Our Commitment to You

alphaAI Capital Management LLC (“alphaAI,” “we,” “our,” or “us”) is committed to safeguarding the personal information we collect as your investment adviser. We protect the security and confidentiality of personal information in our possession and use it for proper business purposes connected to the management and servicing of your account. Our relationship with you is our most important asset, and we work to maintain that trust.

We do not sell your nonpublic personal information to anyone. We share information with third parties only for discrete and proper business purposes connected with the servicing and management of your account, or as otherwise described in this Privacy Policy.

This Privacy Policy explains how we collect, use, share, and protect personal information when you interact with us.

Scope of This Policy

This Privacy Policy applies to:

• Our website at alphaai.capital
• Our application at app.alphaai.capital
• Any related services we provide under the alphaAI brand

This Privacy Policy does not apply to Portfolio Lab, which operates under a separate brand and a separate privacy policy available at portfoliolab.ai.

Information We Collect

Information You Provide to Us

You typically provide personal information when you complete the onboarding process to become an alphaAI client. The information we collect may include:

• Name and address
• Email address
• Phone number
• Social Security or taxpayer identification number
• Date of birth
• Government-issued identification details
• Employment information
• Income and net worth
• Investment objectives, risk tolerance, and time horizon
• Account balances, transactions, and holdings
• Accounts held at other financial institutions
• Information provided through brokerage agreements, managed account agreements, applications, forms, and questionnaires

Information We Collect Automatically

When you use our website or application, we may automatically collect:

• Internet protocol (IP) address
• Browser type and version
• Operating system and device information
• Mobile carrier and mobile advertising identifiers
• Approximate location based on IP address
• Internet service provider information
• Cookie and other unique identifiers
• Pages you visit before, during, and after using our services
• Links you click and other actions you take
• Session duration and referrer URLs
• Date and time of access

This information may be associated with your account and with other devices.

Anonymized or Aggregated Information

We may record anonymized or aggregated information about how visitors and clients use our services. We use this information for internal analysis and research, including measuring interest in features of our website and application. We may share anonymized or aggregated information with third parties in a form that is designed to prevent identification of individuals.

Information We Collect Through Our Referral Program

alphaAI operates referral programs that allow clients to receive a benefit in exchange for referring an individual who becomes a client. Participation is voluntary and free. When you refer someone, we ask you to provide that person’s name and email address so that we can contact them. We treat this information the same way we treat other personal information described in this Privacy Policy. If you have been referred and would like to opt out of further communications, you may contact us at support@alphaai.capital.

How We Use Your Information

We may use your personal information to:

• Onboard you as a client, including identity verification and required regulatory checks such as anti-money laundering and know-your-customer
• Provide investment advisory services, manage your account, and process transactions
• Monitor, support, analyze, and improve our services
• Communicate with you about your account and our services
• Respond to your inquiries and requests
• Send you marketing and educational communications, subject to your communication preferences and applicable law
• Conduct research, project planning, troubleshooting, and analysis
• Detect, prevent, and investigate fraud, security risks, and unlawful activity
• Protect the safety and security of our services, business, and clients
• Comply with our legal, regulatory, tax, and recordkeeping obligations
• Establish, exercise, or defend legal claims
• Carry out any other purpose disclosed to you at the time of collection or with your consent

How We Share Your Information

We do not sell your nonpublic personal information to anyone. We do share certain personal information collected on our marketing website with advertising partners for cross-context behavioral advertising, as described below under “Advertising Partners.” This sharing primarily involves information about visitors to alphaai.capital and does not involve nonpublic personal information that is subject to the federal Gramm-Leach-Bliley Act. You have the right to opt out of this sharing; see “Your Privacy Rights” below for details. We share personal information only as described below.

Service Providers

We share information with third-party service providers that help us operate our business and deliver our services. These providers are contractually obligated to maintain confidentiality and to use information only for the specific services we have engaged them to perform. Categories include:

• Brokerage and custody services
• Identity verification, AML, and KYC providers
• Payment processors
• Email and marketing service providers
• Analytics and product-improvement service providers
• Customer support tools
• Cloud hosting and infrastructure providers
• Professional advisers, including attorneys, auditors, and consultants

Legal and Regulatory Disclosures

We may disclose personal information to comply with applicable laws and regulations, respond to subpoenas, court orders, or other lawful requests by public authorities, satisfy our regulatory obligations as an SEC-registered investment adviser, protect our rights and the rights of our clients, prevent or investigate fraud, and address security or technical issues.

Authorized Representatives

We may disclose personal information to persons we reasonably believe to be your authorized agent or representative.

Joint Marketing Arrangements

We may disclose nonpublic personal information to other financial institutions with which we have joint business arrangements for proper business purposes connected to the management or servicing of your account.

Business Transfers

In connection with a corporate sale, merger, reorganization, sale of assets, financing, dissolution, or similar corporate event, we may transfer your personal information as part of the transferred assets. We will require any successor to honor the terms of this Privacy Policy.

Affiliates

We may share some or all of your information with our parent company, subsidiaries, affiliates, or other companies under common control with us.

With Your Consent

We may share information with other third parties when you direct us to do so or otherwise consent to the sharing.

Information About Former Clients

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

Service Providers and Third-Party Services

We use the following third-party service providers in the operation of our services. Each is subject to its own privacy policy, which we encourage you to review.

Alpaca Securities LLC

Alpaca is a FINRA-registered broker-dealer that provides brokerage services, including the execution, clearing, and custody of securities transactions for alphaAI clients. When you open an account and trade through our service, Alpaca collects personal information directly from you, including your name, address, Social Security number, account balances, transaction history, and investment data, as required for regulatory compliance and transaction processing. Alpaca is a regulated broker-dealer and applies industry-standard security measures to protect your information.

For more information, see Alpaca’s privacy policy at https://forum.alpaca.markets/privacy.

Plaid Inc.

We use Plaid to provide secure connections between your financial accounts and our services. Plaid collects account details, transaction data, and personal identifiers in order to verify accounts and transmit account information to us. Plaid does not share your bank login credentials or passwords with us. You may disconnect your financial accounts from Plaid at any time through your account settings. Disconnecting may affect the availability of services that rely on this data.

For more information, see Plaid’s end-user privacy policy at https://plaid.com/legal/.

Stripe Inc.

We use Stripe as our payment processor. Stripe collects payment details such as card number, expiration date, and security code, along with billing information and transaction details, in order to process payments on our behalf. Your full payment details are not shared with us. Stripe is PCI-DSS compliant and uses encryption, tokenization, and other industry-standard practices to protect your data.

For more information, see Stripe’s privacy policy at https://stripe.com/privacy.

PostHog, Inc.

We use PostHog, a product analytics platform, to understand how users interact with our website and application. PostHog collects device and browser information, usage data (such as pages visited, time spent on pages, navigation paths, and interactions with buttons and forms), session details, and anonymized or pseudonymized identifiers. PostHog does not collect sensitive personal information such as passwords, Social Security numbers, or financial account details. We use PostHog to monitor and improve performance, identify usability issues, analyze feature engagement, run A/B tests, and detect potential security risks. You may limit PostHog data collection by blocking cookies and tracking scripts in your browser, using privacy-focused browser extensions, or opting out via available platform settings.

For more information, see PostHog’s privacy policy at https://posthog.com/privacy.

Mailchimp (Intuit Inc.)

We use Mailchimp to deliver marketing and educational email communications. Mailchimp collects email addresses, names, and engagement data such as opens, clicks, and unsubscribe events, in order to operate our email programs. You may unsubscribe at any time using the link included in every marketing email, or by contacting us at support@alphaai.capital.

For more information, see Mailchimp’s privacy policy at https://mailchimp.com/legal/privacy/.

Google Services

We use several Google products in connection with our services, including Google Workspace for internal email and document collaboration, Google Analytics for website usage analytics, and Google Tag Manager for managing tracking tags. These products may collect information such as IP addresses, browser and device information, pages visited, and referrer URLs.

For more information, see Google’s privacy policy at https://policies.google.com/privacy.

Webflow, Inc.

We use Webflow to host our public marketing website. 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.

Cloud Service Providers

We use third-party cloud service providers to host our infrastructure, store data, and operate our application. 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 alphaAI 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 alphaai.capital) 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. This sharing primarily involves information collected from visitors to alphaai.capital and does not involve nonpublic personal information that is subject to the federal Gramm-Leach-Bliley Act.

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 alphaai.capital 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 Privacy Rights” for details, including how we honor the Global Privacy Control signal.

Cookies and Tracking Technologies

Cookies

We use cookies, which are small data files stored on your device, to identify you and tailor our website and application to you. Cookies do not store personal information you have provided; they are identifiers. We use the following categories of cookies:

• Essential cookies, required for the website and application to function (such as authentication and session management)
• Analytics cookies, used to understand how visitors use our website and application (currently Google Analytics and PostHog)
• Advertising and retargeting cookies, used on alphaai.capital by our advertising partners (currently Google Ads, and from time to time other platforms such as Meta) 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

You may delete cookies through your browser settings at any time, and you may opt out of personalized advertising through industry tools such as the Network Advertising Initiative’s opt-out page at https://optout.networkadvertising.org, 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. Certain cookies may be necessary to access portions of our services.

Pixel Tags

We use pixel tags, also known as web beacons, to monitor use of our website and application. A pixel tag can collect information such as the IP address of the device that downloaded the page, the URL of the page on which the tag appears, the time the page was viewed, the browser type, and identifiers of cookies previously placed on the device.

Third-Party Tracking

We use third-party tracking technologies, including Google Analytics, Google Tag Manager, PostHog, and Google Ads, as described above. We have used in the past, and may use again in the future, additional advertising pixels, including from Meta.

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

Some web browsers offer a Do Not Track (DNT) signal. Because there is no consistent industry standard for DNT signals, our website does not respond to DNT signals at this time. We do, however, honor the Global Privacy Control signal as described above. We do not knowingly authorize third parties to collect personal information about your online activities over time and across different websites or online services for cross-context behavioral advertising purposes, except as disclosed in this Privacy Policy.

Surveys

From time to time, we may invite you to participate in surveys. Participation is voluntary. If you choose to participate, you may be asked to provide certain information, which may include personal information.

Data Security

We maintain a written information security program that includes physical, administrative, and technical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These safeguards include access controls, authentication requirements, encryption of data in transit and at rest where appropriate, employee training, and ongoing monitoring. We also conduct due diligence on our service providers and require them by contract to 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 for notifying us promptly of any unauthorized use of your account.

Incident Response and Customer Notification

We maintain a written incident response program to address unauthorized access to or use of customer information. If we determine that sensitive customer information has been, or is reasonably likely to have been, accessed or used without authorization, we will notify affected individuals as soon as practicable, and in any event not later than 30 days after we become aware of the incident, unless an exception under applicable law applies. We may also notify regulators and other parties as required by law.

We require our service providers to protect customer information in their possession and to notify us of any breach as soon as practicable, but in any event no later than 72 hours after they become aware of unauthorized access to or use of customer information.

Data Retention

We retain personal information for as long as needed to provide our services and fulfill the purposes described in this Privacy Policy. We also retain information as required by our legal, regulatory, tax, and recordkeeping obligations. As an SEC-registered investment adviser, we are required to maintain certain client records for at least five years under SEC Rule 204-2, and certain corporate and partnership records for the lifetime of the firm. When information is no longer required, we will delete, anonymize, or otherwise dispose of it in accordance with applicable law.

Marketing Communications

We may send you marketing and educational email communications. You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email or by contacting us at support@alphaai.capital. Even if you opt out of marketing communications, we may continue to send you transactional and account-related communications, such as messages about your account, transactions, security, and material updates to our services or legal documents.

Your Privacy Rights

GLBA Opt-Out

Under the federal Gramm-Leach-Bliley Act (GLBA) and Regulation S-P, we share nonpublic personal information only as permitted under specific statutory exceptions, such as for servicing your account, complying with legal requirements, or with your consent. We do not share nonpublic personal information with non-affiliated third parties for marketing purposes.

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 certain rights with respect to personal information that is not subject to the GLBA, such as personal information collected from website visitors who have not become clients. These rights include:

• The right to know what categories of personal information we collect, the sources, the purposes, 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 collected on our marketing website 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@alphaai.capital
• The right to limit use and disclosure of sensitive personal information
• The right not to receive discriminatory treatment for exercising your privacy rights

Personal information that is collected, processed, or disclosed pursuant to the GLBA is exempt from these rights. However, the CCPA’s private right of action for certain data breaches still applies.

To exercise any of these rights, contact us at support@alphaai.capital. We may need to verify your identity before fulfilling your request. You may also designate an authorized agent to act on your behalf.

Other State Residents

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, or another state that has enacted a comprehensive consumer privacy law, similar rights may apply to personal information that is not subject to the GLBA. To exercise these rights, contact us at support@alphaai.capital.

Children’s Privacy

Our services are intended for individuals 18 years of age and older. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided personal information to us, please contact us at support@alphaai.capital and we will take appropriate steps to delete the information.

International Users

Our services are intended for and directed to residents of the United States. We do not offer our services to individuals outside the United States, and our advisory services are available only in jurisdictions where alphaAI Capital Management LLC is registered.

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. When we do, we will update the effective date at the top of this policy. If we make material changes to the way we handle nonpublic personal information, we will provide notice as required by applicable law, including by email, in-app notification, or other reasonable means. Where applicable law permits us to rely on the exception from annual privacy notice delivery under Regulation S-P, we may do so. You can request a current copy of our Privacy Policy at any time by contacting us at support@alphaai.capital.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you would like to exercise your privacy rights, contact us at:

alphaAI Capital Management LLC

Email: support@alphaai.capital

Web: https://www.alphaai.capital

‍