Privacy, plainly.

TruVest respects your privacy. This Privacy Policy explains how Truvest Tech Inc., doing business as TruVest (“TruVest,” “we,” “us,” or “our”), collects, uses, stores, shares, and protects personal information when you use our mobile applications, website, community features, and related services (collectively, the “Service”).

TruVest is operated by Truvest Tech Inc., headquartered in Kitchener, Ontario, Canada.

For privacy questions or requests, contact us at:

• Privacy contact: admin@truvesttech.com
• Support contact: admin@truvesttech.com
• Data protection officer and privacy lead: admin@truvesttech.com

Please read this Privacy Policy together with our Terms of Use.

This Privacy Policy applies to personal information we collect through the Service and in our communications with you.

The Service is for adults aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided personal information to TruVest, contact us at admin@truvesttech.com so that we can investigate and take appropriate action.

The information we collect depends on how you use TruVest and the features you choose to enable.

When you create or manage an account, we may collect:

• name, username, email address, phone number, password, and account identifier
• date of birth or age confirmation
• profile photo, biography, location or country, and other profile information you choose to provide
• communication preferences, notification settings, and subscription status; and
• support requests and correspondence with us.

If you choose to connect an eligible brokerage or financial account through an authorized third party connection provider or broker flow, we may receive information that you authorize the provider to make available to us.

Depending on the connection and permissions you authorize, this may include:

• a connection identifier or token
• broker or account provider name
• holdings, positions, asset allocations, balances, portfolio values, and performance information
• securities or other instruments held
• dividends or other portfolio related information; and
• account connection status and related technical information.

TruVest does not ask for, receive, or store your brokerage login credentials. TruVest does not execute trades, hold assets, or access your funds.

We use connected data to provide the portfolio features you request. Connected portfolio information is private by default. We display it to other users only if you actively choose to share selected information through the Service.

When you use social or community features, we may collect:

• posts, comments, reactions, follows, saved content, reports, and messages where messaging is offered
• links, images, videos, and other content you submit
• public portfolio sharing choices and information you elect to publish
• moderation history, including reports you make or receive; and
• information about your interactions with community features.

Content you make public may be visible to other users and may be copied, shared, or discussed by them. Please do not post confidential information, account credentials, or financial information you do not want others to see.

If you choose to use audio features, we collect:

• voice notes you record and send in direct messages, with their length and a visual waveform
• your voice when you speak in a Talks room after choosing to go on the microphone
• recordings of Talks rooms, only where the host turns recording on; everyone in a recorded room sees that it is being recorded
• comments, mentions, likes, and reactions in Talks rooms; and
• the rooms you host, join, schedule, set reminders for, share, or mark as not interested.

We access your microphone only when you record a voice note or speak in a room. Listeners join rooms with the microphone off. Audio in a room that is not being recorded is passed between participants as it happens and is not stored.

A Talks room is open to everyone signed in, to the host’s followers only, or only to people the host invites, as the host chooses. People blocked by or blocking the host, and people the host has removed, cannot join. A private room is not shown to anyone who cannot join it. A room recording can be played by anyone who could join the room, for 30 days after the room ends, unless the host deletes it sooner.

Ask Tru answers questions about stocks, posts, and portfolios. It only runs when you ask it something: when you mention @Tru in a post or a reply, or when you send Tru a message.

To write an answer, we send your question to an AI model run for us by a third party AI service provider, together with the information needed to answer it: the post and the replies above your question, public market prices, recent news headlines, and any photo in that post. In a private chat with Tru, we also send your holdings as a percentage of your portfolio, with their names and returns in percent. We never send amounts, balances, share counts, your name, your email address, or any contact details.

Our AI service provider processes this only to produce the answer. It does not store your question or the answer, and it does not use them to train any model.

An answer in a public thread is public, like any other reply. An answer in a private chat is kept with your messages, like any other message. For each question we record who asked and when, so we can apply the daily limit (3 questions a day, or 20 with Premium) and keep track of costs.

Ask Tru answers are for information only. They are not financial advice or a recommendation to buy or sell anything.

When you access the Service, we may automatically collect:

• device type, operating system, browser type, app version, language, time zone, and device identifiers
• IP address, approximate location derived from IP address, and network information
• log data, crash reports, performance information, and security events
• pages, screens, features, links, and content you interact with; and
• cookie, SDK, and similar tracking information.

When you purchase a subscription through Apple’s App Store or Google Play, Apple or Google processes your payment. TruVest may receive limited information about the purchase, such as subscription status, product type, renewal date, transaction identifier, and confirmation that payment was completed.

We do not receive or store your full payment card number from Apple or Google subscription purchases.

If you opt in to marketing communications, we may collect your email address, notification token, preferences, and engagement information, such as whether you opened an email or interacted with a notification.

You can unsubscribe from promotional emails using the unsubscribe link in the email. You can manage push notifications through your device settings or the Service settings.

We may use personal information to:

• create, authenticate, and maintain your account
• provide portfolio, watchlist, market data, news, community, and subscription features
• facilitate and maintain authorized broker or financial account connections
• display portfolio information only in accordance with your sharing choices
• process subscriptions, verify entitlements, and provide customer support
• send service related messages, including security alerts, changes to the Service, and subscription notices
• send marketing emails or push notifications where you have opted in or where otherwise permitted by law
• personalize content and improve the relevance, usability, performance, and security of the Service
• detect, investigate, prevent, and respond to fraud, scams, abuse, security incidents, and violations of our Terms of Use
• comply with legal, regulatory, accounting, tax, and record keeping obligations
• enforce our agreements and protect the rights, safety, property, and integrity of TruVest, our users, and others; and
• create aggregated information, or information with identifiers removed, that does not reasonably identify you.

Where applicable law requires a legal basis for processing, including for users in the European Economic Area (“EEA”), United Kingdom, and certain other jurisdictions, we rely on one or more of the following:

Contract: to provide the Service you request, including account administration, portfolio features, and subscriptions.

Consent: for optional analytics, marketing communications, certain cookies or SDKs, and other processing where consent is required.

Legitimate interests: to maintain security, prevent fraud and abuse, improve the Service, understand service usage, and protect our legal rights, provided those interests are not overridden by your rights.

Legal obligation: to meet legal, regulatory, tax, accounting, or compliance requirements.

Vital interests or public interest: where necessary in limited circumstances permitted by law.

You may withdraw consent at any time. Withdrawal does not affect processing that occurred before you withdrew consent or processing we are otherwise legally permitted to conduct.

We do not sell personal information. If you allow personalised ads, we share an advertising identifier and a few app events with advertising partners, as described in the Advertising section below. You can turn this off at any time.

We may share personal information only as described below:

Service providers: vendors that help us operate the Service, such as hosting, database, security, analytics, customer support, email, push notification, and technical service providers.

Advertising partners: companies that show and measure TruVest adverts in other apps and on other websites. They receive an advertising identifier and the app events described in the Advertising section, only if you allow personalised ads.

AI service provider: a provider that runs the AI models behind Ask Tru and receives the information described in the Ask Tru section only when you ask Tru a question.

Brokerage connection providers and brokers: when you choose to connect an account or use a connection related feature, subject to the applicable provider’s and broker’s terms and privacy notices.

App stores and payment platforms: Apple and Google in connection with app distribution, subscriptions, and purchase verification.

Other users: when you choose to make your profile, portfolio information, posts, comments, or other content visible to them.

Professional advisers and authorities: legal advisers, auditors, insurers, regulators, law enforcement, courts, or other parties where reasonably necessary to comply with law, protect rights, respond to valid legal process, investigate fraud, or protect safety.

Corporate transactions: a buyer, investor, lender, successor, or other party involved in a merger, financing, acquisition, reorganization, sale of assets, or similar transaction, subject to applicable law.

With your direction or consent: where you ask or authorize us to share information.

We require service providers to handle personal information only for authorized purposes and to maintain appropriate confidentiality and security protections.

TruVest operates from Canada. Our primary database is hosted in Frankfurt, Germany, and so are Talks live audio and room recordings. Personal information may also be accessed or processed in Canada and other countries where TruVest, our affiliates, or service providers operate.

When personal information is transferred internationally, we use appropriate safeguards required by applicable law. For EEA and UK users, this may include European Commission approved Standard Contractual Clauses, adequacy decisions, or another valid transfer mechanism, as appropriate.

You may contact us at admin@truvesttech.com to request more information about applicable transfer safeguards.

We use cookies, SDKs, pixels, and similar technologies on our website and app.

These technologies may be used to:

• keep the Service functioning and secure
• remember preferences and settings
• understand usage, performance, and technical problems
• measure the effectiveness of communications; and
• improve the Service.

In the mobile app we use an analytics service provider to understand how the app is used. It records the screens you open, the features you use, an app instance identifier, and your account identifier once you sign in. It does not record your portfolio value, your holdings, your balances, or anything you write.

App analytics is on by default. You can turn it off at any time in the app, under Settings and then Privacy and Data, and collection stops from that moment. Your choice is stored against your account, so it follows you to a new device.

We advertise TruVest in other apps and on other websites. We do not show adverts inside TruVest.

If you allow personalised ads, we share an advertising identifier and a few app events with our advertising partners: that you installed or opened the app, that you finished signing up, and that you finished setting up your account. This lets us measure which adverts work and show our adverts to people likely to find TruVest useful, and not to people who already use it.

We never share your holdings, amounts, balances, posts, messages, name, email address, or contact details for advertising.

On iPhone, we ask for your permission first through Apple’s tracking request, and nothing is shared unless you allow it. On Android, personalised ads are on by default, except in the United Kingdom and the European Economic Area, where we ask you first. On any device you can turn personalised ads off at any time in the app, under Settings, then Privacy and safety, then Personalised ads. On iPhone you can also turn off tracking under your device’s Settings, then Privacy and Security, then Tracking. Turning analytics off in the app also stops all sharing for advertising.

You can also manage cookie preferences through your device and browser settings, and manage certain device permissions through your device settings.

Blocking or deleting certain technologies may affect the availability or functionality of parts of the Service.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Service, meeting legal obligations, resolving disputes, enforcing agreements, and maintaining security.

In general:

• account and profile information are retained while your account remains active
• connected data records are retained while a connection remains active and for a limited period after disconnection, unless a longer period is required for security, legal, or record keeping purposes
• public content may remain visible until you remove it, your account is deleted, or TruVest removes it under our Terms of Use
• voice notes are kept until you delete them or your account is deleted; deleting a voice note deletes its audio
• Talks room recordings and room comments are deleted 30 days after the room ends
• Ask Tru answers in public threads stay until they are removed like any reply; answers in a private chat stay with your messages; the record of each question (who asked and when) is kept only as long as needed for daily limits and cost tracking
• subscription records are retained as required for accounting, tax, fraud prevention, and legal purposes; and
• security, fraud, and system logs are retained for a period appropriate to their purpose.

After the applicable retention period, we delete, anonymize, or securely strip the identifiers from information, unless we are required or permitted to keep it longer.

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure.

No system is completely secure. You are responsible for protecting your password and devices, and for notifying us promptly if you suspect unauthorized access to your account.

Depending on where you live and applicable law, you may have the right to:

• request access to personal information we hold about you
• request correction of inaccurate or incomplete information
• request deletion of personal information
• request restriction of certain processing
• object to certain processing, including direct marketing
• withdraw consent
• request a portable copy of certain information
• request information about our use or disclosure of your personal information
• lodge a complaint with a relevant data protection authority; and
• not be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

To submit a request, email admin@truvesttech.com with the subject line “Privacy Request.” We may need to verify your identity before completing a request. We will respond within the period required by applicable law.

You may also:

• disconnect a connected brokerage account through the relevant account connection process
• change portfolio visibility settings in the Service
• update certain account information through your profile settings
• opt out of promotional emails using the unsubscribe link; and
• manage push notifications through your device or Service settings.

Some rights are subject to legal exceptions. For example, we may retain information where necessary for legal compliance, fraud prevention, security, accounting, or the establishment, exercise, or defence of legal claims.

If you are in the EEA or United Kingdom, you may have rights to access, correct, delete, restrict, object to, or port your personal information, and to withdraw consent.

You may also lodge a complaint with the data protection authority in your country of residence, place of work, or location of an alleged infringement. We encourage you to contact us first so we can try to resolve your concern.

If you are in Canada, you may request access to, or correction of, personal information held by TruVest and may challenge our privacy practices by contacting admin@truvesttech.com.

If you are not satisfied with our response, you may have the right to contact the Office of the Privacy Commissioner of Canada or an applicable provincial privacy regulator.

Residents of certain U.S. states may have privacy rights, subject to applicable thresholds and exceptions. These may include rights to know, access, correct, delete, obtain a portable copy of personal information, opt out of certain processing, and not be discriminated against for exercising privacy rights.

TruVest does not sell personal information for money. If you allow personalised ads, sharing an advertising identifier and app events with advertising partners, as described in the Advertising section, may count as sharing for cross context behavioural advertising under some state laws. You can opt out of this sharing at any time in the app, under Settings, then Privacy and safety, then Personalised ads, or through your device’s tracking or advertising settings.

If our practices change, we will update this Privacy Policy and provide any required notices or choices before engaging in a sale or sharing covered by applicable law.

Authorized agents may submit eligible requests on behalf of a user where permitted by law. We may require proof of authorization and identity verification.

The Service may contain links to brokers, market data providers, news providers, YouTube, social platforms, and other third party services.

This Privacy Policy does not apply to third party services. Their collection and use of personal information are governed by their own terms and privacy notices. We encourage you to review them before providing personal information.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or the Service.

If we make a material change, we will provide notice through the Service, by email, or another appropriate method before the change takes effect where required by law. The “Last updated” date at the top shows when this Privacy Policy was last revised.

For questions, concerns, or requests about privacy, contact:

Truvest Tech Inc.
Kitchener, Ontario, Canada
Privacy contact: admin@truvesttech.com
Support contact: admin@truvesttech.com
Data Protection Officer / Privacy Lead: admin@truvesttech.com