Our Commitment to You

Portfolio Lab is a product of alphaAI Capital Management LLC (“alphaAI,” “we,” “our,” or “us”), an investment adviser registered with the Securities and Exchange Commission. This Privacy Policy describes how we collect, use, and protect your personal information when you use Portfolio Lab (“PL” or the “Service”).

We are committed to safeguarding your personal information. We do not sell your personal information to anyone. We protect the security and confidentiality of your data and use it only for proper business purposes in connection with providing the Service.

If you also use alphaAI Capital’s Managed Portfolios service, the alphaAI Capital Privacy Policy governs the collection and use of your information in connection with that service. This Privacy Policy covers only your use of Portfolio Lab.

Information We Collect About You

Account Information

When you create a Portfolio Lab account, we collect:

• Name
• Email address
• Password (stored in encrypted form)
• Authentication method (email and password, Google, or Apple)

If you sign in using Google or Apple, those providers share basic profile information with us, and your authentication is subject to their respective privacy policies.

Subscription and Billing Information

If you subscribe to a paid tier (Analyst or Quant), we collect:

• Billing name and address
• Payment method details (processed by Stripe; we do not store full card numbers)
• Subscription tier and billing period
• Transaction history

Strategy and Portfolio Data

When you use Portfolio Lab to build and manage strategies, we collect:

• Strategy type selections
• Asset selections (tickers)
• Build results, including optimization targets and performance metrics
• Paper Portfolio configurations and performance data
• Daily briefing engagement (opens, clicks)

Usage Data

We automatically collect information about how you interact with the Service:

• Pages visited, features used, and actions taken within the app
• Device and browser information (IP address, operating system, browser type)
• Session details (duration, referrer URLs, navigation paths)
• Performance data (page load times, errors encountered)

Sensitive Personal Information

We do not collect Sensitive Personal Information as defined under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). We do not collect government identifiers, precise geolocation, racial or ethnic origin, religious beliefs, union membership, biometric data, health information, sexual orientation, or contents of private communications.

Information We Do NOT Collect

Portfolio Lab does not collect your Social Security number, date of birth, bank account information, brokerage credentials, or other sensitive financial information unless you separately enroll in alphaAI Capital’s Managed Portfolios service, which is governed by its own privacy policy and requires separate onboarding (including KYC verification).

How We Use Your Information

We use the information we collect for the following purposes:

• To provide, maintain, and improve the Service, including generating AI-optimized strategies, operating Paper Portfolios, and delivering daily briefings
• To manage your account and process subscription payments
• To communicate with you about the Service, including product updates, feature announcements, and support
• To understand usage patterns and improve the user experience through analytics
• To detect, prevent, and address technical issues, fraud, and security risks
• To comply with legal and regulatory obligations

Community Features and Aggregated Data

Portfolio Lab uses aggregated and pseudonymized data from your Builds and Paper Portfolios to power community features such as:

• Leaderboards showing top-performing Paper Portfolios. No usernames or identifying information are displayed to other users
• Trending assets (which tickers are most popular across all users)
• Popular Builds (which strategy type and asset combinations are most common)
• Personalized performance insights (for example, “Your portfolio ranked in the top 15% this week”)

We distinguish between three categories of derived data used in the Service:

• Aggregated data: population-level statistics that cannot be linked back to any individual user (for example, the total number of users who built momentum strategies last week)
• Anonymized data: data from which identifiers have been irreversibly removed and which cannot reasonably be linked back to an individual
• Pseudonymized data: data where direct identifiers have been replaced with internal tokens, which remains linkable to an individual user within our systems and is used for personalized features such as performance insights

You may opt out of having your Paper Portfolio data contribute to leaderboards and community features at any time through your account settings or by contacting us at support@portfoliolab.ai. Opting out does not affect your access to other features of the Service or to your own personalized performance insights.

Information We Share

We do not sell your personal information to anyone. We do share certain personal information with advertising partners for cross-context behavioral advertising, as described below in “Advertising Partners.” You have the right to opt out of this sharing; see “Your Rights and Choices” and “California Residents” below for details. We share your information with the following categories of parties for the purposes described below.

Service Providers

We share information with third-party service providers who assist us in operating the Service. These providers are contractually obligated to use your information only for the purposes of providing services to us and to maintain its confidentiality.

• Stripe, Inc. processes subscription payments. Stripe collects payment details (card number, billing address) directly and securely. We do not store your full payment details. For more information, see Stripe’s Privacy Policy at https://stripe.com/privacy
• Alpaca Securities LLC provides paper trading services for Portfolio Lab’s Paper Portfolio feature. When you deploy a strategy to your Paper Portfolio, Alpaca executes simulated trades using real market data. Alpaca is a FINRA-registered broker-dealer. For more information, see Alpaca’s Privacy Policy at https://forum.alpaca.markets/privacy
• PostHog, Inc. provides product analytics. PostHog collects usage data (pages visited, features used, session details) to help us improve the Service. PostHog does not collect personally identifiable information such as Social Security numbers or financial details. For more information, see PostHog’s Privacy Policy at https://posthog.com/privacy
• Email service providers. We use Mailchimp for marketing emails (such as product announcements and newsletters) and SendGrid for transactional emails (such as account confirmations and password resets). Both process your email address and engagement data on our behalf. For more information, see Mailchimp’s Privacy Policy at https://mailchimp.com/legal/privacy/ and SendGrid’s (Twilio’s) Privacy Policy at https://www.twilio.com/legal/privacy
• Webflow, Inc. hosts our public marketing site at portfoliolab.ai. Webflow may process information submitted through web forms, including names and email addresses, along with standard server log data. For more information, see Webflow’s Privacy Policy at https://webflow.com/legal/privacy
• Google services, including Google Analytics and Google Tag Manager, may be used on the marketing site for usage analytics and tag management. These services may collect IP address, browser and device information, pages visited, and referrer URLs. For more information, see Google’s Privacy Policy at https://policies.google.com/privacy
• Cloud service providers. We use third-party cloud service providers to host our infrastructure, store data, and operate the Service. These providers are contractually obligated to protect the information they process on our behalf

Advertising Partners

We work with third-party advertising networks to deliver advertising about Portfolio Lab to users across other websites and platforms. These advertising activities involve sharing limited information (such as cookie identifiers, device identifiers, IP address, and information about your interactions with portfoliolab.ai) with advertising networks so that we can show you relevant ads and measure the effectiveness of those ads. Under the California Consumer Privacy Act, this constitutes “sharing” of personal information for cross-context behavioral advertising. We do not receive payment from advertising networks for sharing this information.

Our current advertising partners include:

• Google Ads (Google LLC), for ad placement, retargeting, and conversion measurement. For more information, see Google’s Privacy Policy at https://policies.google.com/privacy
• From time to time, we may also use other advertising platforms, including Meta Platforms, Inc. (Facebook and Instagram). Where we do so, your interactions with portfoliolab.ai may be associated with your account on those platforms for ad targeting purposes. For more information, see Meta’s Privacy Policy at https://www.facebook.com/privacy/policy

You have the right to opt out of this sharing. See “Your Rights and Choices” and “California Residents” for details, including how we honor the Global Privacy Control signal.

Legal and Regulatory

We may disclose your information to comply with applicable law, respond to legal process (such as a subpoena or court order), protect our rights or the safety of others, investigate fraud, or respond to government requests.

Corporate Transactions

In the event of a merger, acquisition, reorganization, sale of assets, or similar corporate event, your information may be transferred as part of the transaction. We will notify you of any such change in ownership or control of your personal information.

With Your Consent

We may share your information for other purposes with your explicit consent.

Relationship to alphaAI Capital Managed Portfolios

Portfolio Lab includes a “Deploy with Real Money” feature that allows you to deploy strategies through alphaAI Capital’s Managed Portfolios service. If you choose to use this feature:

• You will be directed to the alphaAI Capital onboarding process, which requires separate account setup, KYC verification, and agreement to the alphaAI Capital Privacy Policy and Investment Advisory Agreement
• Additional personal information (including Social Security number, income, and bank account details) will be collected as part of that process and governed by the alphaAI Capital Privacy Policy
• Your Portfolio Lab subscription and your Managed Portfolios account are separate. This Privacy Policy covers only your use of Portfolio Lab

Data Security

We maintain a written information security program that includes physical, administrative, and technical safeguards designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These safeguards include:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication, including support for Google and Apple sign-in
• Access controls limiting employee access to personal information on a need-to-know basis
• Employee training on security and privacy
• Regular security reviews and monitoring
• Due diligence on service providers and contractual requirements that they protect customer information they process on our behalf

No system is perfectly secure, and we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential and notifying us promptly of any unauthorized use of your account.

Data Breach Notification

If we determine that your personal information has been, or is reasonably likely to have been, accessed or used without authorization, we will notify you as required by applicable law, generally within 30 to 60 days of confirming the incident, depending on the requirements of the state in which you reside. We may also notify regulators and other parties as required by law.

Cookies and Tracking Technologies

We use cookies, pixel tags, and similar technologies to operate the Service and understand usage patterns:

• Essential cookies are required for the Service to function (authentication, session management)
• Analytics cookies (via PostHog and Google Analytics) help us understand how users interact with the Service and the marketing site
• Advertising and retargeting cookies on the Portfolio Lab marketing site (portfoliolab.ai) are used by our advertising partners (currently Google Ads, and from time to time other platforms) to measure the effectiveness of our advertising and to show you relevant ads on other websites and platforms. These cookies enable cross-context behavioral advertising as described in “Advertising Partners” above

Marketing and product emails may contain pixel tags that allow us to determine whether the email was opened and which links were clicked. You can disable this by setting your email client to not load remote images.

You may adjust your browser settings to block or delete cookies, including third-party cookies used for advertising, though this may impact the functionality of the Service. You may also opt out of personalized advertising through industry tools such as the Network Advertising Initiative’s opt-out page at https://optout.networkadvertising.org and the Digital Advertising Alliance’s opt-out page at https://optout.aboutads.info, and through the ad settings of individual platforms such as Google’s My Ad Center at https://myadcenter.google.com.

Global Privacy Control

The Global Privacy Control (“GPC”) is a browser-level signal that communicates a user’s preference to opt out of the sale or sharing of their personal information. We recognize and honor the GPC signal where required by applicable law. When we detect a GPC signal from your browser, we treat it as an opt-out of sharing for cross-context behavioral advertising for that browser. For more information about GPC, see https://globalprivacycontrol.org.

Do Not Track

Because there is no consistent industry standard for Do Not Track (“DNT”) signals, our Service does not respond to DNT signals. We do, however, honor the Global Privacy Control signal as described above.

Data Retention

We retain your information for as long as your account is active or as needed to provide the Service, and as follows:

• Account data is retained for the lifetime of your account and for up to 90 days following account deletion to allow for recovery
• Subscription and billing records are retained for seven years to comply with tax and audit requirements
• Paper Portfolio account data is retained for 90 days after downgrade or account termination, after which the underlying paper account is decommissioned
• Marketing email preferences are retained until you opt out, and for 30 days following opt-out to confirm the change
• Analytics data is retained in accordance with PostHog’s default retention period or as we configure

If you delete your account, we will delete or anonymize your personal information within the timeframes above, except where retention is required by law (for example, to comply with tax or recordkeeping obligations). Aggregated and anonymized data may be retained indefinitely as it cannot be used to identify you.

Information About Former Users

We do not disclose personal information to non-affiliated third parties with respect to persons who are no longer Portfolio Lab users, except as described in this Privacy Policy or as required or permitted by law.

Your Rights and Choices

You have the following rights and choices with respect to your personal information:

• Access and update: you can access and update your account information through the Settings page in the app
• Delete your account: you may request deletion of your account by contacting support@portfoliolab.ai. We will process your request within a reasonable timeframe and in accordance with applicable law
• Email preferences: you may unsubscribe from marketing emails at any time using the unsubscribe link in any email. Transactional emails (such as payment confirmations and security alerts) cannot be unsubscribed from while your account is active
• Cookie preferences: you may adjust your browser settings to block or delete cookies
• Analytics opt-out: you may opt out of PostHog analytics tracking via your browser settings or privacy-focused browser extensions
• Community features opt-out: you may opt out of having your Paper Portfolio data contribute to leaderboards and community features through your account settings or by contacting us at support@portfoliolab.ai
• Advertising opt-out: you may opt out of cross-context behavioral advertising by enabling the Global Privacy Control signal in your browser, by adjusting your browser settings to block third-party cookies, by using industry opt-out tools listed in the Cookies section above, or by contacting us at support@portfoliolab.ai

California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), gives you the following rights with respect to your personal information:

• The right to know what categories of personal information we collect, the sources of that information, the purposes for which we use it, and the categories of third parties we share it with
• The right to access the specific pieces of personal information we have collected about you
• The right to request deletion of your personal information
• The right to correct inaccurate personal information
• The right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. We do not sell your personal information. We do share certain personal information with advertising partners for cross-context behavioral advertising, as described in “Advertising Partners.” You may exercise this opt-out right by enabling the Global Privacy Control signal in your browser (which we honor as an opt-out), by adjusting your browser settings to block third-party cookies, by using industry opt-out tools listed in “Cookies and Tracking Technologies,” or by contacting us at support@portfoliolab.ai
• The right to limit the use and disclosure of Sensitive Personal Information. As stated above, we do not collect Sensitive Personal Information
• The right not to receive discriminatory treatment for exercising your privacy rights

To exercise any of these rights, contact us at support@portfoliolab.ai. We may need to verify your identity before fulfilling your request. You may also designate an authorized agent to make a request on your behalf; the authorized agent must provide written documentation of your authorization.

Other State Residents

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Delaware, Iowa, or another state that has enacted a comprehensive consumer privacy law, similar rights may apply to your personal information. The specific rights and the request process vary by state. To exercise these rights, contact us at support@portfoliolab.ai.

Children’s Privacy

Portfolio Lab is intended for individuals 18 years of age and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe a person under 18 has provided personal information to us, please contact us at support@portfoliolab.ai.

International Users

Portfolio Lab is intended for residents of the United States. We do not actively offer or market the Service to individuals outside the United States. If you access or use Portfolio Lab from outside the United States, you do so at your own initiative and are responsible for compliance with local laws. The Service is hosted in the United States and your information will be processed in the United States, which may have data protection laws that differ from those in your country.

Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or by posting a notice on the Service prior to the change becoming effective. The effective date at the top of this policy reflects the most recent update. Your continued use of the Service after the effective date of the revised policy constitutes your acceptance of the changes.

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at:

Portfolio Lab by alphaAI Capital Management LLC

Email: support@portfoliolab.ai

Web: https://portfoliolab.ai

You may also obtain a copy of this Privacy Policy at any time by visiting portfoliolab.ai/legal/privacy or by contacting us at the email address above.

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