Privacy Policy

Depending on the features you use and your interactions with us, we may collect the following categories of information:

a. Information you provide and account records

• Contact information — Your name and email address.
• Billing information — Your subscription plan, billing cycle and status, and payment or transaction identifiers from the payment channel you use, such as Stripe or the App Store. Card details are entered with the payment provider; we do not receive or store your full card number.
• Account information — Your password, stored only as a one-way hash if you use password sign-in; your Google or Apple account association if you use that sign-in method; your language, profile photo, and email preferences.
• Requests and content — Your feedback, inquiries, and records of report requests, generation, access, and sharing. If you use an interactive AI feature that accepts your input, we also process the input and the resulting response to provide that feature.

b. Device and usage information

• Device and usage records — IP address, browser and operating system, access times, pages and features used, and related session and diagnostic information. These records may be associated with account identifiers.
• Cookies and similar technologies — Technologies used to maintain sessions, remember preferences, analyze usage, and support security. Their use depends on the features and tools in operation.

c. The stocks Lumi watches and research inputs

• Stocks Lumi watches — The stocks you choose to follow. We use this list to display reports and, according to your preferences, deliver Daily reads emails. Plan limits and data availability may affect updates and delivery. This list is a content selection, not a statement of your holdings or financial circumstances. Sharing of this information is subject to the How we share your information section. You can add or remove stocks and manage email preferences in Settings.
• Research inputs — Market and financial data, company disclosures, news, and other third-party information sources used to analyze securities and generate research. These are distinct from the account and usage information described above.

We use the information we collect in the following ways:

• To provide services — Delivering and maintaining our services, including AI-powered stock analysis and data analytics.
• To improve our services — Analyzing usage and feedback to improve user experience and develop features. AI-related data uses are described in the AI and data use section below.
• To communicate — Sending account, billing and service notices, the Daily reads email (which you can turn off at any time), product updates (which you can turn off in Settings), and replying to your inquiries.
• To process transactions — Managing billing, payments, and related financial transactions through secure third-party processors.
• To ensure security — Monitoring and protecting against unauthorized access, fraud, and other security threats.
• To comply with legal obligations — Fulfilling legal and regulatory requirements related to data protection and consumer privacy.

AI-specific uses:

• Content preferences — Showing you reports on the stocks Lumi watches for you. This is done by ordinary software, not by AI; the AI models that write reports are not told who follows a stock.

We do not sell your personal data. We may share your information in the following circumstances:

• Service providers — We disclose information needed by providers that help deliver the Services, such as payment processing, analytics, email delivery, hosting, sign-in, and AI and speech features. Providers handle information under applicable contracts and law. The current report-generation inputs sent to AI providers are described in the AI and data use section below.
• Shared reports — When you share a report, anyone with the link can read it until you stop sharing it. The shared page does not show your name or email address.
• Legal requirements — When required by law, regulation, or legal process, including to respond to subpoenas, court orders, or governmental requests.
• Business transfers — In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction. We will notify you via email and/or prominent notice on our website of any change in ownership or uses of your information.
• With your consent — When you have given explicit consent for us to share your information for specific purposes, such as participating in a survey or a promotional offer.

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access — Request access to the personal information we hold about you, including the stocks Lumi watches for you.
• Correction — Request correction of any inaccurate or incomplete information.
• Deletion and account termination — You may delete your account in Settings or ask us to delete your personal information. Account deletion turns off auto-renew for a website subscription. App Store subscriptions must be canceled separately in the App Store. Signing in within 30 days restores your account, but auto-renew for a website subscription remains off unless you resume it under Subscription in Settings. After the 30-day recovery period, we will use scheduled cleanup to delete or de-identify account-associated data, disable sharing links, and cancel any website subscription still active. We may retain records needed for billing, legal compliance, fraud prevention, or disputes. General research content no longer associated with your account may remain. Refunds are governed by the Terms of Service, including any applicable legal exceptions.
• Export — Where applicable law gives you this right, request a copy of your personal information in a commonly used, machine-readable format.
• Email choices — Turn off the Daily reads email or product updates at any time with the unsubscribe link in the email or in Settings.

These rights may vary depending on your location. To exercise these rights, please contact us at hello@apextrader.ai. We usually reply within 45 days. To make sure it is you, please write from the email address of your account.

California residents have specific rights regarding their personal information under the California Consumer Privacy Act (CCPA). These include the right to request disclosure of what personal information we collect, use, and share, the right to request deletion of personal information (subject to certain exceptions), and the right to opt-out of the sale of personal information if applicable. California residents can exercise these rights by contacting us. We will not discriminate against you for exercising your rights under the CCPA. Note that while we have designed our Privacy Policy to accommodate these requirements, we make no representation that we are currently subject to the CCPA.

We use account and content preferences to manage the Services and display the research you choose to follow. This does not mean we assess whether an investment is suitable for you. Research views are not tailored to your holdings, financial circumstances, investment objectives, or risk tolerance.

We use reasonable technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage can be guaranteed completely secure.

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

In practice:

• Account and reports — kept while your account exists, and deleted or de-identified after the 30-day recovery period if you delete it.
• Usage, analytics, and diagnostic records — kept as long as reasonably needed to operate, secure, and improve the Services. Server logs and backups are cleared automatically on a fixed schedule.
• Billing, transaction, and terms-acceptance records — kept as needed for tax, accounting, legal compliance, and disputes.
• Payment records — held by our payment processor under its own retention rules.

When information is no longer needed for these purposes, we delete or de-identify it, subject to applicable law and the time needed to clear backups and provider systems.

Your information may be stored and processed in the United States and other countries where we or our service providers operate. Their data-protection laws may differ from those where you live. We take safeguards required by applicable law.

The Services are not intended for anyone under 18. We do not knowingly collect personal information from people under 18. If we learn that we have done so, we will take steps to delete that information promptly.

a. Models and research inputs

We currently use large language models from third-party providers rather than training or fine-tuning our own models. Reports are generated from market and financial data, company disclosures, news, other third-party information sources, and calculations made by our software.

b. What report-generation models receive

The current report-generation workflow does not send your name, email address, direct account identifiers, payment details, or the list of stocks Lumi watches for you to AI models. When you request an Investment outlook report, a recent report generated for you on the same stock may be included to explain changes, without those direct identifiers. Displaying reports according to the stocks Lumi watches for you is handled by ordinary software; it does not tell the model who follows a stock.

c. Training and service improvement

We currently do not use account information or identifiable user content to train or fine-tune AI models. We may use aggregated or de-identified usage data and feedback to analyze, evaluate, and improve the Services, including AI features. Material changes to how we use identifiable personal information are subject to our existing commitments and the notice and consent requirements described below.

d. Limitations

AI outputs may contain errors or bias. We improve how models are used in response to identified issues, but do not guarantee error-free or bias-free outputs. Research opinions and forward-looking estimates, including target prices, are not tailored to your financial circumstances and are not guarantees. Where applicable privacy law gives you rights concerning automated decisions about you, you may contact us as described in the User rights section.

We may update this policy as our Services and information practices evolve. We will publish the revised policy and its updated date. We will provide prominent notice of material changes to our information practices before they take effect and obtain consent where applicable law requires it. An update does not by itself authorize us to use previously collected information in a way that conflicts with commitments made when it was collected.

Our website may link to third-party websites, services or resources. We are not responsible for their privacy practices or content. Review their privacy policies when you visit.

We use cookies and similar technologies to keep you signed in, remember your preferences, and understand how the site is used. For product analytics we use a third-party analytics service, and link this to your account when you are signed in. We do not use advertising trackers, and we do not sell or share personal information for cross-context advertising. We do not respond to browser Do Not Track (DNT) or Global Privacy Control (GPC) signals. You can also manage cookies in your browser settings; disabling cookies may affect how the website works.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at hello@apextrader.ai.

Registered address: Apex Thoughts LLC, 30 N Gould St Ste N, Sheridan, WY 82801, United States.