The Theo Principles

Theo handles some of the most sensitive information you have: your money, your income, your spending, your goals, and your anxieties about all of it. We're asking for a lot of trust, and most fintech apps do not deserve the trust they ask for.

This page is how we tell you — in plain English — what we'll do with that access, and what we won't. It's not a privacy policy. (We have one of those, linked at the bottom.) It's the shorter, clearer document that sits above the legalese: where we commit to specific things in language you can actually hold us to.

These principles are not static. When we change them, we'll tell you, and we'll show you what changed and why. The version number at the top of this page goes up each time.

1. We give you guidance, not advice.

Theo is not a regulated financial adviser, and that's a deliberate choice, not a gap. Regulated advice in the UK is expensive, slow, and gated by wealth — the typical floor is £100,000 in investable assets. Guidance — information and frameworks that help you make your own decision — is what around 20 million UK adults actually need and can't get.

Theo tells you what your situation looks like, what the relevant rules are, and what reasonable people in your position tend to do. The final decision is always yours.

How to hold us to it: if Theo ever tells you to buy a specific product, switch providers, or take a specific action on a regulated financial product without you asking — that's us breaking this principle. Email us.

2. We help you act, not just look.

Theo is not a budgeting app.

Budgeting apps show you where your money went. That's useful for about a week — after that, most people close the app because all it's doing is making them feel worse about decisions they can't change.

Theo is built for something different. It's here to help you move forward on the things that actually matter: building the savings that give you options, using the tax wrappers you're entitled to, clearing debt that's weighing on you, getting your pension into a shape you actually understand. The point isn't to make you stare at your finances more often. It's to give you the confidence that you're handling them — and the momentum to hit the goals you've set for yourself.

We measure our success by whether you're taking action and making progress on those goals. Not by how often you open the app.

3. We show our working.

Every suggestion Theo makes is based on something specific: your data, a tax rule, an allowance, a pattern in your spending. We will always tell you why we said what we said, in plain English, at the moment we said it. No black box. No “trust the algorithm.”

If you want to go deeper — the exact figures, the rule we applied, the thresholds we used — that information is one tap away. Always.

4. Your data belongs to you.

Theo connects to your bank through Open Banking, which means we have read-only access to your financial data, granted through an FCA-authorised third party, and only for as long as you choose. You can revoke that access at any time, directly, without asking us.

Read-only means exactly that. We can see your balances and transactions. We cannot move, spend, or touch your money. Your cash stays in your existing bank or building society, protected by the Financial Services Compensation Scheme (FSCS) up to the statutory limit. Theo is not a bank, we do not hold your money, and we never will.

We will never sell your data. We will never share it with advertisers. We do not run ads. We will never run ads.

We do not use your personal financial data to train AI models. We only work with AI providers whose terms prohibit training on the data you send through them. Our current AI provider is Anthropic, whose commercial API terms commit to not training on customer inputs. If we ever change provider, we will tell you in advance, and we will not weaken this commitment.

We encrypt your data in transit and at rest, hold only what we need to do the job, and delete it when you close your account — except where we're legally required to keep specific records (for example, complaint records), which we'll tell you about. You can ask us for everything we hold on you at any time, in a format you can actually read, and we'll deliver it within 30 days (usually much sooner). You don't have to explain why.

5. When we make money, we won't make it at your expense.

Theo is still being built. We don't charge for anything today. But when we do start charging, we want you to know the model in advance — and what we have deliberately chosen not to do.

Here's the plan. We'll charge a subscription for premium features, so you know exactly what you're paying and what you get for it. And we'll earn referral fees when some users choose to take up products we surface — that's how we'll keep the free tier genuinely free. When something we surface involves a product we earn a fee on, we'll tell you on the same screen, not buried in a footer. We'll show you what we earn, we'll show you the non-affiliate alternatives we know about, and if there's a better option we don't earn from, we'll say so. We will never accept payment to rank one product above another.

The core of Theo — enough to see your financial position clearly and take meaningful action on it — will always be free. The UK advice gap exists because guidance has been locked behind wealth thresholds, and we are not going to rebuild that wall in subscription form. Premium adds depth and convenience for people who want it. It will never gate the basics.

Here's what we will never do, because the traditional advice industry has spent decades doing it:

We will never charge you a percentage of your money every year as our fee. We will never take a cut of your ISA, your pension, or your savings as they grow. We will never price our service in a way that hides what you're actually paying.

The incumbent advice model takes a slice of your wealth upfront, then takes another slice every year you stay — whether or not the work has changed, whether or not it's earning its keep. It earns more as your pot grows. That model only works for people with six-figure sums to invest, which is a large part of why around 20 million UK adults can't access advice at all.

We refuse to build another version of it.

6. We design with care, not tricks.

The FCA has specific rules around vulnerable customers — people dealing with financial stress, bereavement, income shock, illness. We take those rules seriously, and we design Theo to meet people at their hardest moments rather than exploit them.

We do not use dark patterns. We will never make it harder to cancel than to sign up. We will never send a notification whose only purpose is to pull you back into the app. If the most helpful thing we can do is nothing, we'll do nothing.

7. We say “we don't know” when we don't know.

Theo is built on AI, and AI is confidently wrong more often than it should be. When Theo is not confident about something — a new tax rule, an unusual situation, something outside what it has been trained on — it will say so, and it will tell you where to get a better answer.

For some decisions, you need a regulated financial adviser, an accountant, or a solicitor. Theo will tell you when that's true, and won't try to replace them.

8. We answer to the FCA, and we think that's a feature.

UK financial regulation is strict, and we are glad about it. The Consumer Duty — the set of rules the FCA introduced in 2023 — requires firms like ours to act in good faith, avoid foreseeable harm, and help you understand what we're telling you. Those are the rules we want to be held to.

We read every FCA publication that affects how we build Theo, and we design the product to meet the standards the regulator sets — not the minimum viable version of them. When we build new features, the question of whether it serves you comes before the question of whether it converts.

9. We tell you when we change.

When we update how Theo works, what we do with your data, or what this page says, we tell you — at least seven days before the change takes effect, for anything that materially affects you. Not a banner. An actual, clear message.

Every time we update these principles, we'll mark the change clearly and tell you why.

Contact: ciaran@usetheo.co — the founder. Reads every email.

Complaints: if you think we've broken any of these principles, or anything else, email ciaran@usetheo.co. We'll respond within 5 working days and tell you how we're handling it.

Last updated: 25 April 2026 · Privacy Policy