Oregano

Legal

Privacy Policy

Last updated: 25 October 2026

Your privacy is core to how Oregano is built. This policy explains what we collect, why, and the choices you have.

1. What we collect

We collect the account information you provide (such as your name and email), what you tell the assistant, the files you upload, and the data necessary to deliver the service. If you link a bank or investment account, we also receive the financial data described in section 3.

If you sign in with Google, X or Apple, they share your name and email address with us (X only when your X account has one it shares), and Google also shares your profile picture. X also shares your public profile: your username, bio, location, website, follower and post counts, and whether your account is verified. We do not ask any of them for access to anything else in your account.

When you visit our homepage or request an invitation, we also collect limited technical context supplied by your browser and hosting network: a one-way hash of your IP address and browser signature, approximate country, region, and city, timezone, locale, browser, operating system, device type, referral source, and campaign tags. We do not retain the raw IP address for this tracking. Where you allow measurement, we also set a random first-party visitor identifier that links repeat visits. This information helps us prevent referral abuse, understand demand, and operate the launch.

After you request an invitation, we ask a few questions: where you live, what you have, which countries your savings and investments are in and where you would like to invest next, where you invest today, and, if you like, a question about your money in your own words. We keep your answers with your request to decide whom to invite and to prepare your first plan, and they are deleted with your request.

When you use the mutual fund checker, open a shared link, or answer one of our surveys, we record the IP address your request came from to prevent abuse. We remove it after 30 days and keep only the country it came from.

2. How we use it

We use your information to operate Oregano, answer your questions about your holdings, secure your account, prevent fraud and abuse, meet our legal obligations, and improve the product. We do not sell your personal data, and we do not use it for advertising.

We share it only with the service providers that run Oregano for us, listed on our data retention page, under terms that limit them to that purpose; with a regulator or court where the law requires it; and with a buyer if Oregano is ever acquired, who must honour this policy. We share it with anyone else only when you ask us to.

3. Linking financial accounts with Plaid and SnapTrade

If you choose to link a bank, card, loan, or investment account, we use Plaid Inc. (“Plaid”) to connect to your financial institution. Linking is optional, and Oregano works without it. Plaid is available for accounts in the United States.

How it works

When you select Connect, Plaid's window opens on top of Oregano. You choose your institution and sign in there. Plaid collects your institution credentials (or, at institutions that support it, uses a secure connection that never shares them), and we never see or store your username or password. Plaid then gives us a token that lets us fetch the data you approved.

What we receive

Depending on what your institution supports and what you approve in Plaid's window: account names, types, and masked account numbers; balances; up to two years of transaction history, including amounts, dates, merchants, and categories; recurring payments; investment holdings and investment transactions; and loan and credit card details such as balances, interest rates, and payment dates. We do not request full account or routing numbers.

What we do with it

We use it to show you your accounts, calculate your net worth and portfolio, and let the assistant give you advice grounded in your real numbers. We do not sell it, share it for advertising, or use it for any purpose you have not been told about here. Access is read-only: Oregano cannot move money, place trades, or change anything at your institution. We sync in the background while a connection is active, and you can refresh at any time.

What Plaid does with it

Plaid acts on your instructions to retrieve your data and pass it to us. Plaid also collects, uses, and shares information about you under its own privacy policy, including to provide and improve its services and to prevent fraud, and may hold it whether or not you keep using Oregano.

By linking an account, you grant Oregano and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid End User Privacy Policy, which explains this in full. To see what Plaid holds about you and to manage or revoke access, go to my.plaid.com.

Your choices

You can remove a linked account at any time under Connected accounts on your dashboard or in the app. We then disconnect it at Plaid and delete its accounts, balances, and transactions from Oregano, and deleting your account does the same for every connection. Portfolio history already calculated from a connection stays with your account until you delete it, so recommendations made from it keep their evidence. You can also revoke access from your bank's security settings. See section 7 for timings.

Brokerages through SnapTrade

To link a brokerage or crypto account Plaid does not reach, including brokerages in Canada, the United Kingdom and Europe, Australia, and India, we use SnapTrade, a service of Passiv Inc. (“SnapTrade”). SnapTrade's window opens on top of Oregano, where you choose your brokerage and sign in to it, either at the brokerage itself or in SnapTrade's window. We never see or store your username or password. SnapTrade keeps the connection under a SnapTrade user it creates for your Oregano account, identified by a random id rather than your name or email.

Through it we receive your brokerage accounts' names, types, and masked account numbers; cash balances; positions with their prices and cost; and the account's activity, such as trades, dividends, deposits, and fees, as far back as your brokerage provides it. We use it exactly as described above for Plaid. The connection is read-only: Oregano cannot place trades or move money.

SnapTrade processes your information under the SnapTrade Privacy Policy and the SnapTrade Terms and Conditions, which you accept in its window. When you remove a SnapTrade connection we delete it at SnapTrade and remove its data from Oregano as described above; deleting your Oregano account also deletes your SnapTrade user, which ends every connection under it.

4. How we protect it

We follow industry-standard practices for protecting customer data, including encryption in transit and at rest and least-privilege access throughout our systems. Staff access to customer data requires a second factor. Tokens that connect your linked accounts are stored encrypted and are never sent to your browser. No system is perfectly secure, so if a breach affects you we will tell you as the law requires.

5. Analytics providers

On our public pages (the homepage, about, pricing, contact, support, blog, the legal index, terms, and this privacy policy) we use Google Analytics, PostHog, and Microsoft Clarity. Google Analytics and Microsoft Clarity run nowhere else and never receive your name, email, account id, statements, or holdings. PostHog also runs on the rest of the website, including your dashboard, as described below, but never on the mutual fund checker.

Where the law requires your permission (for example in the European Economic Area, the UK, Switzerland, and Québec) they run only after you allow them. Elsewhere they are on by default, and a Global Privacy Control signal from your browser or your choice in Cookie settings turns them off.

  • Google Analytics (Google LLC) counts page views, referral sources, campaign tags, and approximate location and device type. Page addresses are sent without their query strings, apart from campaign tags. Advertising features and Google signals are off, and Google deletes the data about individual visits after two months, keeping only the totals in its reports. See how Google uses information from sites that use its services, or install the Google Analytics opt-out add-on.
  • PostHog (PostHog, Inc.) counts which pages you view, which buttons and links you use, and how fast pages load, with the referring site and campaign tags. On our public pages, with Session recordings allowed, it also records clicks, scrolling, and page layout, with anything you type hidden. On every other page it records the kind of page (for example “a plan”, never which one) and that you used a button, never the words, amounts, or holdings on it, and records no screen, and once you sign in it links this to your account id. Page addresses are sent without their query strings, apart from campaign tags. Your IP address is discarded. Its cookie lasts 13 months, and turning Measurement off deletes it. In the Oregano app, PostHog also records which screens you open (the kind of screen, never what is on it), which buttons you tap (by name, never their words), when the app is installed, updated, opened, or closed, and errors the app runs into, under your account id once you sign in. On a phone it may also record a session with every screen hidden, so it shows where you went and tapped but nothing that was on the screen, and it may show you a short survey. Where the law requires your permission first, the app asks once and does none of this unless you agree; everywhere else you can turn it off under Usage analytics on the You tab.
  • Microsoft Clarity (Microsoft Corporation). We partner with Microsoft Clarity to capture how you use and interact with our public pages through behavioral metrics, heatmaps, and session replay, so we can improve our products. This usage data is captured with first- and third-party cookies and similar technologies, and we use it for site optimization and for fraud and security purposes. We do not use it for advertising and have not enabled Microsoft Advertising. Anything you type is hidden before it leaves your browser. Microsoft keeps recordings for 30 days, and 9 months for recordings we save and for heatmaps. For more about how Microsoft collects and uses your data, see the Microsoft Privacy Statement.

Inside Oregano, on the website and in the app, we record the steps you take (for example signing up, linking an account, or choosing a plan) in our own database, and our servers send the same records to PostHog under your account id, or a random device id before you sign in, so we can see where people get stuck. These records never include an amount, a holding or fund name, an account number, your name, email address, or anything you type, and PostHog deletes them when you delete your account.

Separately, Vercel Web Analytics (Vercel Inc.), our hosting provider, counts page views across the site without cookies or a persistent identifier. The page addresses it records have private codes, identifiers, and query strings removed, apart from campaign tags.

Google, Microsoft, PostHog, and Vercel may process this data in the United States and other countries.

6. Cookies and similar storage

Necessary items keep the site working and are always on. Measurement and session recording items are used only with your consent where the law requires it, and you can change your choice at any time from Cookie settings in the footer. We do not use advertising cookies.

Necessary

  • pesto.… (cookie, up to 30 days, or until you sign out): Keeps you signed in and protects your session.
  • oregano_consent (cookie, 180 days): Remembers your cookie choices.
  • oregano_consent (local storage, until you change your choices or clear site data): A copy of your cookie choices, in case the cookie is cleared.
  • c15t… (local storage, until the retry succeeds): Holds a cookie choice briefly if saving it to our server fails, so it can be retried.
  • pesto-theme (local storage, until you clear site data): Remembers the colour theme you picked.
  • analyst-guide:… (local storage, until you clear site data): Staff console only: remembers which analyst page guides you hid.
  • pesto_waitlist_intent (cookie, 30 minutes): While you sign in with Google or X to request an invite, carries which friend's link or member's invitation brought you and your time zone, so your new account's spot is credited correctly.
  • pesto_waitlist_invitation (cookie, 14 days): Keeps the invitation a member gave you, from their link, so it is used when you request an invite.
  • pesto_waitlist_inviter (cookie, 14 days): The first name of the member whose invitation link you opened, so the invitation card can say who invited you. Only our server reads it.
  • pesto_desk_inspection (cookie, 12 hours, or until the administrator stops viewing): Staff only: which advisor's wealth desk a platform administrator is viewing, read-only. It grants no access on its own.
  • __ph_opt_in_out_… (local storage, until you turn measurement back on or clear site data): PostHog: remembers that you turned Measurement off, so it sends nothing.
  • oregano_ref (session storage, until you close the tab): Remembers which friend's invite link brought you here, so they are credited if you request an invite on another page of this visit.
  • support-inbox-order (session storage, until you close the tab): Staff console: the order of the support inbox list last opened, so the J and K shortcuts move to the next or previous conversation.
  • oregano:home-place (session storage, until you close the tab): Remembers how far down the home page you were, so reloading it takes you back there instead of replaying the opening film.
  • oregano_invite (local storage, until you choose another email or clear site data): Remembers that you requested an invite, with the email you used and the private link to your invite page, so this device can take you back to it.
  • pesto_welcome_session_v3 (local storage, until you finish or clear site data): Saves your welcome answers so you can pick up where you left off.
  • vouch_… (local storage, until you finish or clear site data): Saves your survey answers, your share link, and any submission that needs a retry.
  • pesto.agent.… (local storage, until you clear site data): Remembers your chat drafts and your chosen agent mode, model, and reasoning effort.
  • support:composer:… (local storage, until you send the reply or clear site data): Keeps a support reply you have not sent yet, so leaving the conversation does not lose it.
  • oregano.sidebar (local storage, until you clear site data): Remembers whether the customer dashboard sidebar is collapsed.
  • oregano.open-app-banner (local storage, until you clear site data): Remembers that you dismissed the prompt to open the Oregano app on your phone.
  • pesto_onboarding_state_v1… (local storage, until you sign out): In the Oregano app on the web, keeps your onboarding answers while you sign up, so a reload keeps your place.
  • pesto.agent.mobile-chat.v2… (local storage, until you sign out): In the Oregano app on the web, reopens your current chat with Oregano after a reload. One copy per account.
  • pesto_analytics_consent_v1 (local storage, until you clear site data): In the Oregano app on the web, remembers whether you allowed usage analytics, so you are asked only once.
  • pesto_posthog_project_v1 (local storage, until you clear site data): In the Oregano app on the web, remembers whether usage analytics may run where you are, so it can start before the app's first screen.
  • pesto_app_preferences_v1 (local storage, until you clear site data): In the Oregano app on the web, remembers display settings on this device.
  • oregano.ambient.selected (local storage, until you clear site data): In the Oregano app, remembers which ambient scene you chose for the home screen on this device.
  • pesto_push_token_v1 (local storage, until you sign out): In the Oregano app on a phone, remembers this device's notification address so signing out can switch it off. Never written on the web.
  • oregano.pendingInvitationCode (local storage, until the code is used or refused after you sign in): In the Oregano app, keeps an invitation code you typed before signing in, so it can be used once you have. Only our server reads it.
  • pesto_app_lock_v1 (local storage, until you turn the lock off or remove the app): In the Oregano app on a phone, remembers whether you asked for Face ID or a fingerprint to open the app. Never written on the web.
  • pesto_push_prompted_v1 (local storage, until you clear the app's data): Remembers that you were already asked about notifications, so you are asked once: in the Oregano app on a phone, and on the web once you answer the app's notifications question.
  • pesto_institution_catalog_v3 (local storage, until you clear site data): In the Oregano app on the web, keeps the list of banks and brokers so it loads quickly. It holds nothing about you.
  • ably-transport-preference (local storage, until you clear site data): Set by Ably, our realtime provider, in the Oregano app on the web and on the staff console's live prices: remembers which connection worked so live chat and prices reconnect quickly.
  • better-auth.message (local storage, until you clear site data): Tells your other open Oregano tabs when you sign in or out, so they follow.
  • pesto.portfolio-… (local storage, until the import finishes): Tracks portfolio imports in progress so they resume after a reload.
  • pesto.wealth.analysis-chat.window (local storage, until you clear site data): Remembers whether the advisor analysis chat is open.
  • pesto.plaid.link (session storage, until the connection finishes or you close the tab): Resumes connecting a bank account after your bank sends you back to Oregano.
  • pesto.… (local storage, until you clear site data): Remembers which dashboard panels you expanded or collapsed, and whether the admin agent builder shows advanced settings.

Measurement

  • pesto_waitlist_visitor (cookie, 90 days): A random id that links repeat homepage visits to a waitlist signup, so we can see which channels bring people in.
  • pesto_mf_session_id (local storage, until you withdraw consent or clear site data): A random id that ties your visits to the mutual fund checker together. Without consent it lasts only for the open page.
  • _ga (cookie, 13 months): Google Analytics: a random id that counts repeat visits to our public pages. Never linked to your account.
  • _ga_… (cookie, 13 months): Google Analytics: keeps one visit's page views together.
  • ph_… (cookie, 13 months): PostHog: a random id that counts repeat visits and keeps one visit's pages together; once you sign in, it is linked to your account.
  • ph_… (session storage, until you close the tab): PostHog: tells apart the tabs of one visit, remembers the page that visit started on, and holds a public page's recording until it is sent.

Session recordings

  • _clck (cookie, 1 year): Microsoft Clarity: a random id that connects your session recordings on our public pages.
  • _clsk (cookie, 1 day): Microsoft Clarity: joins the pages of one visit into a single recording.

7. How long we keep your data

Everything in your account is kept for as long as you have the account. That includes your chats and the answers you were given, what the assistant remembers, the files you upload, your portfolio and linked accounts, and your onboarding call. Nothing in it is deleted on a timer while you use Oregano. It is deleted when you delete it or your account, or after 2 years without signing in. We delete something sooner only where we have to: when the law requires it, to keep the service secure, or when you ask.

Where a regulator requires us to keep a record of advice given to you, only that record is kept after your account is gone, in a restricted archive, for the regulator's period. Copies our service providers hold are deleted within 30 days.

Every category, with its period, the regulators, and our service providers, is on our data retention page. It is generated from the same schedule our systems enforce (version 2, last reviewed 28 September 2026).

8. Your rights

Wherever you live, you can ask for a copy of your data, have it corrected, have it deleted, take it to another service, and withdraw consent you gave us. You can delete your whole account yourself on the web under Account in the account menu, or in the app under Profile → Manage account, and you can delete individual chats, files, memories, and linked accounts where they appear. For anything else, email hello@oregano.club. We may ask you to confirm it is you, and we reply within 30 days. Some records are kept after deletion where the law requires it, as described above.

  • European Economic Area, the UK, and Switzerland. You can also ask us to restrict or stop processing, and object to processing based on our legitimate interests. You can complain to your data protection authority; in the UK, that is the Information Commissioner's Office.
  • India. Under the Digital Personal Data Protection Act, 2023, you can ask for a summary of the data we hold and who we shared it with, have it corrected or erased, and nominate someone to exercise these rights for you. If we do not resolve a grievance, you can complain to the Data Protection Board of India.
  • California. You can ask to know, delete, and correct your personal information, and use an authorised agent. We do not sell or share personal information for cross-context behavioural advertising, and we will not treat you differently for using these rights.
  • United Arab Emirates. You can ask for access, correction, erasure, and restriction, and object to processing.

9. International transfers

Oregano and its service providers process data in the United States and other countries, which may have different data protection laws from where you live. Where the law requires it, we rely on approved safeguards such as standard contractual clauses.

10. Children and changes

Oregano is not for anyone under 18, and we do not knowingly collect their data. If you believe a child has given us data, email us and we will delete it. When we change this policy we update the date at the top, and for a material change we tell you before it takes effect.

11. Contact

Questions about your privacy, or a request about your data? Email hello@oregano.club.