Our Commitment to You

alphaAI Capital Management LLC (“alphaAI”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. alphaAI (referred to as "we", "our" and "us" throughout this notice) protect the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.

We do not sell your nonpublic personal information to anyone. Nor does alphaAI provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account as discussed below.

Details of our approach to privacy and how your personal nonpublic information is collected and used are set forth in this privacy policy.

Information We Collect About You

You typically provide personal information when you complete the onboarding process required to become our Client.

This information may include your:

• Name and address
• Assets
• Email address
• Income
• Phone number
• Account balance
• Social security or taxpayer identification number
• Investment activity
• Accounts at other institutions

In addition, we may collect nonpublic information about you from the following sources:

• Information we receive on Brokerage Agreements, Managed Account Agreements and other Subscription and Account Opening Documents;
• Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires;
• Information about your transactions with us or others

Information We Collect via the Referral Program

alphaAI manages referral programs that allow Clients to receive a benefit in exchange for referring an individual who becomes a Client. Participation in any of our referral programs is free and voluntary for our Clients. By participating, a Client is asked to provide to alphaAI the name and email address of each person to whom Client refers alphaAI’s Services. We treat this information like all other Personal Information described in this Privacy Policy.

Information About You that alphaAI Shares

alphaAI works to provide products and services that benefit our customers. We may share nonpublic personal information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose nonpublic personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your nonpublic personal information may also be disclosed to you, persons we believe to be your authorized agent or representative, regulators in order to satisfy alphaAI’s regulatory obligations, and is otherwise required or permitted by law. Lastly, we may disclose your nonpublic personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.

To repeat, we do not sell your nonpublic personal information to anyone.

Information About Former Investors

alphaAI does not disclose, and does not intend to disclose, nonpublic personal information to non-affiliated third parties with respect to persons who are no longer our clients.

Confidentiality and Security

Our employees are advised about the firm's need to respect the confidentiality of our customers' nonpublic personal information. Additionally, we maintain physical, procedural, and electronic safeguards in an effort to protect the information from access by unauthorized parties.

Other Ways We Collect Information

Other means by which we collect Personal Information include the following:

Automatic Data Collection

When you use our Services, we may collect your Internet protocol (“IP”) address; cookie identifiers; mobile carrier, mobile advertising and other unique identifiers; details about your browser, operating system or device; location information; Internet service provider information; pages that you visit before, during and after using the Services; information about the links you click; and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

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Anonymized or Aggregated Information

alphaAI’s Site and App record certain anonymized or aggregated information about your use or evaluation of our Services. Anonymized or aggregated information is used for a variety of purposes, including the measurement of Users’ and Clients’ interest in and use of various portions or features of the Site and App. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including for internal analysis and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

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Cookies and Pixels

Similar to other consumer internet services, alphaAI uses cookies, a small piece of computer code that enables our Web servers to identify Users and Clients, each time an individual initiates a session on our Site. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your hard drive at any time through your browser settings. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.

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Pixel Tags

Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Site. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.

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Site and App Activity

alphaAI may also use third-party tracking technology, such as Google Analytics, to record your activity on our Site and App.

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“Do Not Track” Technology

We do not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different websites or online services.

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Surveys

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.

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Microsoft Clarity

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

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Plaid Inc.

alphaAI utilizes Plaid Inc. ("Plaid") to provide secure and reliable connections to your financial accounts. Plaid allows us to access your account information, such as balances and transaction history, to offer you seamless financial services.

What Plaid Does: Plaid is a third-party service provider that securely links your bank accounts and other financial institutions with our services. When you connect your financial accounts via Plaid, it collects and transmits your account data to us, ensuring the security and integrity of the process.

Data Collected Through Plaid:

• Account details (e.g., account numbers, balances)
• Transaction data (e.g., amounts, dates, merchants)
• Personal identifiers (e.g., name, email)

Please note that Plaid does not share your login credentials or passwords with us.

How We Use Plaid: We use the data provided by Plaid solely to deliver the services you have requested, such as account verification, transaction processing, or financial insights. Your information is not shared with third parties for marketing purposes. 

Data Security: Plaid employs robust security measures to protect your information. We rely on these protections to ensure your data is handled securely when transmitted to our systems.

Your Control: You may disconnect your financial accounts from Plaid at any time by updating your settings. Disconnecting may impact the availability of certain services that rely on this data.

For more information on how Plaid handles your data, please review their Privacy Policy.

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Stripe Inc.

alphaAI utilizes Stripe, Inc. ("Stripe") as our payment processor to securely handle your transactions. Stripe allows us to accept and manage payments, ensuring that your financial data is protected throughout the process.

What Stripe Does: Stripe is a third-party payment processing platform that facilitates secure transactions between our business and our customers. When you make a payment through our service, Stripe collects and processes your payment information on our behalf.

Data Collected Through Stripe: 

• Payment details (e.g., credit/debit card number, expiration date, CVV)
• Billing information (e.g., name, billing address)
• Transaction details (e.g., amount, date, merchant)

Please note that your full payment details are not shared with us; Stripe processes these directly and securely.

How We Use Stripe: We use Stripe to process payments for the services or products you purchase. The payment information collected by Stripe is used exclusively to complete transactions and manage billing.

Data Security: Stripe is PCI-DSS compliant and implements advanced security measures to safeguard your payment information. This includes encryption, tokenization, and other industry-standard practices to protect your data.

Your Control: You have the option to manage your payment methods and review transaction history through your account settings. Any updates to your payment information will be securely handled by Stripe.

For more information on how Stripe handles your data, please review their Privacy Policy.

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Alpaca Securities LLC

alphaAI partners with Alpaca Securities LLC ("Alpaca") to provide brokerage services that enable you to trade securities. Alpaca ensures that your investment transactions are executed securely and in compliance with regulatory standards.

What Alpaca Does: Alpaca Securities LLC is a FINRA-registered broker-dealer that facilitates securities trading on our platform. When you open an account and trade through our service, Alpaca manages the execution, clearing, and custody of your securities transactions.

Data Collected Through Alpaca:

• Personal information (e.g., name, address, Social Security number)
• Financial information (e.g., account balances, transaction history)
• Investment data (e.g., trade orders, asset holdings)

Please note that your personal and financial information is collected by Alpaca directly as part of regulatory compliance and transaction processing.

How We Use Alpaca: We use Alpaca to facilitate your trading activities, including the buying and selling of securities. The data collected by Alpaca is used to execute trades, maintain account records, and comply with regulatory requirements.

Data Security: Alpaca employs robust security measures, including encryption and secure authentication, to protect your data. As a regulated broker-dealer, Alpaca adheres to stringent industry standards to ensure the safety of your personal and financial information.

Your Control: You have access to manage your investment account through our platform, where you can view and update your information, monitor your portfolio, and execute trades. Any changes to your account details are securely processed by Alpaca.

For more information on how Alpaca handles your data, please review their Privacy Policy.

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How do we use and share your information?

We may use and share your personal information as set forth below:

• To onboard you as a customer, including identity verification, credit, AML, KYC checks, or other due diligence efforts;
• Provide the Service to you, including servicing, and maintaining your account, and processing transactions in your account;
• To monitor, support, analyze, and improve the Service;
• To communicate with you regarding the Service and your accounts;
• To fulfill your requests for information regarding the Service and any new or improved products and Service;
• To engage in marketing and advertising activities, provided that, where required under applicable law, we will obtain your prior opt-in consent;
• To understand general customer trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and Service;
• To engage in research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;
• To protect the safety and security of our Service, businesses and customers;
• To third-party contractors and service providers that provide Service to us in the operation of our business and assistance with the Service, such as administrators, broker/dealers, custodians, payment processors, consulting service, IT and cloud service providers, among others;
• To our auditors, attorneys and similar advisors in connection with our receiving their professional Service, subject to standard confidentiality obligations;
• To disclose aggregated, anonymous, user statistics and other information to (i) agents, business partners, and other third parties; (ii) describe the Service to current and prospective business partners; and (iii) other third parties for lawful purposes;
• To share some or all of your information with our parent company, subsidiaries, affiliates or other companies under common control with us;
• To fulfill our legal and regulatory requirements;
• To comply with applicable law, such as to comply with a subpoena, lawful court order, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• To assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your personal information will be part of the transferred assets; and
• Otherwise, with your consent.

We will take reasonable measures (e.g., by contract) to require that any party receiving any of your personal information from us, including for purposes of providing the Service, undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by applicable law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.

How long do we retain your information?

We will retain your information for at least as long as it serves the purposes for which it was initially collected or subsequently authorized. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We'll Keep You Informed

We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our privacy policy and will provide you with a revised policy if the changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of nonpublic personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. You may obtain a copy of our current privacy policy by contacting us at support@alphaai.capital.