Privacy Policy

1. Who we are and what this policy covers

TruthSayer AI Inc. ("TruthSayer", "we", "us") operates the website at www.truthsayer.com, the TruthSayer web app, and the TruthSayer iOS and Android apps, together with related products and content (the "Services"). We operate from Vancouver, British Columbia, Canada.

This Privacy Policy explains how we collect, use, share and protect personal information when you use the Services, including our AI agent Tru and our brokerage connection and trading features. It forms part of our Terms of Use. Capitalised terms not defined here, such as Brokerage Data, Read-Only Access, Trading Access, Confirmed Order and Automated Rule, have the meanings given in the Terms of Use.

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), British Columbia's Personal Information Protection Act (PIPA), and other privacy laws that apply to you. By using the Services, you consent to the practices described in this policy.

2. Information we collect

We collect information you give us, information from your use of the Services, and information from third parties you choose to connect.

Account and profile information. Your username, password, date of birth, email address and/or phone number, profile details and profile photo.

Content you create. Posts, comments, uploads, watchlists, items you follow, and investment-related content you choose to view or share with other users.

Tru interactions. The questions, instructions and other inputs you send to Tru, the responses Tru generates ("Output"), your notification and follow settings, and any feedback you give on Output.

Brokerage Data. If you connect a brokerage account, we receive information about that account through our connection provider, SnapTrade (see section 4). This can include the brokerage name, account identifiers and type, balances, positions and holdings, transaction and order history, and the access level you granted. We do not receive, collect or store your brokerage login credentials.

Trading information. If you enable Trading Access, we collect the details of Orders you create, confirm or authorise through an Automated Rule. This includes the account, security, side, quantity, order type, price, time in force, the time of your confirmation, the Automated Rule that triggered it (if any), and the status your brokerage returns.

Usage and inferred information. How you use the Services, such as pages and features viewed and engagement with content. We may infer interests, and approximate age and gender, to personalise the Services.

Subscription and payment information. Your subscription tier, trial status and billing history. Payments are processed by third-party payment processors and app stores; we do not store full card or bank account details on our servers.

Device and technical information. Device type, browser, operating system, IP address, app version, crash reports and log data.

Location information. Approximate location derived from your IP address or, with your permission, your device's location services.

Information from social sign-in. If you sign in with a third-party account (such as Google, Apple, Facebook, X/Twitter or Instagram), we receive the basic profile information you allow that provider to share.

Communications. Messages you send to our support team, and your responses to surveys or referral programs.

3. How we use information

We use personal information to:

• Provide, operate and maintain the Services, including your account, subscription and free trial.
• Run Tru: answer your queries, summarise your Brokerage Data, describe risks, and send notifications about items you choose to follow.
• Display your connected accounts and holdings, and submit Orders you confirm or authorise through an Automated Rule.
• Personalise content, features and, where permitted, advertising.
• Process payments and manage subscriptions.
• Provide customer support and send service messages, such as order status, security alerts and changes to our terms.
• Send promotional messages and run referral programs, where you have not opted out.
• Detect, prevent and investigate fraud, abuse, security incidents and violations of our Terms of Use.
• Analyse usage to understand and improve the Services.
• Comply with legal obligations and enforce our rights.
• Any other purpose we describe when we collect the information, with your consent.

How Tru and AI training use your data. Tru processes your inputs, and, where you have connected accounts, your Brokerage Data, in order to generate Output for you. We may use your queries to Tru, in de-identified form where practicable, to improve our AI models and features. We do not use your Brokerage Data to train AI models unless you give separate, express consent, which you can withdraw at any time. Tru Output is generated automatically, may be inaccurate or out of date, and is not investment advice (see our Terms of Use).

4. Brokerage connections and trading

Connection provider. Brokerage connections are made through Passiv Inc., doing business as SnapTrade (the "Connection Provider"). When you connect an account, you sign in to your brokerage through SnapTrade's connection portal, not through TruthSayer. SnapTrade's handling of your information is governed by its own privacy policy and terms, which we encourage you to read.

Credentials. TruthSayer does not receive, collect or store your brokerage username, password or other login credentials.

Access levels. For each connected account you choose:

Access level	What TruthSayer can do
Read-Only Access	Retrieve account details, balances, holdings and transaction history
Trading Access	Everything in Read-Only Access, plus submit Orders on your instruction

When Orders are submitted. With Trading Access, we submit an Order to your brokerage only when (a) you confirm it in the Services (a Confirmed Order), or (b) it is generated by an Automated Rule that you have set up and not paused or revoked. We keep a record of each confirmation and Automated Rule so you can review what was submitted and why.

Changing or revoking access. You can change an account's access level, pause or delete an Automated Rule, or disconnect an account at any time in the Services or through SnapTrade. You can also revoke access from your brokerage directly. Once you disconnect, we stop retrieving new Brokerage Data for that account.

Our role. TruthSayer is not a broker-dealer and does not hold custody of your funds or securities. Your brokerage decides whether to accept and execute any Order, and its own privacy policy governs the information it holds.

Our commitments on Brokerage Data.

• Brokerage Data remains your property.
• We do not sell Brokerage Data.
• We do not use Brokerage Data to train AI models without your separate, express consent.
• You can ask us to delete your brokerage connections and related Brokerage Data at any time (see section 7).

5. How we share information

We share personal information only as described here:

• Connection Provider and brokerages. With SnapTrade and your brokerage, to connect your accounts, retrieve Brokerage Data and submit Orders you confirm or authorise.
• Service providers. With vendors who help us run the Services, such as cloud hosting, analytics and search, AI model providers, content moderation, customer support, email and messaging, and payment processing. They may use the information only to provide services to us and are bound by confidentiality and security obligations.
• App stores and payment processors. With Apple, Google and payment processors to handle downloads, subscriptions and payments.
• Social sign-in providers. With the provider you use to sign in, as needed to authenticate you.
• Other users. Content you choose to post or share publicly can be seen by anyone, and may be indexed by search engines and news sites. Brokerage Data is never made public unless you choose to share it.
• Affiliates. With our subsidiaries and affiliates, under this policy.
• Business transfers. With a successor or acquirer in a merger, acquisition, financing or sale of assets, subject to this policy.
• Legal and safety. With courts, regulators, law enforcement or others when required by law, or to protect the rights, property or safety of TruthSayer, our users or the public.
• With your consent. In any other case, with your consent.

We do not sell your personal information, and we do not sell Brokerage Data.

6. Cookies, advertising, transfers, retention and security

Cookies and similar technologies. We use cookies, web beacons, SDKs and similar technologies to keep you signed in, remember preferences, measure usage, and support advertising. You can manage cookies in your browser or device settings, but some features may not work without them.

Advertising. The Services may display advertising, which may be personalised using usage and inferred-interest information. We do not use Brokerage Data to target advertising.

International transfers. We and our service providers may store and process personal information in Canada, the United States and other countries. Information held in another country may be accessible to that country's courts, law enforcement and national security authorities. We require our providers to protect information to the standard this policy describes.

Retention. We keep personal information only as long as needed for the purposes in this policy, including to provide the Services, keep records of Orders, resolve disputes and meet legal, tax and regulatory obligations. When you disconnect a brokerage account or delete your account, we delete or de-identify the related information within a reasonable time, unless we must keep it by law. We may use de-identified information for legitimate business purposes.

Security. We use physical, electronic and administrative safeguards, including encryption in transit, to protect personal information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

7. Your rights and choices

Subject to applicable law, you can:

• Access and correct your personal information, and edit your profile in Settings.
• Delete content, your brokerage connections and related Brokerage Data, or your entire account.
• Change or revoke brokerage access, and pause or delete Automated Rules, at any time.
• Withdraw consent, including consent to use Brokerage Data for AI training. Withdrawing consent may limit some features.
• Opt out of promotional emails using the unsubscribe link, and manage push notifications in your device settings.
• Complain to the Office of the Privacy Commissioner of Canada or the Office of the Information and Privacy Commissioner for British Columbia.

To make a request, email [email protected]. We may need to verify your identity before acting on it.

8. Age requirement

The Services are not intended for children. You must be at least 18 years old to use the Services. We do not knowingly collect personal information from anyone under 18, and we will delete it if we learn we have.

9. Third-party sites and services

The Services contain links to and content from third parties, including SnapTrade and your brokerage. Their own privacy policies govern their handling of your information, and we are not responsible for their practices.

10. Changes to this policy

We may update this policy from time to time. We will post the updated version with a new "Last updated" date and, for material changes, notify you through the Services or by email.

11. Contact us

TruthSayer AI Inc., Vancouver, British Columbia, Canada

• Privacy requests: [email protected]
• General questions and our Privacy Officer: [email protected]