Privacy Policy

Sembroni Tech Inc. (“Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Fluence mobile application and related services (collectively, the “Service”).

By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

This Privacy Policy applies only to users in the United States. The Service is intended for users located in the United States.

We use the information we collect for the following purposes:

• Provide the Service: To operate, maintain, and deliver the features and functionality of the Service.
• Financial Analysis: To aggregate, categorize, and display your financial data; calculate KPIs; and generate insights.
• AI Features: To power the conversational AI interface and provide responses to your financial queries. We use automated processing and machine learning models to analyze your financial data and generate business KPIs. We do not use your identifiable financial data or clinic-specific inputs to train our global or foundation AI models for use by other customers. Your data is siloed to your specific account for the purpose of generating your unique insights. We reserve the right to modify or substitute AI models used in the Service at any time.
• Account Management: To create and manage your account, process subscriptions, and provide customer support.
• Communications: To send you service-related communications, including account verification, billing notifications, and important updates.
• Security: To detect, prevent, and address fraud, unauthorized access, and other security issues.
• Improvement: To analyze usage patterns and improve the Service's features, functionality, and user experience.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes.

Fluence uses artificial-intelligence services to automatically categorize your financial transactions and to power our in-app financial assistant (“Fluence AI”). This section explains, in detail, what data is shared with these services, who processes it, and the protections that apply.

• What We Process with AI: To provide these features, we send the following to our AI provider: transaction details (merchant name, amount, date, and category), connected account names and balances, and your clinic's location (city, state, and ZIP code). We do not send your bank login credentials, full bank account numbers, or government-issued identifiers.
• Who Processes It: This processing is performed by Google's Gemini models running on Google Cloud Vertex AI. Under Google Cloud's terms, data submitted to Vertex AI is not used to train Google's models and is subject to Google Cloud's data-protection commitments, which provide protections equivalent to those described in this Privacy Policy.
• Your Consent: Before any data is shared with these AI services, the app presents a disclosure and obtains your consent during sign-up.
• Data Minimization: We limit the information sent to AI services to what is necessary to provide the feature, and we remove identifiers that are not needed.

We do not use your identifiable financial data or clinic-specific inputs to train our own global or foundation AI models for use by other customers, and we do not use AI to make “consequential decisions” (e.g., credit lending or employment). We reserve the right to modify or substitute the AI models used in the Service at any time, subject to equivalent data-protection commitments.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

We may share your information only in the following limited circumstances:

We retain your personal information for as long as your account is active or as needed to provide you the Service. Upon account deletion or termination:

• Permanent Deletion: If you delete your account through the application, data deletion is immediate. If you request deletion through the operations support channel (support@sembroni.tech), it may take up to thirty (30) days to permanently delete all data. Audit and security logs may be retained in accordance with our cloud infrastructure provider's retention policies for security, fraud prevention, and legal compliance purposes.
• Anonymized Data: We may retain anonymized and aggregated data that cannot be used to identify you for analytical and improvement purposes.
• Legal Requirements: We may retain certain information as required by law or for legitimate business purposes, such as resolving disputes or enforcing our agreements.

Data Retention Schedule. To ensure transparency, we adhere to the following retention periods:

• Active Account Data: Retained for the duration of your subscription.
• Deleted Account Data: Permanently deleted within thirty (30) days of your request, except where retention is required by law (e.g., tax or audit records).
• AI Interaction Logs: AI interaction logs follow the same deletion policy as all other user data.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purposes for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
• No Sale of Personal Information: We do not sell your personal information as defined under the CCPA.

To exercise your CCPA rights, please contact us at support@sembroni.tech. We will verify your identity before processing your request.

The Service is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from anyone under 18 years of age. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at support@sembroni.tech. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information.

The Service may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access.

Neither Party will be liable for any failure or delay in performance (other than for delay in payment of fees) due to causes beyond its reasonable control, including, but not limited to, acts of God, war, riot, embargoes, acts of civil or military authorities, fire, flood, accident, strikes, telecommunications failure, or internet service provider failures. The party experiencing such an event shall notify the other party within a reasonable time, use diligent efforts to resume performance, and the time for performance shall be extended for a period equal to the duration of the event.

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on our website and/or within the Service, and by updating the “Effective Date” at the top of this Privacy Policy. Your continued use of the Service after the posting of changes constitutes your acceptance of such changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

We will respond to your inquiry within a reasonable timeframe.