Privacy Policy

NRI Clear

Effective date: [EFFECTIVE DATE] Last updated: [EFFECTIVE DATE] Version: 1.1-draft

Draft — not yet published. This text describes what the software actually does today. It must be reviewed by counsel, and the open items in legal/PUBLISHING-CHECKLIST.md must be closed, before it is shown to a user or before any real Social Security number is collected.

The short version

We are a software tool, not your accountant. You prepare and file your own return.
Your tax documents are read by an AI model that runs on our own servers. They are not sent to OpenAI, Anthropic, Google, or any other AI company.
We ask for your SSN or ITIN only at the last step, to print it on the form. We do not save it in our database.
We do not sell your data, share it for advertising, or run any analytics or tracking tools.
You can ask us to delete everything at any time: [privacy@EXAMPLE.com].

The rest of this policy is the detail behind those five statements.

1. Who we are

NRI Clear is operated by [COMPANY LEGAL NAME], [ENTITY TYPE] registered in [JURISDICTION], with its address at [POSTAL ADDRESS] ("we", "us").

For questions about this policy or about your data, contact [privacy@EXAMPLE.com].

This policy covers the NRI Clear website and web application at [DOMAIN]. It does not cover any third-party site we link to.

2. Who this service is for

NRI Clear is built for international students and other nonresident filers in the United States. It is not intended for anyone under 18, and we do not knowingly collect information from children. If you believe a minor has given us information, email us and we will delete it.

3. What we collect

We only collect what the return needs. There is no advertising profile, no behavioural tracking, and no data collected "just in case".

3.1 Information you give us directly

What	Why we need it
Email address	To identify your session, so you can come back to a return in progress, and so we can reach you about it
Email address, if you ask for an invite on the home page	So we can email you an invitation. Asking doesn't start a session, and we send nothing else to that address
Answers to the intake questions (whether you already filed, and which form)	To decide whether you can do a practice run
Your name	It goes on the return
Visa type, current immigration status, date you entered the US, whether your status changed	Required by the substantial presence test and by Form 8843
Country of citizenship and country of tax residence	Determines which tax treaty applies
Passport number and issuing country	Form 8843 asks for it (lines 3a and 3b)
Days you were present in the US, per year, and your entry/exit dates	Required by the substantial presence test, Schedule OI and Form 8843
Your school's name, address and phone, and your program director's name, address and phone	Form 8843 Part III asks for them (lines 9 and 10)
Which prior years you claimed exempt status or filed a US return	Form 8843 lines 11-12 and Schedule OI item H
Whether you have applied for a green card or taken steps toward permanent residence	Form 8843 line 12 and Schedule OI item M
Your SSN or ITIN	Printed on the return. See section 5 — this one is treated differently from everything else

3.2 Documents you upload

You may upload tax forms — W-2, 1042-S, 1099-B, 1099-DIV, 1099-INT, 1099-MISC. We store the file you uploaded, and we store the individual figures our AI reads out of it (wage amounts, withholding amounts, employer and payer names, account identifiers, and so on) so you can check and correct them.

So that we don't have to ask you for your details, you may also upload last year's Form 8843 or Form 1040-NR, this year's filed Form 1040-NR, and your immigration documents: your Form I-94 record or I-94 travel history, Form I-20 or Form DS-2019. From those we read your name, visa class, the dates you entered and left the US, your country of citizenship, passport number and issuing country, your school or program sponsor, your program director and program dates, and the figures on a filed return, and we use them to fill in the details in section 3.1 (you can change any of them). We read only those fields: we do not record your SEVIS number, and an SSN or ITIN on a filed return is cut to its last four digits like any other (section 5).

3.3 Bank and brokerage data, if you choose to connect an account

Connecting an account is optional. The service works without it.

If you connect one, we use Plaid to do it. You enter your bank credentials into Plaid's interface — we never see or receive your banking username or password. Plaid gives us an access token, which we store encrypted, and we use it to read a tax year of transactions and investment activity from the accounts you selected. We use that to pre-fill draft figures that you must then confirm against your real tax forms.

Plaid's handling of your data is governed by Plaid's own privacy policy.

3.4 What we generate about you

The computed return: your income, deductions, treaty exemption, tax, and refund or balance due.
The filled PDF packet (Form 1040-NR or 1040, Schedule OI, Schedule NEC, Form 8843, and where relevant instructions for claiming back Social Security and Medicare tax on Forms 843 and 8316). We build it fresh each time you download it, from the figures above, and do not keep a copy (section 5).
Suggestions from the built-in advisor about documents you may be missing.
Counts of how many uploads and AI calls your session has made, to enforce rate limits and prevent abuse.

3.5 What we do not collect

No advertising or analytics identifiers. We run no analytics product, no advertising pixel, no session recorder, and no third-party tracking script of any kind.
No location data.
No contacts, photos, or device data beyond what your browser sends with an ordinary web request.
No bank login credentials (see 3.3).

4. How your documents are read — the AI question

This is the part most people ask about, so it is stated plainly.

When you upload a tax form, we convert its first page to an image and pass it to a vision language model that runs on infrastructure we control. The model weights are downloaded and executed on our own server.

Your tax documents are not transmitted to any third-party AI provider. We do not use OpenAI, Anthropic, Google, or any hosted model API to read them. This was a deliberate design decision and it is enforced in the code: the extraction service is configured to talk only to a model server on our own network.

We also do not use your documents, your figures, or your return to train any model — ours or anyone else's.

The advisor feature, which tells you which documents you might be missing, does not use AI at all: it is a fixed set of rules applied to your answers.

5. Your SSN or ITIN

We treat your taxpayer identification number differently from every other field.

We do not ask for it during intake. We ask for it at the final step, each time you download your PDF.
It is not written to our database. It is held in memory only long enough to print it onto the form.
If our AI happens to read an SSN off a document you uploaded, we mask it before saving — we store only the last four digits, as ***-**-1234.
Before we save a copy of your computed return, we strip the number out of it.

We do not keep the PDF either. The completed packet has your SSN printed on the face of the form, because the IRS requires it there. So we never store it: each time you download, we build the packet from your saved figures, send it to your browser, and discard it. That is also why we ask for your SSN again on each download — we have nowhere to get it from.

The one place your SSN does exist after you leave is the PDF on your own device. Keep it as carefully as you would the paper return.

6. How we use your information

We use it to:

determine whether you are a resident or nonresident for tax purposes;
work out which forms you must file, and fill them in;
compute your tax, treaty exemption, and refund or balance due;
tell you which documents you appear to be missing;
keep your session working, and stop abuse of the service;
respond to you when you contact us.

We do not use it to advertise to you, to build a profile of you, or to train AI models.

7. When we share information

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

We share it only with the service providers we need to run the product:

Provider	What they handle	Where
[NETWORK PROVIDER — the service that connects your browser to our computer, e.g. Cloudflare, Inc.]	Carries traffic between your browser and our computer	[REGION — confirm]
Resend, Inc.	Delivers sign-in emails; sees your email address and the sign-in link	United States
Plaid Inc.	Bank and brokerage connection, only if you choose to connect an account	United States

During the beta, the website, the database and your uploaded documents all run on a computer we own and operate in the United States, not on a cloud hosting provider. [CONFIRM WITH COUNSEL whether the network provider above must be named as a processor, since it can see traffic in transit.]

The AI model that reads your documents is not on this list, because it runs on our own infrastructure (section 4).

Beyond those providers, we will disclose information only:

when you ask us to;
if we are legally required to — by subpoena, court order, or law — in which case we will tell you unless we are legally prohibited from doing so;
to investigate or stop fraud or abuse of the service, or a threat to someone's safety;
to a successor entity in a merger or acquisition, in which case this policy continues to govern your information until you are given notice and a choice.

8. How long we keep it

Data	Retention
Your session and everything attached to it (profile, documents, extracted figures, computed return)	Up to 90 days from when the session is created
Encrypted bank access token	Deleted with the session, or immediately when you ask us to disconnect the account
Your SSN or ITIN, and the PDF packet it is printed on	Never stored (section 5)
Rate-limit counters	90 days
Usage and cost records (which kind of form was read, how much computing it took, what it cost — no name, email address or document content)	Kept after your session is deleted, with the link to your session removed, so we can track what the service costs to run
Beta invite list (your email address only, if you were invited)	Until the beta ends, or sooner if you ask
Invite requests from the home page (your email address and the date you asked)	Until the beta ends, or sooner if you ask
Server logs	[RETENTION PERIOD — confirm with hosting provider]

Deletion is automatic. A scheduled job runs daily, and when a session passes its retention date it removes the database records *and* the uploaded files from storage. It is not a flag or an archive: the data is gone.

Keep your own copy of your filed return. The IRS recommends retaining tax records for at least three years, and we are not your record-keeper — do not rely on us to hold your return for you.

9. Your choices and rights

Whoever and wherever you are, you can:

Get a copy of the information we hold about you.
Correct anything that is wrong — most of it you can edit directly in the app.
Delete everything. Email [privacy@EXAMPLE.com] and we will delete your session, your documents and your computed return within 30 days.
Disconnect a linked bank account at any time, which deletes the access token.
Object or complain. If you think we have handled your data badly, tell us first — and you may also complain to your local data protection authority.

We will not charge you for exercising these rights, and we will not treat you differently for doing so.

If you are in California, the CCPA/CPRA gives you the rights above by name, including the right to know, delete, correct, and to opt out of sale or sharing — we do not sell or share your information, so there is nothing to opt out of. We do not use or disclose sensitive personal information for any purpose other than providing the service you asked for.

If you are in the EU or UK, our legal basis for processing is the performance of our contract with you (preparing your return at your request), and our legitimate interest in keeping the service secure. Where you have given consent — for example to connect a bank account — you may withdraw it at any time.

10. Security

What we actually do:

Encryption in transit. All traffic uses HTTPS.
Encryption at rest. The computer that holds the database and your documents uses full-disk encryption. [CONFIRM: FileVault enabled.] Bank access tokens get an additional layer: AES-256-GCM encryption with a key held only in our server environment.
No public database access. Every table denies access to anonymous and logged-in browser clients outright; the database can only be reached by our server code.
Signed session cookies. Your session cookie is cryptographically signed, HTTP-only, restricted to our own site, and marked Secure in production. A tampered cookie is rejected, and a cookie for one session cannot read another session's return.
SSN minimisation. Described in section 5.
Local AI. Described in section 4.

No system is perfectly secure, and we will not pretend otherwise. If we discover a breach affecting your personal information, we will notify you and the relevant regulators as required by law.

11. Cookies

We use exactly one cookie:

Name	Purpose	Type	Lifetime
`tax_session_id`	Keeps you signed in to your own return, and proves the request is yours	Strictly necessary	90 days

It is HTTP-only (JavaScript cannot read it), Secure in production, and SameSite=Lax. It contains your session identifier and a signature — nothing else.

We set no advertising, analytics or third-party cookies. Because our only cookie is strictly necessary, there is no consent banner to click.

12. Where your data is

Our servers and providers are in the United States. If you are outside the US — and most of our users are — using the service means your information is transferred to and processed in the US, where the privacy laws differ from those in your home country. [TRANSFER MECHANISM FOR EU/UK USERS — SCCs? Confirm with counsel.]

13. Changes to this policy

If we change this policy materially, we will update the date at the top and notify you by email before the change takes effect. Continuing to use the service after that means you accept the new policy.

14. Contact us

[privacy@EXAMPLE.com] [COMPANY LEGAL NAME], [POSTAL ADDRESS]

[EU/UK REPRESENTATIVE, IF REQUIRED — confirm with counsel.]