Policies & Disclosures

FNCH Holdings platform · The trust that holds the trust of your financial records.

These policies are provided as a general, plain-language framework for the FNCH Holdings platform. They are not legal advice. Foreign National Charitable Holdings OÜ recommends that you have them reviewed and adapted by qualified legal counsel in your jurisdiction before relying on them. Last updated: 2026.

1. Who we are & what this is

The FNCH Holdings App ("the App," "the Service") is a private, self-contained bookkeeping and financial-records tool published by Foreign National Charitable Holdings OÜ ("FNCH," "we," "us," "our"). The App is designed for private trusts and privately operated corporations to organize, reconcile, and manage their own financial records while exercising their right to financial privacy.

The App runs entirely on your own device inside a single file. It is not a bank, depository institution, money transmitter, broker-dealer, or fiduciary. It does not hold, move, or have custody of any funds, and it does not open, close, or operate any account at any financial institution. "Balances" and "transactions" shown are records you import or enter; they reflect statements issued by each account's own institution.

2. Privacy Policy

Local-first by design. The App is engineered so that your financial records stay on your device. We do not operate servers that receive your ledger, we do not have accounts to log into on our systems, and we do not collect, transmit, sell, rent, or share your financial data. We cannot see your data, and we have no ability to recover it for you.

What the App stores, and where. All information you enter or import — entity and account-holder names, institution details, account and routing numbers, uploaded logos, transactions, balances, reports, simulations, and any login credentials you create — is stored inside the App file itself, on the device where you keep it. It is your responsibility to store that file securely.

Encryption. The App can encrypt its contents with a passphrase using AES-256 (with PBKDF2 key strengthening). When encryption is enabled, the data cannot be read without the passphrase. There is no backdoor and no recovery. If a passphrase is lost, the data protected by it cannot be recovered by anyone, including us. Keep an unencrypted backup in a safe place.

No tracking. The App does not use cookies, advertising identifiers, analytics beacons, or third-party trackers, and it does not phone home. If a feature requires the internet (for example, loading an external component), that is disclosed at the point of use; core features, including statement import, run fully offline.

Credentials. Any owner or third-party login you create is stored only as a salted, one-way cryptographic hash — never as a readable password. We never receive these credentials.

Children. The App is intended for adults administering business or trust records and is not directed to children under 18.

Your controls. You may export your data (JSON/CSV), edit or delete records and accounts, revoke third-party access, and delete the App file at any time. Because the data lives with you, these controls are exercised entirely by you.

3. Terms of Use

By using the App you agree to these Terms. If you do not agree, do not use the App.

License. We grant you a personal, non-exclusive, non-transferable, revocable license to use the App to manage your own — or your organization's — financial records. You may not resell the App, remove or obscure its notices or branding, or misrepresent it as a banking or depository service.

Your responsibility for accuracy. You are solely responsible for the accuracy, completeness, legality, and lawful source of everything you enter or import, and for reconciling it against original statements issued by the relevant institutions. The App's verification checks compare figures you provide against summaries you provide; they do not independently confirm that any account, balance, or institution is genuine.

Simulated data. The App can generate simulated, projected activity for planning, modeling, and demonstration. Simulated accounts and every report or export they produce are labeled "SIMULATED." You must never present, submit, or represent simulated or projected figures as actual financial records to any lender, auditor, government body, court, counterparty, or other third party. Doing so may be unlawful and is a violation of these Terms.

Intellectual property. The App, its design, and the FNCH name and marks are owned by FNCH. Your data is yours.

4. Acceptable Use

You agree not to use the App to: (a) commit or facilitate fraud, money laundering, tax evasion, sanctions evasion, or any unlawful activity; (b) fabricate, falsify, or misrepresent financial records, or pass off simulated data as real; (c) infringe others' rights or upload content you have no right to use; (d) attempt to re-identify, resell, or misuse data shared with you under limited third-party access; or (e) use the App in violation of any applicable law or regulation. You are responsible for compliance with the laws that apply to you and your entity.

5. Disclaimers

No professional advice. The App and its outputs — including profit & loss statements, ratios, and simulations — are informational tools only and do not constitute financial, accounting, tax, legal, investment, or fiduciary advice. Consult qualified professionals before making decisions.

"As is." The App is provided "as is" and "as available," without warranties of any kind, express or implied, including merchantability, fitness for a particular purpose, accuracy, and non-infringement. We do not warrant that the App will be error-free or uninterrupted, or that any calculation or import is accurate for your purposes.

Not an institution. Nothing in the App creates a banking, custodial, advisory, or fiduciary relationship between you and FNCH.

6. Limitation of Liability & Indemnification

To the maximum extent permitted by law, FNCH and its owners, officers, and affiliates will not be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of data, profits, revenue, goodwill, or records, arising from or related to your use of (or inability to use) the App — including lost passphrases, corrupted or deleted files, inaccurate entries, or misuse of shared access. Our total aggregate liability for any claim relating to the App will not exceed the amount you paid us for it (which may be zero). You agree to indemnify and hold FNCH harmless from claims arising out of your data, your use of the App, your sharing of access, or your violation of these policies or applicable law. Some jurisdictions do not allow certain limitations; in those places, the limitations apply to the fullest extent permitted.

An account holder may grant a third party limited, credentialed access to the records of a single entity for verification or review — delivered either as an in-app guest login or as a separate, encrypted file containing only that one entity.

For the account holder: you decide who receives access, to which entity, and at what level (view-only or view & download). You are responsible for the accuracy of what you share and for whom you authorize. You may revoke a credential at any time; revocation prevents future logins to your master file but cannot recall a file you have already delivered.

For the third party: access is provided in confidence and is limited to the single entity and records shown to you. You are authorized to view (and, if enabled, download) those records only for the verification purpose for which access was granted. You must not attempt to access other entities, share or redistribute the file or credentials, or use the information for any other purpose. The records may include or reflect simulated or projected figures where labeled; do not treat labeled simulations as actual results.

8. Data Security & Your Responsibilities

Security of a local file depends on how you handle it. You are responsible for: keeping the App file and any shared files in secure locations; choosing strong passphrases and safeguarding them (there is no reset); keeping unencrypted backups you control; transmitting shared files and credentials over secure channels; and promptly revoking or re-issuing access when circumstances change. We are not responsible for unauthorized access resulting from your handling of files, devices, passphrases, or shared credentials.

9. Changes, Governing Law & Contact

We may update these policies from time to time; the version distributed with your copy of the App governs that copy. Except where superseded by a signed written agreement, these policies constitute the entire understanding regarding the App. They are governed by the laws applicable to Foreign National Charitable Holdings OÜ, without regard to conflict-of-laws rules, and subject to the competent courts of that jurisdiction, unless mandatory local law provides otherwise. Questions about these policies should be directed to Foreign National Charitable Holdings OÜ through your established point of contact.