● CFPB Section 1033 & Zero Data Retention (ZDR) Compliant

Privacy-First Held-Away Account Aggregation for Registered Investment Advisors

Operated by Black Dog Strategy Partners / Nodus Infrastructure, Inc. | Official Domain: heldaway.app & getheldaway.com | Security & Privacy Contact: support@blackdogstrategy.ai

HeldAway provides read-only open banking connection management, cash-flow normalization, and CRM synchronization exclusively for vetted Registered Investment Advisors (RIAs), wealth management practices, and their client households.

🔒 Strictly Read-Only Scope

HeldAway never sees, collects, or stores banking usernames or passwords, and never initiates ACH transfers or money movement.

🛡️ Zero Data Retention (ZDR)

Automated Named Entity Recognition (NER) PII scrubbing strips SSNs, unmasked account numbers, emails, and street addresses prior to analytics.

📜 CFPB Section 1033 Controls

Enforces phishing-resistant MFA prior to Plaid Link, 90-day consent lifecycles, and 1-click self-service account disconnection & data erasure.

Consumer Rights & Self-Service Disconnection

Clients of participating wealth management firms can review active bank connections, renew 90-day open banking authorizations, or permanently revoke and purge their connected data at any time through the HeldAway Client Security Portal or by emailing support@blackdogstrategy.ai.