”) describes how ProCap Financial, Inc. and its subsidiaries, including Silvia Technologies, Inc. (collectively, “ProCap,” “we,” “us,” or “our”), collect, use, disclose, retain, and protect personal information when you visit our websites, use our products and services, or otherwise interact with us.
This Policy covers all products and services operated by ProCap and its subsidiaries, including:
- CFO Silvia: An AI-powered personal finance platform operated by Silvia Technologies, Inc. at www.cfosilvia.com and through web and mobile applications, APIs, and related services.
- ProCap Insights: A subscription content service providing AI-generated financial news, analysis, and research, available through www.procapinsights.com.
- ProCap Financial Website: The corporate website at www.procapfinancial.com.
Collectively, these are referred to as the “Services.” Where data practices differ between products, this Policy includes product-specific sections clearly labeled as such (see Section 13).
This Policy is incorporated into the ProCap Financial, Inc. Terms and Conditions of Use and any applicable Supplemental Terms. By using the Services, you acknowledge that you have read this Policy. This Policy does not apply to third-party services you may connect to through the Services; those are governed by their own privacy policies.
Geographic Focus: The Services are designed for and primarily offered to users in the United States. We do not specifically target or market to users in the European Union, United Kingdom, or other jurisdictions outside the United States. However, because the Services are accessible globally, this Policy includes provisions addressing the rights of users in those jurisdictions where applicable.
Data Controllers: ProCap Financial, Inc. is the data controller for personal information collected through procapfinancial.com and ProCap Insights. Silvia Technologies, Inc. is the data controller for personal information collected through CFO Silvia. For inquiries about either controller, contact privacy@procapfinancial.com.
2. Personal Information We Collect
We collect personal information across the categories described below. The specific data elements depend on which Services you use and how you interact with them.
2.1 Account and Identity Information
Information you provide when you create an account, update your profile, or verify your identity: full name, email address, phone number, username, password (stored in hashed form), date of birth or age range, profile photo, household size, employment status, income range, financial goals, risk tolerance, authentication credentials, and login history.
2.2 Payment and Subscription Data
When you purchase a subscription: name on payment method, billing address, payment card type and last four digits, expiration date, billing ZIP code, plan type, subscription dates, billing cycle, payment amounts, transaction confirmations, and refund history. Full payment card numbers and bank account numbers are processed exclusively by our payment processor (Stripe) and are never stored on our systems.
2.3 Device, Technical, and Usage Data
Information collected automatically: IP address, browser type and version, device manufacturer and model, operating system, screen resolution, unique device identifiers, usage and interaction data (pages visited, features accessed, session duration), performance and diagnostic data (crash reports, error logs), approximate geographic location derived from IP address, referral and attribution data, and analytics data collected through PostHog and similar tools.
2.4 Marketing and Communications Data
Your marketing preferences and opt-in/opt-out status, email engagement data, referral information, survey responses, and social media interactions with our accounts.
2.5 Information from Third-Party Sources
We may receive information from payment processors, analytics providers, marketing platforms, and publicly available sources. We may combine this with information we collect directly.
2.6 Support and Feedback Data
Support communications (emails, chat transcripts, phone recordings where disclosed), feedback and ratings, beta and research participation data, and community contributions.
2.7 Product-Specific Data Collection
Additional data collected by CFO Silvia and ProCap Insights is described in Section 13.
3. How We Use Your Personal Information
We use personal information for the following purposes. For users in the EEA, UK, and Switzerland, the applicable legal basis is noted in brackets.
3.1 Service Delivery [Contract]
Providing, maintaining, and operating the Services; creating and managing accounts; processing payments and subscriptions; providing customer support.
3.2 Product Improvement [Legitimate Interests]
Analyzing usage patterns, conducting A/B testing and user research, performing internal analytics and benchmarking.
3.3 Personalization [Legitimate Interests; Consent where required]
Tailoring content, features, and recommendations based on your usage and preferences; customizing notifications and alerts; remembering settings across sessions.
3.4 Marketing [Consent; Legitimate Interests for service communications]
Sending service-related notices and administrative messages (not marketing; cannot be opted out of while you maintain an account). Sending promotional communications where you have opted in or where permitted by law. You may opt out of marketing at any time by clicking unsubscribe, adjusting preferences in account settings, or contacting privacy@procapfinancial.com.
3.5 Safety, Security, and Compliance [Legal Obligation; Legitimate Interests]
Detecting and preventing fraud, unauthorized access, and abuse; complying with applicable laws and regulations; enforcing our Terms; maintaining audit logs.
3.6 Aggregate and De-Identified Data [Legitimate Interests]
We may create aggregate or de-identified data sets by removing information that could identify you. Such data is not personal information under applicable law. Product-specific uses of anonymized data are described in Section 13.
4. Automated Decision-Making and Profiling
Certain features of the Services, particularly within CFO Silvia, involve automated processing to evaluate aspects of your financial situation, including financial health scores, behavioral profiles, risk tolerance assessments, and personalized recommendations.
No automated decision made through the Services has legal or similarly significant effects on you. CFO Silvia does not make binding financial decisions on your behalf, approve or deny credit, set insurance rates, or take any action that produces legal effects. All Outputs are informational and require your independent judgment.
If you are located in the EEA, UK, or Switzerland, you may contact privacy@procapfinancial.com to request human review of any automated Output, express your point of view, or contest any result. You may also opt out of certain profiling activities through your account settings.
5. Legal Bases for Processing (EEA, UK, and Switzerland)
Where required by applicable law, we process personal information only with a valid legal basis:
| Processing Activity | Legal Basis |
|---|---|
| Account creation, service delivery, payments | Performance of contract (Art. 6(1)(b)) |
| Marketing and promotional communications | Consent (Art. 6(1)(a)) |
| Personalization of content and features | Legitimate interests (Art. 6(1)(f)) |
| Analytics, A/B testing, product improvement | Legitimate interests (Art. 6(1)(f)) |
| AI model training using de-identified data (Silvia) | Legitimate interests (Art. 6(1)(f)); subject to opt-out |
| Fraud detection and security monitoring | Legitimate interests (Art. 6(1)(f)) |
| Legal compliance (tax, financial reporting) | Legal obligation (Art. 6(1)(c)) |
| Financial account linking (Silvia) | Consent (Art. 6(1)(a)) |
| Creation and commercialization of Anonymized Data | Legitimate interests (Art. 6(1)(f)) |
| Voice data collection (Silvia) | Consent (Art. 6(1)(a)) |
Where we rely on legitimate interests, we have conducted balancing tests to confirm our interests are not overridden by your rights. Records of our balancing assessments are available upon request to our Data Protection Officer. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
6. How We Share and Disclose Personal Information
6.1 Service Providers
We share information with trusted service providers who assist in operating the Services (cloud infrastructure, payment processors, analytics, customer support). They are contractually bound to use your data only for specified purposes and to maintain appropriate security.
6.2 Financial Integration Partners (CFO Silvia)
When you link financial accounts, your data is shared with integration partners (Plaid, SnapTrade, Coinbase) to facilitate connectivity. Data sharing is governed by your authorization and their privacy policies.
6.3 Legal and Regulatory Disclosures
We may disclose personal information to comply with law, regulation, or legal process; protect rights, property, or safety; detect or prevent fraud; or enforce our Terms.
6.4 Business Transfers
In the event of a merger, acquisition, or similar transaction, your information may be transferred to the acquiring entity. We will provide notice before your information becomes subject to a different privacy policy.
6.5 Anonymized Data Recipients (CFO Silvia)
We may license Anonymized Data derived from CFO Silvia user data to third parties for analytics, benchmarking, and research purposes. Anonymized Data is not personal information and is not subject to personal data restrictions. See Section 13.1 for details.
6.6 With Your Consent
We may share your information when you direct us to do so or provide explicit consent.
7. Sale of Personal Information
ProCap does not sell your personal information as that term is defined under the CCPA/CPRA.
Where we commercialize Anonymized Data (as described in Section 13.1), that data has been de-identified and no longer constitutes personal information. We do not knowingly sell or share the personal information of individuals under 16.
You may exercise your right to opt out of any future sale or sharing by clicking the “Do Not Sell or Share My Personal Information” link on our homepage or contacting privacy@procapfinancial.com.
8. Data Retention
We retain personal information for as long as your account is active, as needed to provide the Services, and as necessary for legal compliance, dispute resolution, and legitimate business purposes.
| Category | Retention Period | Reason |
|---|---|---|
| Account and Identity Data | Account + 3 years post-deletion | Legal compliance, fraud prevention |
| Financial Transaction Data (Silvia) | Minimum 7 years | Financial recordkeeping, tax |
| Payment and Subscription Data | Subscription + 7 years | Tax and accounting |
| Conversational Data / AI I/O (Silvia) | Account + 3 years post-deletion | Service delivery, safety review |
| Usage and Analytics Data | 2 years identifiable; then anonymized | Product improvement |
| Marketing Data | Until opt-out + 1 year suppression | Honoring opt-out preferences |
| Support and Feedback Data | 3 years from last interaction | Service quality |
| Anonymized Data | Indefinitely | Not personal information |
When personal information is no longer needed, we securely destroy, delete, or anonymize it.
9. Data Security
We implement industry-standard technical and organizational measures including: encryption in transit (TLS 1.2+) and at rest (AES-256), role-based access controls, regular security assessments and penetration testing, incident response and breach notification procedures, employee security training, and SOC 2 Type II compliant infrastructure.
9.1 Breach Notification
For GDPR: we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay where required. For U.S. residents: we will comply with applicable state breach notification laws. No method of transmission or storage is 100% secure. We encourage you to use strong passwords and enable two-factor authentication.
10. Cookies and Tracking Technologies
We use cookies and similar technologies for session management, analytics, preferences, and integration functionality. We do not use third-party advertising cookies on CFO Silvia. Full details are in our Cookie Policy at www.procapfinancial.com/cookies.
You can manage cookie preferences through your browser settings or our cookie consent mechanism. We honor Global Privacy Control (GPC) signals where required by law.
11. Your Rights and Choices
11.1 Access and Portability
You may request a copy of the personal information we hold about you in a structured, commonly used, machine-readable format.
11.2 Correction
You may request that we correct inaccurate or incomplete personal information.
11.3 Deletion
You may request deletion, subject to certain exceptions (legal compliance, fraud prevention, contractual obligations). You can delete your account through account settings or by contacting privacy@procapfinancial.com.
11.4 Restriction, Objection, and Withdrawal of Consent
You may request restriction of processing, object to processing based on legitimate interests, or withdraw consent at any time. Withdrawal may limit available features as described in Section 5.
11.5 Opt-Out of Marketing
Follow unsubscribe instructions in any marketing email, adjust notification preferences, or contact privacy@procapfinancial.com.
11.6 Global Privacy Control
We honor GPC signals where required by law. We do not currently respond to browser-based Do Not Track (DNT) signals, as there is no uniform standard.
11.7 Right to Appeal
If we decline a privacy request, you may appeal by contacting privacy@procapfinancial.com with the subject line “Privacy Rights Appeal.”
11.8 Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights.
To exercise any right, contact privacy@procapfinancial.com. We will verify your identity and respond within the timeframes required by applicable law (generally 30 to 45 days).
12. State and International Privacy Disclosures
12.1 California (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act. This section describes our practices for the preceding 12 months.
Categories of personal information collected, sources, business purposes, and categories of recipients are described in Sections 2, 3, and 6. We have not sold personal information in the preceding 12 months. We have not shared personal information for cross-context behavioral advertising. We collect financial account information as sensitive personal information and use it only as necessary to perform the Services.
Your California Rights: Right to Know, Right to Delete, Right to Correct, Right to Opt Out of Sale/Sharing, Right to Limit Sensitive PI, Right to Non-Discrimination. You may designate an authorized agent with written proof of authorization.
12.2 Virginia, Colorado, Connecticut, Texas, and Other U.S. States
Residents of states with comprehensive privacy laws have similar rights to access, correct, delete, and opt out of certain processing. Contact privacy@procapfinancial.com to exercise your rights. If we decline a request, you have the right to appeal.
12.3 European Economic Area, United Kingdom, and Switzerland
While the Services are designed for and primarily offered to US residents, if you are located in the EEA, UK, or Switzerland and use the Services, the following applies: legal bases for processing are in Section 5, your rights are in Section 11, automated decision-making information is in Section 4, and international transfer safeguards are in Section 14. You have the right to lodge a complaint with your local data protection authority.
12.4 Canada
Canadian residents may have rights under PIPEDA and provincial legislation. Your information may be transferred to and processed in the United States.
12.5 Brazil
If you are located in Brazil, you have rights under the LGPD including confirmation of processing, access, correction, anonymization, portability, deletion, and information about sharing. Contact privacy@procapfinancial.com.
13. Product-Specific Data Practices
13.1 CFO Silvia
13.1.1 Additional Data Collected
In addition to the categories in Section 2, CFO Silvia collects:
- Financial Account and Transaction Data: Linked account data (names, types, masked numbers, balances, status), transaction records (date, amount, merchant, category, status), investment holdings (securities, cost basis, market value), cryptocurrency data (public wallet addresses, token balances), debt and liability data (loan balances, interest rates, payment schedules), and real estate data (property values, mortgage details).
- Inputs, Prompts, and Conversational Data: All text, voice, and other inputs through chat, voice, SMS, email, or other channels; AI-generated Outputs; full conversation history; uploaded files and documents; voice recordings and transcriptions.
- Derived and Inferred Data: Financial insights and scores (net worth, cash flow, savings rate), behavioral profiles (spending patterns, income regularity), risk assessments, AI model outputs (recommendations, forecasts, alerts), and automated categorizations.
13.1.2 AI Model Training
We use CFO Silvia Inputs, Outputs, and feedback to train, evaluate, and improve our AI models. Data used for training is de-identified or anonymized before use. You may opt out through Account Settings > Privacy > Model Training or by contacting privacy@cfosilvia.com. Opting out does not degrade service quality or affect our ability to use your data for runtime processing or to create Anonymized Data.
Regardless of opt-out, we may use data flagged for safety review, submitted as explicit feedback, or reported for violations, for maintaining the safety and integrity of the Services.
13.1.3 Anonymized Data Program
Silvia Technologies may create anonymized, de-identified, or aggregated data sets from CFO Silvia user data (“Anonymized Data”). Once anonymized, this data is no longer personal information and may be used, licensed, and otherwise commercialized for lawful purposes, including industry benchmarking, market research, analytics products, academic research partnerships, and improving machine learning models.
Anonymization Standards: Removal of all direct identifiers; suppression, generalization, or perturbation of quasi-identifiers; application of k-anonymity, l-diversity, or differential privacy techniques as appropriate; validation testing against re-identification before external use; compliance with CCPA/CPRA de-identification requirements, GDPR anonymization standards, and NIST de-identification guidelines.
Protections: All third-party recipients are bound by agreements that prohibit re-identification, restrict downstream sharing, require breach notification and data deletion upon termination, and include audit rights. The program is subject to periodic privacy team review, annual re-identification risk assessments, and board-level reporting.
13.2 ProCap Insights
13.2.1 Additional Data Collected
ProCap Insights collects: which articles and content you access, time spent on each piece, content preferences, reading history, navigation patterns, report open rates, click-through behavior, and engagement metrics.
13.2.2 AI-Generated Content and Your Data
We do not use your personal information as inputs to the AI models that generate ProCap Insights content. We may use aggregate, de-identified usage data to inform editorial decisions. We do not sell or provide your personal information to third-party AI model providers for training.
13.2.3 No Anonymized Data Commercialization
ProCap Insights does not create anonymized data sets from subscriber data for sale or licensing. We may use aggregate usage data internally for product improvement only.
14. International Data Transfers
ProCap Financial, Inc. is based in the United States. If you access the Services from outside the United States, your personal information will be transferred to and processed in the United States.
Where required by applicable law, we implement appropriate safeguards including Standard Contractual Clauses (SCCs), adequacy decisions, the EU-U.S. Data Privacy Framework (and UK/Swiss extensions where applicable), and consent where required.
15. Children's Privacy
The Services are not intended for individuals under 18. We do not knowingly collect personal information from anyone under 18. If we learn we have collected information from a child under 18, we will promptly delete it. Contact privacy@procapfinancial.com if you believe a child has provided us with personal information.
16. Third-Party Links and Integrations
The Services may contain links to third-party websites and services. We do not control them and are not responsible for their privacy practices. This Policy does not apply to third-party services.
17. Data Protection Officer
ProCap has designated a Data Protection Officer responsible for overseeing data protection compliance:
Email: dpo@procapfinancial.com
Mailing Address: Data Protection Officer, ProCap Financial, Inc., 600 Lexington Avenue, New York, NY 10022
Because the Services are designed for and primarily offered to users in the United States, ProCap has not appointed representatives in the European Union or United Kingdom under GDPR Article 27 or UK GDPR at this time. If our user base in those jurisdictions grows to a point where appointment is required, we will update this Policy with the relevant contact information.
18. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will update the effective date, post the updated Policy, notify you by email, and where required by law, obtain your consent. Your continued use after changes constitutes acceptance.
19. Contact Us
ProCap Financial, Inc.
600 Lexington Avenue, New York, NY 10022
Privacy Inquiries: privacy@procapfinancial.com
Data Protection Officer: dpo@procapfinancial.com
Security: security@procapfinancial.com
General Support: support@procapfinancial.com
Legal Notices: legal@procapfinancial.com
For CFO Silvia privacy inquiries: privacy@cfosilvia.com