OnTrade Privacy Policy

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us.

Registration Information. When you sign up for an account as a wealth advisor or investment team member, we ask you for your name, professional email address, phone number, mailing address, username, and profile photo or logo. If you sign up using a Google account, we will also receive information from Google such as your first name, last name, email address, mailing address, language preference, and profile photo.

Account Information. After you register to use our Service, we ask you for your company email and information relevant to your investment activities, such as details about portfolios you manage, investment strategies, and related financial data. We may also request photo or document proof of your professional credentials or affiliations.

Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, and the contents of a message or attachments that you may send to us, and other information you choose to provide. When you communicate with us online, third-party vendors receive and store these communications on our behalf. If you subscribe to our e-mail notifications, then we will collect certain information from you, such as your email address. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, your Location Information (described below), and your Device Information (described below), to learn how to deliver a better customer experience and improve our Services.

Payment Information. If you make a payment on our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

User Feedback. We appreciate feedback, including ideas and suggestions for improvement or rating of Outputs in response to an Input ("Feedback"). If you provide us feedback, we will store the related information as part of your Feedback.

B. Information We Collect When You Use Our Services.

Location Information. When you use our Services, we receive your general location information. For example, we infer your location information by using your internet protocol (IP) address.

Device Information. We receive information about the device and software you use to access our Services, including IP address, device type, device identifiers, web browser type and version, operating system version, phone carrier and manufacturer, application installations, mobile advertising identifiers, and push notification tokens.

User Content. You may choose to submit data, questions, or other content to the Service to perform portfolio evaluations, scenario models, or utilize our AI service for investment-related inquiries and to analyze portfolios.

Usage Information. We automatically receive information about your interactions with our Services, like the pages or other content you view, referrer information (the website you visited before coming to our Services), the dates and times of your visits, your answers to questionnaires, your comments, and any content you post.

Prompts and Outputs. Our Services allow you to submit text, user responses, data for portfolio analysis, and other materials to the Services ("Prompts"), which generate responses based on your Prompts ("Outputs"), such as portfolio evaluations, scenario models, or AI-generated answers. We will collect any information you choose to provide in your Prompts and this information may be reproduced in the Outputs.

Service Memory. To support continuity and personalization, the Services may maintain limited contextual information derived from your firm's use of the Services. We use this information to provide, maintain, and improve the Services for your firm, subject to the model-training limits described below.

Information from Cookies and Other Tracking Technologies. We and our third-party partners collect information about your activities on our Services using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics, advertising, and security partners, may also use these technologies to collect information about your online activities over time and across different services.

C. Information We Receive from Other Sources.

Information from Third-party Services. If you choose to link our Services to a third-party account, we may receive information about you, including your name, email, address, language preferences, profile photo, and your use of the third-party account. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

Information from Third-Party Sites. We collect publicly-available information from third-party sites to support the development and improvement of our Services and systems.

How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services, specifically for wealth advisors and investment teams to perform portfolio evaluations, scenario models, and utilize AI for investment analysis and rebalancing.
• To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services, subject to the limits described under "Model training" below.
• To personalize your experience on our Services, such as by providing tailored content and recommendations relevant to investment management.
• To understand and analyze how you use our Services and develop new products, services, features, and functionality.
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.
• To facilitate the connection of third-party services or applications, such as to provide you access to financial news and market data.
• To generate de-identified or aggregate data that we may use for any lawful purpose, such as publishing reports, subject to our de-identification commitment below.
• To send you text messages and push notifications.
• To facilitate transactions and payments.
• To find and prevent fraud and abuse and respond to trust and safety issues that may arise.
• For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
• For other purposes for which we provide specific notice at the time the information is collected.

How We Disclose the Information We Collect

Model training. We do not use customer content (including Prompts, Outputs, and client data received directly or through integrations) to train or improve any model except in aggregated or de-identified form. Our personnel may review individual interactions under access controls to diagnose problems and evaluate quality; that review does not train our models.

Our de-identification commitment. When we de-identify or aggregate data, we take reasonable measures to ensure it cannot be associated with any individual or household; we maintain and use it only in de-identified form; we do not attempt to re-identify it, except to test our de-identification processes; and we contractually require any recipient of it to do the same. Published aggregate information, such as industry reports, will not identify any customer firm.

Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services, under written obligations of confidentiality and use restrictions consistent with this Privacy Policy.

AI Service Providers. We may disclose information to artificial intelligence service providers that support language-processing capabilities in our Services. We access these providers through commercial API services. We do not permit these providers to use customer content to train their models. Under their terms, these providers may process customer content only to provide responses to our Services and for security, abuse monitoring, and legal compliance. A current list of our AI service providers and sub-processors is available upon written request.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others' rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

Your Choices

Text Messages. If you wish to opt out of all text messages from OnTrade, you can email support@ontrade.ai or text the word "STOP" to the number from which you are receiving the messages, however you acknowledge that opting out of receiving all messages may impact your use of the service. You may continue to receive text messages for a short period while we process your request, including a message confirming the receipt of your opt-out request.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the information we maintain. Because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal information.

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at support@ontrade.ai.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

Update Your Information

You can update your account and profile information or close your account through your profile settings.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will attempt to notify you through the Services, by email, or other written communication.

Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at support@ontrade.ai.