DeFolio Privacy Policy

1. Introduction

This Privacy Policy explains how Grant Financial LLC, doing business as DeFolio (“DeFolio,” “we,” “us,” or “our”), collects, uses, shares, and protects information when you use the DeFolio websites, applications, dashboards, analytics, alerts, and related services (collectively, the “Platform”).

By using the Platform you agree to this Privacy Policy. This Policy is incorporated into and supplements the DeFolio Terms of Use.

2. Information You Provide

• Account information: first and last name, email address, password credentials, and account tier.
• Billing information: subscription status, plan, payment history metadata, and identifiers issued by our payment processor. We do not store full card numbers.
• Portfolio inputs: manually entered holdings, watchlists, saved recommendations, saved pools, and alert preferences.
• Exchange connections: read-only API credentials you choose to connect. These are used solely to read balances and positions and can be revoked by you at any time.
• Communications: messages, support requests, and feedback you send to us.

3. Information Collected Automatically

• Usage data such as pages viewed, features used, timestamps, and referring pages.
• Device and technical data such as browser type, operating system, approximate location derived from IP address, and error logs.
• Cookies and similar technologies used for authentication, session management, security, and product analytics.

Most browsers let you refuse or delete cookies. Blocking essential cookies may prevent you from signing in or using core Platform features.

4. How We Use Information

• Provide, operate, personalize, and improve the Platform and its analytics.
• Create and maintain your account, authenticate you, and manage subscription tiers.
• Process payments, refunds, renewals, and cancellations through our payment processor.
• Generate portfolio views, rankings, screens, alerts, and AI-assisted explanations.
• Send transactional email such as confirmations, password resets, receipts, and service notices.
• Send product updates and marketing where permitted; you may opt out at any time.
• Detect, investigate, and prevent fraud, abuse, and security incidents.
• Comply with legal, tax, accounting, and regulatory obligations.

5. Legal Bases for Processing

Where the GDPR or similar law applies, we process personal data on the basis of contract performance (providing the Platform you requested), legitimate interests (securing and improving the Platform), consent (optional marketing and certain cookies), and legal obligation (tax and compliance recordkeeping).

6. Artificial Intelligence Features

Certain features send market data and limited account context to third-party AI model providers to generate summaries, scores, sentiment reads, and plain-English explanations. We do not send exchange API secrets or payment credentials to AI providers. AI output is informational only and may be inaccurate or incomplete.

7. How We Share Information

We do not sell your personal information. We share information only as described below:

• Service providers: hosting, database, authentication, email delivery, website analytics, and customer relationship tooling, each acting on our instructions.
• Payment processing: Stripe processes subscription payments and refunds under its own privacy policy.
• Legal and safety: when required by law, subpoena, or to protect the rights, property, or safety of DeFolio, our users, or the public.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

8. Data Security

We use encryption in transit, access controls, row-level database security, and least-privilege service credentials to protect information. Exchange API credentials are stored with restricted access and used read-only. No method of transmission or storage is perfectly secure, and you are responsible for safeguarding your password and revoking exchange keys you no longer use.

9. Data Retention

We retain account and billing records for as long as your account is active and thereafter as needed to comply with legal, tax, and accounting obligations, resolve disputes, and enforce agreements. Usage logs and cached market data are retained on shorter operational cycles. When you delete your account, we delete or de-identify personal data that we are not required to keep.

10. Your Rights and Choices

• Access, correct, or update your name and email from the Account and Profile page.
• Delete your account and associated personal data by contacting privacy@defolio.io.
• Disconnect exchange connections or remove manual holdings at any time.
• Opt out of marketing email using the unsubscribe link in any such message.
• Depending on your jurisdiction, request a copy of your data, restrict or object to processing, or lodge a complaint with a supervisory authority.

We will verify requests using the email address associated with your account and respond within the period required by applicable law.

11. International Transfers

DeFolio is operated from the United States. If you access the Platform from outside the United States, your information will be transferred to and processed in the United States and other countries where our service providers operate, which may have different data protection laws than your jurisdiction.

12. Children's Privacy

The Platform is not intended for anyone under 18. We do not knowingly collect personal information from children. If we learn that we have collected such information, we will delete it and terminate the associated account.

13. Third-Party Links and Protocols

The Platform links to exchanges, protocols, airdrop pages, data providers, and other third-party sites we do not control. Their collection and use of information is governed by their own privacy policies. Review them before interacting.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will revise the effective date above and, for material changes, provide additional notice through the Platform or by email. Your continued use after an update constitutes acceptance of the revised Policy.

15. Contact Us

Grant Financial LLC d/b/a DeFolio, 4949 Liberty Lane, Allentown, PA 18106. Privacy questions: privacy@defolio.io. Legal questions: legal@defolio.io.