Harlo Security Kit — Fintech-Adjacent Vendor Wording Pack

Selling to banks, credit unions, lenders, payment companies, or finance teams? Their security reviews ask about financial data: whether you touch card numbers, whether you hold or move funds, how you connect to bank accounts, who can see account numbers, how payee changes are checked, and whether your logs can be edited. This pack gives small B2B SaaS teams 25 original, plain-English starting answers for those questions, plus a starter Financial Data Handling Policy.

Every answer has a short version, a longer version, an honest "if not yet in place" variant, and a list of evidence to have ready. Honest variants are included for vendors who do not take payments, do not connect to banks, or are still building their controls. All company details are {{placeholders}} you fill in.

Written for vendors that touch financial data without being a bank or payment company. Nothing in this pack makes you or your customers meet any financial, payment card, or banking rule.

Includes: 25 Q&As (Markdown with YAML front-matter, Notion-importable), CSV answer bank, starter Financial Data Handling Policy (with effective and next-review dates), placeholder list.

Covers: financial data scope, card data position (tokens only via hosted processor), funds-flow position (not a bank; does not hold customer funds), bank connections via aggregator tokens, account number masking and field encryption, encryption and key rotation, customer payment approvals, internal separation of duties, protected audit logs, log and transaction export, staff access, MFA and step-up checks, API key scopes and signed webhooks, fraud signals, payee-change controls, retention and deletion, sub-processors, breach notice, outage recovery for money features, no real financial data in test systems, AI on financial data, supporting customers' third-party risk reviews, offboarding, policy ownership, honest "does this make us meet our rules" answer.

Important: A starting point, not legal advice, not a certification, and not an audit. Edit every answer and the policy to match what you actually do, and have your own counsel review any contract wording.

License: one organization. No resale. Support: digitalpromohub.support@gmail.com