THESIS TRADE APP PRIVACY NOTICE

This Privacy Policy (“Policy”) describes how Thesis Trade Inc., a Delaware corporation (“Thesis Trade,” “Company,” “we,” “us,” or “our”), collects, uses, and discloses information about you when you access or use the thesis.trade software platform available at https://thesis.trade, together with all related features, tools, content, and services that link to this Policy (collectively, the “Services”).

This Policy is incorporated by reference into our Terms of Use, available at https://thesis.trade/terms (the “Terms”). Capitalized terms used but not defined in this Policy have the meanings given in the Terms. In the event of a conflict between this Policy and the Terms with respect to the collection, use, and disclosure of personal information, this Policy controls.

If you do not acknowledge this Policy, do not access product functionality. You may still contact us and manage or cancel billing. For questions about this Policy or to exercise a privacy right, contact support@thesis.trade.

Table of Contents

• Introduction and Scope

• Information We Collect

• Sensitive Personal Information

• How We Use Information

• How We Share Information

• Financial Information; Safeguards

• Cookies and Tracking Technologies

• Data Retention

• Data Security

• Your Privacy Choices and Rights

• U.S. State Privacy Rights

• Children’s Privacy

• United States Operations

• Changes to This Policy

• Contact Us

1. Introduction and Scope

Thesis Trade provides a software platform that lets you express an investment thesis or research request in natural language. The Services use your inputs together with market data and, when you connect a brokerage account, relevant account and position context to research and generate or rank proposed position structures for your review. You decide whether to submit any proposed structure. The Services do not exercise discretionary authority over your account, do not originate autonomous trades, and do not place an order without your explicit per-order confirmation.

This Policy applies to personal information we collect through the Services, in email and other communications between you and Thesis Trade, and when you connect a brokerage account to the Services. It does not apply to the practices of third parties we do not own or control, including your brokerage, SnapTrade (defined below), Google OAuth, or any third-party website linked from the Services. Those parties’ own terms and privacy policies govern their handling of your information.

In this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular individual or household, and any other information treated as “personal information” or “personal data” under applicable law.

You acknowledge this Policy through the affirmative acknowledgment presented with the applicable version. That acknowledgment describes receipt of the Policy and does not waive your privacy rights or replace separate consent where required.

2. Information We Collect

The information we collect depends on how you interact with the Services.

2.1 Information You Provide to Us

• Account and profile information. Email address; a password or Google OAuth identity used to authenticate you; your chosen handle; access-code status; and other account or profile information you provide. Google sign-in records may include the Google account identifier, email address and verification status, and profile or display name. Account features may also store watchlists, preferred display or brokerage settings, and saved workspace results. Authorized personnel may receive limited new-account notifications through our email provider to administer access.

• Investing-experience preferences and guided intake. You may tell us your familiarity with shares, ETFs and options, and your preferred explanation depth and length. We store those settings and records of changes to them to provide the account features you request. We also store your private intake draft, which may contain your question, interpretation, quoted source material or a source link. These inputs help you prepare a Research request or an explicit construction request. They do not establish investment suitability or authorize trading. This account-feature processing is separate from the optional analytics described in Section 2.5.

• Trading theses, research prompts, and inputs. Natural-language thesis statements, research requests and prompts, parameters, risk settings, named tickers, and other inputs you submit so the Services can answer Research requests and generate or rank proposed position structures.

• Research and order content. Relevant conversation context and chat history needed to operate a Research session; proposed position structures you save or stage; and records of orders you explicitly confirm. Private account content is not made visible to other ordinary users. If a separately enabled publication feature is available and you deliberately choose it, selected content and your public handle may be displayed to the audience described by that feature. This does not make your other private account content public. Authorized personnel and service providers may process private content for the purposes described in this Policy.

• Payment and subscription information. We use Stripe, Inc. (“Stripe”) for paid subscriptions through Stripe-hosted Checkout and the Stripe billing portal. When you choose an available paid plan, Stripe collects your card or other offered payment-method details and any billing or contact information required by its payment flow. Those details are submitted to Stripe, rather than entered into Thesis Trade payment forms. Our hosted-checkout integration does not store full card numbers or card security codes in the Thesis Trade billing ledger. Stripe handles payment information under its own applicable terms and privacy disclosures.

Thesis Trade keeps limited billing records linked to your account: Stripe customer, checkout-session, subscription, price, invoice and payment or charge references; your selected plan and billing interval; currency and amounts; recurring-payment authorization and its disclosure version and time; payment and subscription status; paid-period, renewal, failure and cancellation timestamps; and limited refund, dispute and reconciliation evidence. We also keep operation identifiers and fingerprints to prevent duplicate processing. These references and account-linked records are personal information, even though they are not full card details. The price, recurring period and payment authorization are presented separately before you commit to a purchase. An invitation or access-code redemption does not itself start a subscription or authorize a charge, and a checkout return alone does not establish confirmed payment or paid access.

• Communications. We collect information you provide when you contact us for support, respond to a survey, or otherwise communicate with us. Support messages are handled by authorized Thesis Trade personnel through our monitored support inbox. We do not currently use an AI support agent to answer those messages.

2.2 Brokerage Account Information (via SnapTrade)

When you choose to connect a brokerage account to the Services, you do so through our connectivity provider, SnapTrade (Passiv Inc.) (“SnapTrade”). SnapTrade and your brokerage present and govern the authorization and consent required in their connection flow, including their applicable terms and privacy disclosures. By completing that flow, you authorize access, processing, and storage within the scope of that authorization. Thesis Trade receives and accesses connected brokerage information through SnapTrade within that authorization, which may include:

• account identifiers and account type;

• balances, positions, and holdings;

• transaction and order history; and

• order status information for orders you explicitly confirm through the Services.

We also maintain connection records, including SnapTrade user and authorization identifiers, connection status and granted permission scope, and an encrypted provider-issued connection secret used for authenticated SnapTrade requests.

To display a requested order review or fee/impact estimate, we may send the proposed instrument, quantity, price and order parameters, together with the relevant account and connection context, to SnapTrade before you confirm submission. A preview request is distinct from placing an order; submission still requires your explicit per-order confirmation.

We access brokerage information for the Services you request, including relevant account and position context, order review and portfolio views. Orders are submitted, modified or canceled only on your direct, per-order confirmation; we do not exercise investment discretion over your account. After product entitlement ends or access is suspended, we send no new brokerage instruction on your behalf, including a close, cancellation, amendment or retry, as described in Terms Sections 8.7 through 8.9. Canceling renewal does not end already-paid access early; access during payment grace is addressed separately in Terms Section 8.8. SnapTrade and your brokerage present their connection terms and privacy disclosures. You may request disconnection using the broker-connection controls. Successful disconnection and provider completion are described in Section 10.

2.3 Information Collected Automatically

When you use the Services, our service providers and we automatically collect certain information, including:

• Device and usage information. Our records may include your IP address, browser or user-agent information, requested route, request outcome, account-creation and latest-login timestamps, selected feature activity, and dates and times of recorded events. We associate relevant events with an account identifier and, where applicable, the access code or campaign through which the account obtained access.

• Log, diagnostic, and audit information. We record selected service activity, model usage, response timing, token counts, failures, research-recognition tags, proposed-structure selection outcomes, and related order and operational evidence. Some diagnostic and audit records include the message or thesis text you submitted, an excerpt, the response returned to you, and contextual information used to investigate how a response or proposed structure was produced. Full rendered prompts may be stored in selected cases, including errors, risk flags, recent deployments, and sampling. Those copies may include the financial context and explanation settings supplied to the model. Public-route security records may include an attempted email address and a summary of request-field names rather than the raw request body. These records are personal information when linked to you; the limited-content design of the optional app analytics stream does not mean that existing diagnostic records exclude text.

• Cookies and similar technologies. See Section 7.

2.4 Information from Third Parties

We may receive information from services you use in connection with Thesis Trade, including SnapTrade (brokerage connection, account, position and order information), Google OAuth (identity and authentication information), and Stripe (the limited billing references, payment, subscription and reconciliation information described in Section 2.1 when you use paid billing). We do not purchase personal information from data brokers.

2.5 Usage Reporting and Optional App Analytics

We may summarize the existing first-party records described in Section 2.3 to understand onboarding, usage by access-code or campaign cohort, use of Research and construction features, service reliability, and progression toward user-confirmed orders. Reports can use counts and other summaries without including raw messages or thesis text. Records or reports that can be linked to an account remain personal information, including when internal identifiers replace names. Usage reporting does not itself train or activate production trading models.

Optional app analytics is a separate product-event stream for improving the app. It is not required to use your account. This notice treats new and existing accounts differently. A new account means an account created on or after the effective date of this revised notice. Before the first optional analytics event for a new account, we will display a brief, visible disclosure at collection, identify the limited activity data and PostHog processing, and provide an easy “Turn off analytics” control. Eligible future activity for a new account may then be recorded unless you opt out or a separate consent requirement applies. We will not make accepting optional analytics an additional onboarding gate.

Existing accounts means accounts created before that effective date, including accounts whose users have already acknowledged an earlier policy. We will honor the separate-consent commitment for those accounts: optional third-party analytics will remain off until the user makes a distinct, informed affirmative choice to allow it. Acknowledging this revised notice, accepting the Terms, signing in, or continuing to use the app does not substitute for that choice. A previous decline, withdrawal or other applicable opt-out is preserved for every account; a new notice does not silently reverse it. If an account cannot be reliably classified as new or existing, optional analytics remains off pending resolution.

Only future eligible app activity is recorded under the applicable rule above. Event categories are limited to account-creation, verification and sign-in events; app page categories; onboarding steps reported as visibly reached; content-free records that preferences changed, an intake handoff completed or you explicitly chose direct input; admitted Research or construction requests and finite outcomes; qualified reports that a result became visible; and later meaningful Research or construction activity. Events include times, deployment environment, a reference to the analytics-choice revision, and restricted browser, account, session and request references. Current analytics-choice records identify the applicable notice; each event does not contain an immutable copy of its original notice. A restricted category of the campaign through which an account obtained access may be associated with eligible events; the access code itself is excluded.

This optional event stream excludes email addresses, usernames, intake drafts, questions, raw thesis or research text, source excerpts or links, conversations, preference values and declared knowledge levels, holdings, balances, financial-account data, brokerage or order payloads, credentials and payment details. A preferences-saved event records that a committed change occurred, not which settings you chose. These restrictions apply to both new and existing accounts. The stream is distinct from necessary service, diagnostic and audit records in Section 2.3, which may contain content. A refusal of optional analytics does not disable the account features you request. Missing or declined analytics is not proof that you did not use the Services. We do not retrospectively collect, reconstruct or backfill earlier behavior, export historical product or diagnostic records into this stream, or apply a new default retroactively.

When delivery is enabled after the applicable notice, choice and rollout checks, PostHog receives a restricted copy of permitted events using environment-specific pseudonymous identifiers. We retain the account association in our own database; replacing names with pseudonyms does not make these records de-identified. This stream is not used for advertising, cross-context behavioral targeting, session replay, automatic input capture or training or activating trading models. Before first delivery, we must verify the applicable PostHog processor/service-provider agreement and provider-side Product Development and Model Development restrictions and prospective opt-out settings. Those vendor checks must be completed before first delivery. Material changes to data, purpose, recipients or defaults require updated disclosures and any required separate consent, while preserving existing choices and the existing-account rule above.

3. Sensitive Personal Information

The connected brokerage account, position, and order information we access through SnapTrade may constitute financial information and may qualify as “sensitive personal information” under the California Privacy Rights Act and comparable state laws. We collect and use this information to provide the Services you request and for the related purposes described in Section 4, such as using relevant account and position context, supporting portfolio views, and maintaining records of orders you confirm. We do not use sensitive personal information to infer characteristics about you, and we do not sell it or share it for cross-context behavioral advertising. Disclosures to operate the Services, including authorized service-provider processing, are described in Section 5. See Section 11.1 for the right, where applicable, to limit the use of sensitive personal information.

4. How We Use Information

We use the information we collect to:

• provide, operate, maintain, and secure the Services—including interpreting your thesis and research requests, combining your inputs with market data and relevant connected account or position context, generating or ranking the proposed position structures you request, displaying risk parameters and maximum-loss calculations, and submitting only the orders you explicitly confirm;

• create and manage your account and authenticate your access;

• administer the paid subscriptions you choose, including processing payments through Stripe, managing subscriptions and related access codes or grants, presenting billing disclosures and obtaining payment authorization, sending receipts and billing notices, and addressing payment fraud through the payment processor described in Section 2.1;

• communicate with you, including transactional communications (service announcements, security alerts, account notices, and user-confirmed order communications) and, subject to your opt-out rights, product and marketing communications, consistent with the Terms;

• maintain records of proposed structures you stage, the orders you confirm, and the disclosures presented to you at the time of instruction, including the audit trail of your instructions;

• monitor, analyze and improve the Services through troubleshooting, testing, reliability checks and usage reporting on the records described in Sections 2.3 and 2.5;

• protect the security and integrity of the Services, prevent fraud and abuse, and enforce our Terms; and

• comply with applicable laws, regulations, legal processes, and governmental requests.

AI processing. The Services use artificial-intelligence models, including large language models provided by Anthropic, PBC (“Anthropic”), to interpret thesis and research prompts and help generate responses and proposed position structures. Anthropic may receive your thesis or research prompt, relevant conversation context, market context and named tickers. Depending on the feature, relevant financial context may include account value and buying power; position counts and broker or source labels; holdings and option terms such as strikes and expiry; quantities, cost or entry and current values, unrealized gains or losses; and user-set position-management rules or trigger levels. We do not represent that your full brokerage account is always sent. Anthropic describes commercial API content as excluded from model training by default, with exceptions for explicit feedback or other training opt-ins. Our applicable account settings, service terms and any separate agreement govern the processing we use. That no-training commitment restricts training use; it is not a representation that no data is retained. Anthropic may retain inputs and outputs for the periods and purposes permitted by its applicable commercial terms, such as operating the service, security, and abuse monitoring. For this launch, automatic application of outcome-based learned adjustments to production trading models must remain disabled. Recording and evaluating outcomes is separate from activating those adjustments. Using your prompt and relevant context to produce a response is distinct from training a model. Recording outcomes for evaluation does not itself change the production models. For reliability and performance evaluation, authorized personnel may review selected diagnostic records, proposed or confirmed structures, relevant signal and market context, and later outcomes. Account-linked records and exported working copies remain personal information and follow the access, purpose and retention protections in this Policy. This does not make those records part of the optional content-free analytics stream. We will review and disclose any material change to these uses before enabling it, and obtain any separate consent required by law. If we engage an additional or replacement AI provider, we will update this Policy as appropriate.

Explanation preferences. When you ask Research to respond, the declared investing-experience and presentation settings, together with relevant product-guidance context, may be included in the instructions supplied to the AI provider to adjust its explanation. Source material you deliberately include in a Research request is processed as part of that request. Those service inputs are separate from the content-free optional analytics events; declining analytics does not disable the explanation settings you choose. The settings do not change trading permissions or constitute an assessment of your investing ability or suitability.

5. How We Share Information

We do not sell your personal information or share it for cross-context behavioral advertising. We do not sell, re-sell, or re-package brokerage account information, or use it for third-party marketing. Disclosures needed for the Services, including authorized brokerage transmission and the AI processing described in Section 4, are described below. Material changes to these uses require updated disclosures and any required separate consent. We disclose information as follows:

• Service providers. We use vendors to perform services on our behalf, including SnapTrade (brokerage connectivity, requested order-review and fee/impact processing, and user-confirmed order transmission), Railway (hosting and data storage), Anthropic (AI processing), Google OAuth (identity and authentication), and Mailgun (email delivery). Stripe provides the hosted payment, subscription-billing and customer-portal services described in Section 2.1. For the optional app analytics described in Section 2.5, PostHog processes the permitted pseudonymous events when delivery is enabled. Vendor processing is subject to applicable service terms and the purposes described in this Policy.

• Market-data and reference-data providers. The Services obtain market and reference data from Intrinio and, where used by the relevant feature, Massive/Polygon, Yahoo Finance/yfinance, and Finnhub. These services provide price, options, earnings, calendar, company-reference or related market information. Requests may include ticker, contract and time-window parameters selected from the feature, thesis or holdings being researched, including later outcome evaluation. Queries to these providers do not intentionally include your account identity, thesis or research prompt, broker credentials, or order instructions.

• Your brokerage. When you explicitly confirm an order, the order instruction is transmitted through SnapTrade to your brokerage for handling under your brokerage’s own agreements with you.

• Legal and safety. When we believe disclosure is required by or appropriate under applicable law, regulation, legal process, or governmental request; to enforce our Terms; or to protect the rights, property, or safety of Thesis Trade, our users, or others.

• Business transfers. In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, in which case the successor’s use of your information remains subject to this Policy, or you will be notified of any material changes as described in Section 14.

• With your consent. For any other purpose disclosed to you at the time of collection or with your express consent.

We may share aggregated or de-identified information that cannot reasonably be used to identify you. Information that is merely pseudonymous — for example, records keyed to an internal user identifier or cohort — is not de-identified and remains personal information under this Policy. We maintain and use de-identified information only in de-identified form and do not attempt to re-identify it, except as permitted by law to test de-identification.

6. Financial Information; Safeguards

Connected brokerage information is sensitive. We apply reasonable administrative, technical, and organizational safeguards appropriate to our size and the nature of the information we handle, including access controls and service-provider oversight.

Please do not transmit sensitive financial information, account numbers, or credentials to us by email. Email transmissions are not secure.

7. Cookies and Tracking Technologies

We use browser local storage and session storage for interface preferences and short-lived navigation or workflow state. We use strictly necessary first-party cookies, including a server-session identifier, to support authentication, security and session management. Server-side application, security and diagnostic records help us operate and troubleshoot the Services. Our waitlist email sends explicitly disable Mailgun open and click tracking. Other transactional email sends may follow the Mailgun domain settings and, if tracking is enabled there, may record opens and link clicks. We use delivery and failure information to operate email communications.

• Strictly necessary cookies are required for the Services to function (authentication, security, session management) and cannot be disabled through the Services.

• Optional app analytics identifiers. An optional first-party analytics identifier may be created for a new account only after the at-collection disclosure and eligibility checks in Section 2.5 and while no applicable opt-out applies. For an existing account, it is created only after the separate affirmative analytics choice. This optional analytics stream does not enable optional tracking while signed out or on the public website; account classification alone does not authorize collection. After sign-in, an eligible browser interval may be linked only to that same account; signing out or changing accounts resets the browser identity, and activity is not silently assigned to another account. Staging and production analytics are separated. No vendor browser SDK, session replay, automatic input capture or advertising cookies are used by this stream. Acknowledging the Policy, accepting the Terms, using the app and choosing marketing communications remain distinct from the existing user's analytics consent. A changed notice does not erase a prior opt-out, and any separately required renewed consent must be obtained before affected collection resumes.

• Advertising cookies. We do not use advertising or targeting cookies.

Most browsers let you refuse or delete cookies through browser settings; disabling strictly necessary cookies may prevent some account features from functioning. The analytics controls will honor a detected Global Privacy Control (“GPC”) signal by disabling optional product analytics for that browser and, where reliably linked, the account. This is a product choice in addition to any legally required sale, sharing or targeted-advertising opt-out; we do not sell personal information or use this stream for advertising. The new-user default applies only after these controls have been implemented and tested. Other “Do Not Track” signals are not currently supported. A missing signal never overrides a saved opt-out or supplies an existing user's consent.

8. Data Retention

We retain personal information for the specific purposes described below, taking into account account operation, the sensitivity of the information, subscription and offer administration, evidence of authorization, security and dispute needs, and applicable legal obligations. Retention is limited to what is reasonably needed for those purposes. Closing product access, including at the end of failed-payment grace, is separate from a request to delete personal information. When we receive a verified deletion request, we review each applicable category and any permitted exception; an ordinary retention period does not by itself justify denying or postponing a valid request.

• Account and profile information: retained while needed to administer the account and address verified closure or deletion requests. Information needed for a separately identified billing, agreement, order, security or dispute purpose is classified and retained under that purpose, rather than keeping the full profile by default.

• Access, onboarding, and founder-offer records: limited evidence is retained to administer grants, prevent repeat redemption of a one-time founder offer, and preserve founder-price eligibility after involuntary failed-renewal closure. The necessary evidence may include an account reference, a protected representation of the verified email, the offer and redemption record, the closure reason and the retained price entitlement. Keeping this evidence does not retain a complete account or provide product access. A protected or pseudonymous identifier remains personal information if it can be linked to you. We evaluate its continuing purpose and any deletion request separately.

• Thesis statements, research prompts, chat history, and related inputs: retained to provide the features you request and, for a bounded diagnostic period, to investigate outputs or faults. A narrowly selected copy needed as order, security-incident or dispute evidence follows that separate purpose. A verified deletion request is assessed for earlier removal of ordinary content; routine diagnostic usefulness is not a blanket exception.

• Preferences, watchlists, and saved publications: retained while needed for the account features you choose to use, then removed following the relevant item deletion, account closure or verified deletion request, except for any specifically justified evidence copy. Available controls differ by feature; published content may require a reviewed request or administrative takedown rather than a self-service delete control.

Saved intake drafts are cleared when you reopen them more than seven days after the draft was last saved. This is read-time cleanup, not a promise that an idle draft is deleted automatically on the seventh day. Research requests or other account content you separately submit follow their own retention and deletion criteria above.

• Device, usage, diagnostic, and routine security records: retained for limited service-operation, troubleshooting, usage-reporting and abuse-prevention purposes. Information needed for a particular incident, dispute or legal obligation is identified separately; a general security purpose does not make all routine records permanent.

• Administrative and incident-specific evidence: selected records are retained to investigate or document a privileged action, security incident, abuse matter, dispute or legal obligation. We periodically review whether those records remain needed and release any hold when its reason ends.

• Non-audit connected brokerage information: retained to provide the active connection and requested portfolio features. After disconnection or verified account closure, information no longer needed for those features is removed separately from order, authorization or reconciliation evidence. Your brokerage independently controls its own records.

• Authentication and connection tokens: access is governed by the applicable expiry, revocation and connection lifecycle. Secret material is removed when no longer needed for authorized access. Limited non-secret metadata may be kept for an identified security or authorization purpose after a token becomes unusable.

• Order, confirmation, disclosure, execution, and reconciliation evidence: limited records are retained to document the relevant presentation, your authorization, the brokerage response and subsequent reconciliation, and to address specific dispute or legal requirements. These purposes do not automatically justify retaining every prompt, portfolio snapshot or unrelated account field.

• Agreement acceptance evidence: limited information is retained to identify the Terms or Privacy version presented, the acceptance or acknowledgment event and the account to which it relates. Historical document versions are preserved so that those records can be understood. Personal assent evidence is evaluated separately from the non-personal text of a published policy.

• Genuinely de-identified aggregate outcomes: records may be retained while they cannot reasonably be linked to a person or household and are maintained without re-identification. Replacing a name with a user ID, account ID or email hash does not by itself de-identify information. Linked or pseudonymous records remain personal information and follow the appropriate category’s retention criteria.

• Support and other direct communications: retained to respond to your request and for a limited period after the matter closes, with any communication needed for a specific dispute or legal obligation classified separately. Requests concerning privacy rights are recorded with enough evidence to document verification, handling and the outcome.

• Payment and subscription records: retained to administer billing, demonstrate separate payment authorization and meet applicable accounting, tax and dispute needs. These may include the record that a failed renewal was waived and whether a founder rate remains available. Waiving an unpaid invoice does not require deleting the evidence of that waiver. Stripe independently handles payment information under its applicable terms. Offer-eligibility evidence and Terms or Privacy acceptance follow their separate purposes above.

• Usage reports and optional app analytics: account-linked events and reports follow a defined purpose and retention period. Aggregated reporting is not exempt from those limits merely because names have been replaced. We assess the collection, recipients and retention of materially different future analytics before enabling it.

Optional analytics cleanup. Local event records made under a browser identifier become eligible for cleanup after 90 days, including if that earlier browser interval is later associated with an account. Events recorded directly against an account identifier and the limited account-attribution snapshot become eligible after 365 days. Aggregate ingestion counters become eligible after 90 days. These are local eligibility rules: when the applicable cleanup jobs are configured and running, they remove eligible records in bounded batches, rather than a record disappearing automatically at the instant an age is reached. Scheduling and verifying those jobs is a prerequisite to analytics activation. Analytics choice, applicable notice, consent and account-linkage records follow the account, preference and authorization purposes described above rather than being deleted automatically with each event. These event periods do not govern your private intake, Research content or other product records.

Local cleanup and withdrawal do not automatically delete copies already delivered to PostHog. Provider-held records require a separate applicable retention and deletion process. Requests to delete optional analytics are handled for local and provider-held copies separately, subject to the applicable criteria in this Policy; we do not describe local deletion as proof of provider deletion.

When information is no longer needed for an identified purpose and any applicable retention requirement has ended, we delete it or appropriately de-identify it. A specifically justified legal hold may preserve a limited record while the matter remains open. We assess verified deletion requests separately from ordinary retention clocks and explain any permitted retention exception. Where deletion affects information held by a service provider on our behalf, we address that copy through the applicable provider process. Copies in backups are handled under the applicable backup lifecycle and must not be returned to ordinary use after deletion without restoring the deletion restrictions.

9. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. However, no method of internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. If we become aware of a breach affecting your personal information, we will notify you and applicable regulators as required by law.

10. Your Privacy Choices and Rights

• Access, correction, and deletion. You may access and update account information through available account settings, or request access, correction, or deletion by contacting support@thesis.trade. We handle requests in accordance with applicable law. Certain information may be retained for the specifically identified billing, agreement, order, security, dispute or legal-obligation purposes described in Section 8, subject to the approved periods and applicable exceptions.

Account closure and deletion requests. Contact support@thesis.trade to request account closure or deletion of personal information. Canceling subscription renewal preserves access through the already-paid period under Terms Section 8.7. Product and trading access close immediately if a renewal remains unpaid at the end of the seven-day grace period; full access continues during grace as described in Terms Section 8.8. The unpaid failed renewal is waived, and founder-price eligibility is preserved if the closure resulted solely from involuntary nonpayment. A later return requires successful payment for a fresh month. Product closure does not itself erase records, terminate your brokerage account or change orders or positions held there. A separate verified account-closure or deletion request is handled under the criteria in Section 8.

• Brokerage disconnection. Use the broker-connection controls in your account settings to request disconnection. A successfully completed disconnection disables the relevant connection in Thesis and removes or requests removal of the applicable provider authorization. Final SnapTrade user deletion may complete asynchronously. If a disconnection attempt fails, the interface reports the failure so it can be retried or addressed with support. Disconnection does not cancel, close, or otherwise change any position or working order at your brokerage. Information already collected is retained and handled as described in Section 8; disconnection is not a request to erase all retained records.

• Marketing opt-out. You may opt out of optional marketing communications at any time using the “unsubscribe” link in any marketing email or by contacting us at support@thesis.trade. You cannot opt out of essential account and service communications — including security alerts, account and access-status notices, communications about orders you confirm, and billing and subscription notices such as receipts and renewal or payment-failure notices — because they are necessary to operate and secure your account. Opting out of marketing does not affect those communications.

• Cookies. See Section 7.

• Optional app analytics. The sign-in and app interface will provide an easy, persistent “Turn off analytics” control and a Privacy settings route, including while product access or a required agreement needs attention. New users can opt out; existing users can decline the separate choice or withdraw it later. Opting out stops future optional collection and suppresses events waiting for delivery. It does not recall events already delivered or automatically erase earlier records. Saving an opt-out or a withdrawal must not require agreeing to optional analytics, accepting a new product agreement or sending a support email. Opting out must not reduce account functionality, and the preference is preserved when the browser is reliably linked to the account. Contact support@thesis.trade to request access to or deletion of analytics associated with you. We may need information to locate relevant records and verify an access or deletion request; this is separate from exercising an opt-out. Please do not send passwords, brokerage credentials or sensitive trading information. Analytics choices do not grant or remove product or trading permissions.

We may need to verify your identity before acting on a request, and we may deny requests where permitted by law. We will not discriminate against you for exercising your privacy rights.

11. U.S. State Privacy Rights

Depending on your state of residence, you may have rights under a state comprehensive privacy law. As a matter of practice, Thesis Trade extends the core rights below to residents of any state with an applicable law, regardless of whether we currently meet that law’s applicability thresholds.

Subject to legal exceptions, you may have the right to:

• confirm whether we process your personal information and access it;

• request the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients (subject to the record-retention limits in Section 8);

• correct inaccurate personal information;

• delete personal information we have collected from you (subject to the record-retention limits in Section 8);

• obtain a portable copy of your personal information (subject to the record-retention limits in Section 8);

• opt out of the sale of personal information, sharing for cross-context behavioral advertising, and targeted advertising — none of which we do; and

• not be discriminated against for exercising your rights.

How to exercise your rights. Submit a request to support@thesis.trade. You may use an authorized agent; we may require evidence of the agent’s authority and verification of your identity.

Appeals. If we decline to act on your request, you may appeal by contacting us at support@thesis.trade within a reasonable time after receiving our decision. We will respond in writing within the period required by applicable law, explaining the action taken or not taken. If your appeal is denied, you may contact your state Attorney General to file a complaint, where permitted by law.

11.1 California (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), provides the rights described in this Section.

Categories of personal information. We collect the following categories of personal information from the sources described in Section 2 and for the purposes described in Section 4:

• Identifiers and account information (e.g., name, email address, account identifiers);

• Commercial information (for example, proposed structures you stage, records of orders you confirm, and subscription, plan, access-grant, and payment-event records described in Section 2.1);

• Financial information, including brokerage account information accessed via SnapTrade with your consent (which may constitute sensitive personal information — see Section 3);

• User Content, including thesis statements, research prompts, relevant Research conversation context, and saved proposed position structures;

• Internet or other electronic network activity (e.g., device and usage information); and

• Inferences drawn to provide the Services, if any.

Sensitive personal information. As described in Section 3, we use sensitive personal information only for permitted business purposes and do not use it to infer characteristics. To the extent the right applies, you may request that we limit our use of your sensitive personal information; because we already limit use to providing the Services, this does not change how we handle it.

Sale/sharing. We do not sell or share personal information as those terms are defined under the CCPA/CPRA. Accordingly, we do not offer a “Do Not Sell or Share My Personal Information” mechanism, because no such activity occurs.

Verification. When you submit a request, we will verify your identity before fulfilling it, which may require you to provide information we can match against what we already have on file. We use verification information only for verification.

Shine the Light. California Civil Code § 1798.83 permits California residents to request information about disclosures of personal information to third parties for those parties’ own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Metrics. To the extent we become subject to the CCPA/CPRA metrics reporting requirement, we will disclose the required annual metrics on consumer requests received, complied with, and denied.

12. Children’s Privacy

The Services are intended for users who are at least 18 years old. The Services are not directed to children under 13, and we do not knowingly collect personal information from them. If you believe a child under 13 has provided us personal information, contact us at support@thesis.trade, and we will delete it as required by the Children’s Online Privacy Protection Act (“COPPA”).

13. United States Operations

Thesis Trade is operated from the United States and offers the Services only to users located in the United States. Information is also processed outside the United States: our current Railway application deployment is hosted in Southeast Asia, and our service providers may process information in other locations under their applicable terms. United States customer eligibility does not mean that all information is stored or processed only in the United States. We use the safeguards and service-provider arrangements described in this Policy for that processing.

14. Changes to This Policy

We may update this Policy from time to time. We will post the updated notice and show the effective date with the published version. Material changes require additional notice, such as an email to the account address, and affirmative acknowledgment of the exact updated version before the change applies; continued use alone is not that acknowledgment. For existing users, that acknowledgment remains separate from the distinct affirmative choice required to enable optional third-party analytics under Section 2.5. For new users, it does not remove at-collection disclosure or easy opt-out rights, and any processing that separately requires consent remains off until that consent is obtained. We do not use a changed policy to backfill activity or silently reverse an earlier decline or withdrawal.

15. Contact Us

For questions, concerns, or requests regarding this Policy or our privacy practices, contact us at:

Thesis Trade Inc.
333 W Brown Deer Rd, Ste G #4343
Bayside, WI 53217

Support, account closure, deletion requests, privacy appeals and questions about this Policy: support@thesis.trade. This inbox is monitored by Thesis Trade personnel.

Website measurement amendment — website-v1

Website measurement amendment — website-v1. This amendment forms part of the Privacy Policy and applies only to optional measurement on the public website. For that separate website stream, this amendment and the Website Measurement Notice replace the statements in Sections 2.5 and 7 describing this collection as future-only, saying that we do not use analytics cookies or identifiers, or saying that we do not respond to Do Not Track or Global Privacy Control. Website measurement remains off until you separately choose Allow website measurement for the exact website notice presented. The Website Measurement Notice describes the fixed event categories, first-party database, random identifiers, choices, and website-specific retention criteria under Section 8, including the 30-day reporting window and bounded request-driven cleanup rather than guaranteed deletion on day 30. Website events are not sent to PostHog or another product-analytics provider and are not linked to your app account. The separately reviewed app notice and app consent rules remain unchanged; the app stream’s exclusion of public website visits continues to describe that app stream, while this amendment governs the independent website stream. Accepting Terms, acknowledging the Privacy Policy or choosing app analytics does not allow website measurement. Material changes remain subject to Section 14’s additional notice and affirmative acknowledgment requirements. Publication of this amendment does not itself enable collection.

Optional website measurement

You can use our website and thesis demo with website measurement turned off. This choice is separate from app analytics, accepting the Terms or acknowledging the Privacy Policy, and choosing marketing communications.

What we measure

After you choose Allow website measurement, we record fixed public-page categories, broad source and campaign categories, demo starts and whether the demo shows a result, no result or an error, and clicks on Sign up. We also record timestamps and random measurement identifiers. A visit identifier is stored in your browser tab and changes after 30 minutes without observed activity. These records are pseudonymous and do not establish a unique person.

This measurement excludes what you type, thesis text, conversations, email addresses, account and brokerage identifiers, holdings, balances, order details, full URLs and query strings. We do not link these website measurements to your app account. We do not use automatic input capture, session replay or advertising tracking. Information you deliberately submit to the demo or another form is processed separately to provide that service, as described in our Privacy Policy.

Where records go

Website measurement records stay in our first-party application database and support aggregate reporting for authorized personnel. This website release sends no analytics events to PostHog or another product-analytics provider. Our hosting and ordinary operational and security processing remain described in our Privacy Policy.

Your choice

We save your Allow or Decline choice in localStorage. After you choose Allow, we set a first-party HttpOnly consent-receipt cookie that expires after 30 days, and use sessionStorage in your browser tab for a random visit identifier and limited source and campaign attribution. Optional measurement identifiers are created only after you allow measurement. Use Website privacy settings to decline or turn measurement off at any time. Global Privacy Control and Do Not Track signals keep this website measurement off. A saved decline is not reversed when a privacy signal is absent. Turning it off does not reduce website or demo functionality.

Retention

Website events are used in reports for up to 30 days and then become eligible for deletion in bounded cleanup batches. Current cleanup runs when measurement endpoints are used; this is not an automatic deletion promise on day 30. Turning measurement off revokes the current measurement consent and removes its associated website events. Other retained records and backups follow the applicable retention and deletion process. An Allow receipt expires after 30 days; allowing measurement again requires a new choice.

For broader privacy information or a privacy request, see our Privacy Policy or contact support@thesis.trade. Do not include passwords, brokerage credentials or sensitive trading information in a request.