Privacy Policy

1. Information We Collect

1.1 Information You Provide

We may collect limited information you voluntarily provide, such as:

• Account information — the email address you register with, or the name and email address released to us when you sign in with Apple or Google, and your app settings and preferences.
• Watchlists, saved symbols, and any portfolio information you enter manually.
• The prompts, questions and messages you send to the AI features, and the conversation history and per-user AI memory derived from them.
• Contact information (e.g. email address) if you contact us for support or inquiries.
• Email address if you voluntarily submit it through an app download, lead, or smart-link flow.

1.2 Usage and Technical Information

We may collect basic technical and usage information to operate and improve the Service, such as:

• Device type and operating system
• App version
• General usage events (e.g. feature interactions, crashes)
• Crash reports and diagnostic traces, including device model, OS version and app instance identifier
• Push notification tokens, where you enable notifications
• Purchase and subscription records — store transaction and entitlement identifiers, plan, renewal and trial status (we never receive your card number)
• Campaign attribution parameters, such as referral source, campaign tags, advertising click identifiers when present in the URL, and the Google Play install referrer
• IP address, from which approximate (city-level) location may be inferred

This information is collected in an aggregated or anonymized form where possible.

1.3 Information from a connected brokerage or exchange account (optional)

If you choose to connect a brokerage or crypto exchange account, the connection is made through SnapTrade, Inc., our account-aggregation provider. You authenticate directly with your institution inside SnapTrade's connection portal. We request read access only, and through the connection we receive:

• the name of the institution and the type, nickname and currency of each connected account, with the account number shown only as its last digits;
• account balances, cash balance and total value;
• position-level holdings: symbol, description, asset class, quantity, price, cost basis as reported by the institution, market value and open profit or loss;
• transaction history for the account, such as trades, dividends, fees and transfers, with date, symbol, quantity, price, amount and fees;
• daily account value history, used to display performance over time;
• technical records of each synchronization (time, outcome, and any error), kept for support and reliability.

What we do not receive. We do not ask for, receive or store your brokerage or exchange username, password, PIN or multi-factor authentication codes. Those are entered in our aggregation provider's own hosted flow and are not transmitted to us. We do not receive, and cannot obtain, the ability to place orders, move money, or withdraw or transfer assets. We receive no payment card number, no bank account number and no government identification number from the connection.

What we use it for. We use this information only to display your portfolio to you, to compute performance and analytics for you, and — when you ask a question about your portfolio — to include the relevant parts of it in a prompt to our AI providers so the answer reflects your actual holdings. We do not sell it, we do not share it for advertising, and we do not use it to train AI models. You can disconnect at any time from inside the app, which revokes our access and deletes the stored positions, balances and activity for that connection.

What we hold to keep the connection alive. We store a per-user access secret issued to us by the aggregation provider. It is encrypted at rest on our servers using AES-256-GCM with a key held outside the database, and it is never written to logs. It is not your brokerage password, and on its own it is not usable — every request to the provider is additionally signed with a key held only on our servers.

1.4 Information We Do Not Collect

AI Investing does not:

• Collect banking credentials
• Receive or store brokerage usernames, passwords, PINs or multi-factor authentication codes
• Execute trades or move money
• Require sensitive personal financial information — the optional brokerage connection described in §1.3 is the only route by which account data reaches us, and it is entirely your choice

2. How We Use Information

We use the information we collect to:

• Operate and maintain the Service
• Provide market analysis and contextual insights
• Improve app performance, reliability, and usability
• Respond to support requests
• Measure app install campaigns, smart-link redirects, and aggregate marketing performance
• Generate AI Output in response to your questions — your prompt, and the relevant context we send with it (which may include watchlist or connected-account holdings when you ask about your portfolio), are sent to our model providers
• Manage your subscription, trial and entitlements
• Detect, prevent and investigate fraud, abuse and security incidents, enforce our Terms, and establish, exercise or defend legal claims
• Comply with legal obligations that apply to us, including screening accounts and the details available to us against sanctions and restricted-party lists (for example lists maintained by OFAC, the EU and the UK) so that we do not provide the Service where export-control or sanctions law prohibits it

We may use analytics and advertising-attribution tools to measure campaign performance and app installs. We do not sell personal data and we do not share it for cross-context behavioural advertising, we do not use it to train or fine-tune AI models, and AI Investing does not use it to provide personalized financial advice.

3. Data Sharing and Disclosure

AI Investing does not sell user data and does not share it for cross-context behavioural advertising.

We share information with the service providers below, each under a written agreement that limits them to processing on our instructions and requires them to protect it to a standard consistent with this policy. Each provider makes its own representations about its security practices; we rely on those representations and do not independently guarantee them.

We may also disclose information where required by law or legal process, to enforce our terms, to protect the rights, security or integrity of the Service, or in connection with a merger or sale of the business — in which case we will tell you before your information becomes subject to a different policy.

Account-aggregation provider. If you use the optional brokerage connection feature, SnapTrade acts as our aggregation provider. You authorize the connection directly with SnapTrade and with your institution; SnapTrade holds that authorization and supplies us with read-only account data. SnapTrade processes your data under its own terms and privacy policy. We do not send SnapTrade any data other than what is needed to establish, maintain and delete your connection.

4. Data Security

We follow standard industry practices to protect user information, including technical and organizational safeguards designed to prevent unauthorized access, disclosure, or misuse.

We use TLS for data in transit. The secret that maintains a brokerage connection is encrypted at rest on our servers using AES-256-GCM and is excluded from application logs. Access to production systems is restricted and audited.

No system can be made perfectly secure, and we do not claim otherwise. If you discover a vulnerability, report it to contact@a2group.llc.

5. Data Retention

We retain information only for as long as necessary to:

• Provide the Service
• Comply with legal obligations
• Resolve disputes
• Improve the app

When data is no longer required, it is deleted or anonymized. We keep your account information for as long as your account is open. Conversation history and AI memory are retained while your account is open so the Service can refer back to earlier context. Diagnostic and crash data is retained on our providers' standard schedules. Billing records are retained for as long as tax and accounting law requires.

Deleting your account. You can delete your account from inside the app (Settings → Delete Account) or by emailing contact@a2group.llc. When you delete your account we delete or irreversibly anonymize your profile, watchlists, conversation history and the per-user AI memory collection held with our model provider, we delete stored brokerage positions, balances and activity and remove the aggregation provider's user record and its authorizations, and we cancel or revoke the subscription records we control. Some records are retained where law requires (for example billing and tax records) or in encrypted backups for a limited period before being overwritten. Deleting your account does not cancel a subscription bought through the Apple App Store or Google Play — cancel that in your store account.

Withdrawing consent. You can disconnect a brokerage connection, turn off notifications and analytics permissions in your device settings, and withdraw consent to non-essential cookies at any time, without affecting the lawfulness of processing before you withdrew it.

Connected-account data. Data synced from a connected account is retained while the connection is active. Position data is replaced in full on each synchronization rather than accumulated. When you disconnect, we instruct the aggregation provider to delete the authorization and we delete the accounts, positions, transaction history, value history and synchronization records associated with that connection. When you delete your account, any connection and all data synced through it are deleted with it.

6. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you, and obtain a portable copy
• Request correction or deletion of your data
• Object to or restrict certain processing activities
• Withdraw consent you have given

You can exercise these rights by emailing contact@a2group.llc. We verify requests using the email address on your account and respond within the period required by the law that applies to you (45 days in California; one month under the GDPR).

6.1 European Economic Area, United Kingdom and Switzerland

Where the GDPR or UK GDPR applies, A2GROUP LLC is the controller of the personal data described in this policy. Our legal bases are:

Automated decision-making. The Service generates AI analysis about markets and about your portfolio. It is designed not to issue personalised instructions to buy or sell, and it produces no decision that has a legal or similarly significant effect on you. It does not determine credit, eligibility, pricing, or access to any product. On that basis we do not consider it automated decision-making within Art. 22. You can always ask us to review any AI Output at contact@a2group.llc.

Your rights under Arts. 15–22 are access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. You may complain to your supervisory authority — in Spain, the Agencia Española de Protección de Datos (AEPD); in the UK, the Information Commissioner's Office.

6.2 Notice for California residents

We do not sell your personal information, and we do not share it for cross-context behavioural advertising as those terms are defined by the CCPA/CPRA. We have not done so in the preceding twelve months, and we do not sell or share the personal information of consumers we know to be under 16.

We use analytics and advertising-measurement providers (Google Analytics, Google Ads and TikTok, and on our websites other measurement pixels where enabled). Some of these technologies can be treated as a "sale" or "share" under California law depending on configuration. We have configured them not to be used for cross-context behavioural advertising, we honour Global Privacy Control signals sent by your browser, and you can opt out at any time by emailing contact@a2group.llc — no account required.

Sensitive personal information. Certain information we handle may be sensitive personal information under California law, including the authorization that allows retrieval of data from your brokerage or exchange account, and the contents of your messages to the AI features. We use sensitive personal information only to provide the Service you requested and for purposes permitted without an option to limit under Cal. Civ. Code §1798.121 — we do not use it to infer characteristics about you. We treat the brokerage holdings and transaction data we retrieve as sensitive by policy, even though California law does not classify it that way.

Your California rights, whether or not we currently meet the CCPA's applicability thresholds: to know, access and obtain a copy; to delete; to correct; to opt out of sale or sharing; to limit the use of sensitive personal information; and not to be discriminated against for exercising any of them.

6.3 Other US states

Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Rhode Island, Indiana, Kentucky and Texas have rights to access, correct, delete and obtain a portable copy of their personal data, to opt out of targeted advertising, sale and certain profiling, and to appeal a refusal. We do not sell personal data and we do not process sensitive data for targeted advertising. Contact contact@a2group.llc; if we decline a request you may appeal by replying, and if we deny the appeal you may complain to your state Attorney General.

6.4 Spain and Latin America

España. Under Spanish law (LOPDGDD art. 7) consent to processing may only be given by a person aged 14 or over; independently of that, AI Investing requires you to be 18. You may complain to the Agencia Española de Protección de Datos.

México. If you are in Mexico, you may exercise your ARCO rights — Acceso, Rectificación, Cancelación y Oposición — and revoke your consent, by writing to contact@a2group.llc. A2GROUP LLC is the responsable of the data described in this policy; the purposes marked in sections 2 and 6.1 as necessary to provide the Service are primary purposes, and analytics and marketing measurement are secondary purposes you may refuse without losing access to the Service. Financial and patrimonial data requires your express consent: connecting a brokerage or exchange account is optional and is processed only on the separate consent you give at the connection step.

6.5 International transfers

We are based in the United States and our providers are located in the United States and elsewhere. When we transfer personal data out of the EEA, the UK or Switzerland, we rely on the European Commission's Standard Contractual Clauses (and the UK Addendum where applicable), together with a documented transfer impact assessment and technical safeguards including encryption in transit and at rest. You can request a copy of the relevant safeguards at contact@a2group.llc.

7. Cookies and Similar Technologies

On our websites we use strictly necessary technologies to run the site and — only with your consent — analytics and marketing-measurement technologies. You may accept or reject non-essential technologies, and change your mind at any time, through our cookie banner and preference centre. In the app, analytics and attribution SDKs operate subject to the tracking and notification permissions you grant on your device, which you can change at any time in your device settings.

8. Third-Party Services

AI Investing may include links to third-party websites or services (e.g. data providers). We are not responsible for the privacy practices of those third parties.

9. Children's Privacy

The Service is not directed to children. You must be at least 18 years old to create an account. We do not knowingly collect personal information from anyone under 18; if we learn we have, we delete it. Contact contact@a2group.llc.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be reflected on this page with an updated "Last updated" date. Where a change is material, we will give you at least thirty (30) days' advance notice before it takes effect, by email to the address on your account and by an in-app notice.

Earlier versions. We keep the superseded versions of this policy. You can request the version that applied on a particular date by emailing contact@a2group.llc.

11. Contact Us

If you have any questions about this Privacy Policy or how we handle data, you can contact us at:

Privacy requests and general enquiries: contact@a2group.llc

Company: A2GROUP LLC, a Wyoming limited liability company

Postal address: 5830 E 2nd St, Ste 7000 #16007, Casper, WY 82609, USA