1. Introduction

Truefolio (“we,” “us,” or “our”) is committed to protecting your privacy through compliance with this policy. This Privacy Policy explains how we collect, process, retain, disclose, use, and protect your information when you use our social investing platform (the “Services”).

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.
• When you interact with our advertising and applications (including mobile apps) on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us through any other means, including on any other website operated by Truefolio or any third party (including our affiliates and subsidiaries) that does not link to this policy; or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

2. Information We Collect

We collect information necessary to build your social profile and provide comparative social metrics.

• Account Information: Name, email address, username, and bio.
• Financial Data (Read-Only): When you link a brokerage account via Plaid, we receive:
  • Portfolio holdings (ticker symbols and quantities).
  • Transaction history (buy/sell dates and prices).
  • Account balances (used solely for generating relative performance metrics).
• Payment information: Credit card or debit card information and information about the payment methods and services (such as PayPal or Venmo) you use in connection with the Services.
• Account history: Information about your account, transactions, and trades.
• Demographic information: Your age, gender, income level, education, or family or marital status, if you have consented to such information collection.
• Device information: Including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, app usage patterns, and other device information.
• Content and information: You elect to provide as part of your profile or in any reviews you make through the Services or emails, chats, or other communications sent to us.
• Images, voice recordings, and videos: Collected or stored in connection with the Services, if you have consented to such information collection.
• Technical Data: IP address, device type, and app usage patterns.

3. How We Collect Your Information

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, subscribe, participate in surveys, sweepstakes, contests, or promotions, or create, upload, or post content to the Services, including reviews, media such as photos, videos, or audio recordings.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies: A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons: Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Truefolio, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your device manufacturer.
• Your internet or mobile service provider.
• Cloud Infrastructure and Security Providers.
• Identity Verification Services.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, content delivery services, payment processors, promotions services, gift card program providers, analytics, security and anti-fraud services, and data brokers.

We also may receive personal data from business partners that we engage to share consumer information with us, including your personal preferences and demographic information such as age, gender, and income level so that we can better provide you with a personalized experience, including personalized content, offers, and services.

4. How We Use Your Information

We use your data to power the social features of the Platform:

• Social Metrics: To generate estimated performance percentages and social rankings. These figures are mathematical estimates and not official financial audits.
• Social Feed:To share your investment activity (e.g., “User X added a position in AAPL”) with the community, subject to your privacy settings.
• Platform Personalization: To suggest relevant content or users to follow.
• Notices: To provide you with notices about your account, including when Services updates are available and about changes to any products or services we offer or provide though them.
• Improve our Services: To develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them. Our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing with third parties for model training.
• Promote our Services:To promote our business and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Services.
• Legal Obligations: To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

5. Aggregated and Anonymized Data

We may use data from your account, including accounts set to "Private", to create aggregated, de-identified metrics.

• Community Trends:We may share community-wide trends (e.g., "The most-bought stock today is TSLA") or sentiment data.
• Anonymity: This data is combined with thousands of other data points; it contains no personal identifiers and cannot be traced back to you.

6. Financial Privacy & Visibility Model

To protect your sensitive financial information, the Platform operates on a "Percentage-Based" transparency model:

• Strictly Confidential: Your total account balance, net worth, and specific dollar amounts of any transaction or holding are never shared with other users or displayed publicly.
• Community Visible:Only your portfolio allocation percentages (e.g., "12% of portfolio is in NVDA") and your estimated performance percentages are visible to others, subject to your privacy settings.

7. Data Sharing and Third Parties

We do not sell your personal financial data. We may, however, disclose aggregated information about our users, and information that does not identify any individual, without restriction. We share information that may identify you with:

• Service Providers: Infrastructure providers (e.g., cloud hosting) and analytics tools necessary to run the Platform.
• Financial Aggregators:We use Plaid to link your accounts. We never see or store your institution's login credentials.
• Market Data Providers: We use Twelve Data, FMP, and Marketaux to provide real-time pricing and analyst data.

We also may share your information:

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Truefolio's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Truefolio is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers/members, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

8. Your Controls

• Privacy Settings:You may set your profile to "Private." This hides your individual holdings and performance from the public leaderboard and feed.
• Brokerage Removal: You can remove your brokerage in Truefolio at any time. We will stop fetching new data immediately and remove its portfolio, transactions, and holdings from our active database, though aggregated historical data (which is not personally identifiable) may remain part of community-wide metrics.
• Deletion: You can delete your account yourself, at any time, from Settings in the app or on the web. No request or email is required. Your profile, posts, and performance are hidden from other members immediately, and your brokerage connection is disconnected immediately. If you have approved access, we keep your data for 30 days so you can change your mind: sign back in, choose "Restore my account", and your account and performance history come back. Reconnect your brokerage to resume syncing. After the restoration window ends, your data is scheduled for permanent deletion. Once deletion is complete, it cannot be undone. If you never received access, or your access was rejected or revoked, your account is deleted right away without a restoration window. If you have questions about the process, contact support@truefolio.app.
• Cookies and Other Tracking Technologies:You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.
• California's "Shine the Light" law: California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Note that we do NOT share personal information with third parties for this purpose.

9. Security

We employ industry-standard encryption and security protocols designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. Because our access is Read-Only, the Platform cannot be used to move funds, withdraw money, or execute transactions in your connected accounts.

Note that no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

10. How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

11. Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

12. Contact Information

To ask questions or comment about this privacy policy or our privacy practices, contact us at: support@truefolio.app