Last updated: 22 October 2026
1. Who we are
Kyoto is a product of Thrive Fintech Inc., a Delaware corporation doing business as Thrive.Club ("Thrive", "we", "us" or "our"). This Privacy Policy describes how we collect, use, disclose and protect personal information in connection with the website located at heykyoto.com and any successor URL(s) (the "Site"), our mobile applications (the "Apps"), and all related software, tools and services we provide or facilitate access to through them (collectively, the "Service").
You can reach us at privacy@heykyoto.com, or by mail at Thrive Fintech Inc., 62 W 62nd St, New York, NY 10023.
2. Two sets of rules apply to your information
We are a tax return preparer. That makes us a "financial institution" under the Gramm-Leach-Bliley Act, and it means two separate legal regimes govern your information.
- Your tax return information is governed by Internal Revenue Code section 7216 and by the Gramm-Leach-Bliley Act. Section 9 explains this, and our separate Gramm-Leach-Bliley notice gives the details.
- Everything else, such as how you use our website, is governed by general privacy law, including state privacy laws. Section 12 explains your rights.
Where the two disagree, the tax rules are stricter and they win.
3. Information we collect
3.1 Information you give us
Account information. Your name, email address, and password. If you sign in with Google, we receive your name, email address and profile image from Google.
Tax return information. To prepare a return we collect what a return requires. This includes your Social Security number, date of birth, address, phone number, occupation, filing status and marital status; your spouse's name, Social Security number and date of birth; each dependant's name, Social Security number, date of birth and months lived with you; your bank account number, routing number and account type, for refund routing; your driver's licence or state identification details, which some states require to e-file; and every figure of income, deduction and credit that your return reports.
Documents you upload. Tax forms such as Forms W-2, 1099, 1098 and prior-year returns, and any other document you send us.
Messages. What you write to Kyoto, including your conversations with the AI assistant and your messages to a Thrive expert.
3.2 Information we collect automatically
Your IP address, browser type, device information, and the pages you view. We record the IP address and browser string of each sign-in session. Section 14 covers cookies.
3.3 Sensitive personal information
California law treats some of what we collect as sensitive personal information. For us this means your Social Security number, your driver's licence or state identification number, your financial account numbers, and your account credentials.
We use and disclose sensitive personal information only to prepare and file your return, to run and secure the Service, and as the law requires. We do not use it to infer characteristics about you. Because our use falls inside the purposes that California law permits without a right to limit, we do not offer a "Limit the Use of My Sensitive Personal Information" link. If that changes, we will publish one.
4. Sources
We collect information from you directly, from documents you upload, from your device, from Google if you choose to sign in with Google, and, if you use our tool for AI assistants, from the assistant you connect it to.
5. How we use your information
- To prepare, compute, review and file your tax return.
- To create and secure your account, and to verify your identity.
- To answer your questions, and to let a Thrive expert help with your return.
- To detect and prevent fraud, abuse and security incidents.
- To send you administrative messages about your return and your account.
- To comply with law, including record-retention rules.
- To improve Kyoto, only if you give us a separate signed consent. See section 9.
6. How Kyoto uses artificial intelligence
Kyoto uses large language models to read your documents and to help prepare your return. You should know exactly what this means.
Your data goes to Anthropic. Anthropic, PBC is our only model provider. When Kyoto reads an uploaded document, the pages of that document are sent to Anthropic. When you chat with Kyoto, your messages and the relevant facts from your return are sent to Anthropic. We name our provider because you are entitled to know where your tax data goes.
We do not build our own models. Kyoto uses models made by third-party foundation model companies. We build the product around them.
Anthropic does not train on your data. Our agreement with Anthropic bars it from training models on the content we send. This is a contractual bar, not a statement of intent.
We do not train large language models on your data. We do not collect, use or sell personal information for the purpose of training large language models. Where a provider gives us the choice, we always choose that your data is not used for training, and we will never change that choice.
AI output can be wrong. Kyoto's output may contain errors even when it looks confident and detailed. You must review your return before you sign it. Our Terms of Service explain your review duty, which is also a legal requirement.
A human is in the loop. A Thrive tax professional is responsible for your return. No decision that affects your return is made by automated processing alone.
Kyoto's residency tool for AI assistants
Kyoto offers a free tool that answers questions about US tax residency from inside an AI assistant, such as Claude or ChatGPT. You do not need a Kyoto account to use it. This part of the policy applies when you, or your assistant on your behalf, use the tool.
What we receive. The facts the residency rules need, such as your filing status, your travel dates, your immigration status over time and details about your household, together with technical information about each request, such as an IP address and identifiers that your assistant provider sends. The tool is not designed to receive names, identity numbers, addresses, health information or income amounts, and we remove or refuse them if they are sent.
How we use it. To answer your question, to keep the tool secure and protect it from abuse, and to understand how the tool is used. For that last purpose we keep usage records, such as which tool was called and whether it gave an answer, under a pseudonymous identifier, which can stay the same over time. If you sign in, we can link it to your account. To stop them, disconnect the tool from your assistant. Kyoto's rules engine produces the answer; no language model at Kyoto reads these facts. We do not share them, sell them, or use them for training, marketing or advertising.
What we keep. We do not store the facts you give or the answers we return. We keep limited technical records for security and abuse prevention for a short period, and in any case no longer than 30 days. We keep the usage records described above as analytics data (section 10).
Your assistant provider. Your conversation with your assistant is governed by that provider's terms and privacy policy, not ours.
7. When we share your information
We share personal information with the following categories of recipients, and for the following reasons.
| Recipient | What they get | Why |
|---|---|---|
| Anthropic, PBC | Document pages, return facts, chat messages | To read documents and assist preparation |
| Amazon Web Services | Encryption key material only, never your documents | To protect the keys that encrypt your files |
| Our email provider | Your email address and the message | To send account and verification email |
| PostHog | Pages you view, IP address, browser string; for our tool for AI assistants, usage records | Product analytics |
| Only if you sign in with Google | Authentication | |
| The IRS and state tax authorities | Your return and what filing requires | To file your return |
| Thrive experts | Your return and the documents you share with them | To prepare and review your return |
| Law enforcement and regulators | What the law compels | Legal process, fraud, safety |
We also disclose information to our hosting and database providers, who store it on our instruction. If Thrive is acquired or merges, your information may transfer with the business, and it stays subject to this policy or a successor notice you are told about.
8. We do not sell or share your personal information
We do not sell your personal information. We do not share it for cross-context behavioural advertising. We have not done either in the preceding twelve months. We do not have actual knowledge of selling or sharing the personal information of anyone under 16 years of age.
We do not serve advertising on pages that display your tax documents or your return.
9. Tax return information and IRC section 7216
Federal law treats your tax return information as confidential. Section 7216 of the Internal Revenue Code makes it a crime for a preparer to use or disclose it beyond preparing your return, unless the law permits it or you consent in writing.
Without your consent, we may use and disclose your tax return information only where the law allows it. For us this means preparing your return; disclosing it within our own firm so our people can work on it; transmitting it to the IRS and to state authorities; and keeping the records the law requires.
With your separate signed consent, and only then, we may use your tax return information to improve Kyoto. For example, we may measure how accurately Kyoto reads a tax document, and improve the questions it asks. We do not use it to train large language models, with or without consent. That consent is a separate document. It is not part of this policy and it is not part of our Terms of Service. Federal law forbids bundling it. You can decline, and we will still prepare your return on the same terms.
If you believe your tax return information has been used or disclosed improperly, you may contact the Treasury Inspector General for Tax Administration at 1-800-366-4484, or at complaints@tigta.treas.gov.
10. How long we keep your information
| What | How long |
|---|---|
| Your tax return and the documents supporting it | 7 years, which tax record rules require |
| IRS e-file signature authorisations (Form 8879) | 3 years from the return due date or our receipt, whichever is later |
| Your account and profile | While your account is open, then 7 years for return-related records |
| Sign-in session records | Until the session expires |
| Analytics data | 12 months |
| Technical records for our tool for AI assistants, kept for security and abuse prevention | No longer than 30 days |
When you delete a document, we remove the file and mark the record deleted. When you close your account and ask us to delete everything, we destroy the encryption key unique to your household, which makes every document sealed under it permanently unrecoverable, including backup copies. We keep what tax record rules require us to keep.
11. How we protect your information
Your documents are encrypted with AES-256 before they reach storage, under a key unique to your household, which is itself protected by a key held in AWS Key Management Service. Traffic to and from the Service is protected with TLS. Access is limited to people who need it to do your return.
We are honest about the limits. We decrypt your documents on our servers, because that is how we prepare your return. So this is not end-to-end encryption, and we do not claim it is. No system is completely secure.
We do not currently hold a SOC 2 or ISO 27001 certification, and we do not display badges we have not earned.
12. Your privacy rights
Depending on where you live, you may have the right to know what we collect, to get a copy, to correct it, to delete it, to receive it in a portable form, to opt out of sale, sharing and targeted advertising, to opt out of profiling, and not to be treated differently for exercising any of these rights.
To make a request, email privacy@heykyoto.com. Because we are an online business that deals with you directly, we accept requests by email. We will verify your identity before we act, usually through your account.
We respond within 45 days. We may extend once by another 45 days, and we will tell you within the first 45 days if we do. An authorised agent may act for you with proof.
Appeals. If we refuse your request, you may appeal by replying to our decision. We will answer your appeal in writing within 45 days and tell you how to complain to your state attorney general.
Your tax return information is largely governed by federal financial privacy law rather than by state privacy law, and some of these rights may not reach it. We will tell you which rule we applied when we answer.
13. Opt-out preference signals
We honour the Global Privacy Control and similar browser signals as an opt-out of sale and sharing. Because we do not sell or share personal information, the signal makes no practical difference, but we process it.
We do not respond to older "Do Not Track" browser signals, because there is no common standard for them.
14. Cookies
We use a cookie to keep you signed in. We use first-party analytics cookies to count page views. We do not use advertising cookies, and we do not allow advertising pixels on pages that display your documents or your return. You can block cookies in your browser, although the Service will not work without the sign-in cookie.
15. If your data is breached
If a breach affects your information, we will tell you within 30 days of discovering it. The law allows us to delay only for a law enforcement investigation, or for the time we need to find the scope of the breach and make our systems safe again.
Our notice will be titled "Notice of Data Breach". It will tell you what happened, what information was involved, what we are doing, what you can do, and where to get more information. If your Social Security number or your driver's licence number was exposed, we will also give you the contact details of the credit reporting agencies. Where we were the source of the breach, we will pay for identity theft prevention and monitoring services for you, for at least 12 months.
We will also notify the regulators that our rules name. These include the IRS by the next business day, the Federal Trade Commission within 30 days where 500 or more people are affected, and the state authorities that apply, within their own deadlines.
16. Children
The Service is for people aged 18 or older. We do not knowingly collect personal information from children under 13. If we learn that we have, we delete it. A parent or guardian may give us a dependant child's details as part of their own return, which is normal and permitted.
17. Where we operate
We operate in the United States and we store your information there. The Service is intended for filers of United States tax returns.
18. Changes
We will post any new version here with a new date. If a change is significant, we will email you at your account address, or post a prominent notice, at least 30 days before it takes effect. Minor clarifications take effect when posted.
19. Contact us
Thrive Fintech Inc. 62 W 62nd St, New York, NY 10023 privacy@heykyoto.com