Privacy Policy for Asset Wisp

Effective Date: 01/01/2025

Last Updated: 07/01/2025

1. Introduction

Axion Expert Services INC. ("we," "our," or "us") built the Asset Wisp mobile application (the "App") as a commercial service. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App and related services (collectively, the "Service").

By using Asset Wisp, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

2. Information We Collect

2.1 Personal Information

We may collect personally identifiable information that you voluntarily provide to us when you:

• Create an account (email, Google, Facebook, Apple ID)
• Use our services
• Contact us for support
• Subscribe to our services
• Set up multi-factor authentication

This information may include:

• Name and email address
• Phone number (for MFA and notifications)
• Profile information and investment preferences
• Financial portfolio data (manually entered)
• Investment goals and risk tolerance
• Account credentials for third-party integrations (encrypted and tokenized)
• Payment information for subscription services
• Biometric data (if you enable device authentication features)

2.2 Financial and Investment Data

When you use Asset Wisp, we may collect and process:

• Portfolio holdings, transactions, and performance data
• Watchlist preferences and custom alerts
• Investment preferences, goals, and risk tolerance settings
• Trading signals and alert preferences
• Brokerage account information (when you choose to connect accounts via secure APIs like Plaid)
• Real estate investment data including ZIP code analysis requests
• Subscription tier and payment information
• AI prediction preferences and success rate tracking
• Custom screener settings and filter preferences

2.3 Social Media and News Data

For sentiment analysis and market intelligence, we collect publicly available information from:

• Social media platforms (Reddit, Twitter/X, and other financial forums)
• Financial news sources (Bloomberg, Reuters, Google News)
• Public financial discussions and sentiment data
• Market-related social media posts and trends

This data is aggregated and anonymized for sentiment analysis purposes and is not linked to your personal identity.

2.4 Usage and Analytics Data

We automatically collect certain information when you use our App:

• Device information (device type, operating system, unique device identifiers)
• App usage statistics and feature interactions
• Log data (IP addresses, access times, pages viewed)
• Crash reports and performance data
• Search queries within the App
• Notification interaction data

2.5 Location and Real Estate Data

We may collect location data to:

• Provide relevant real estate market information and analysis using 200+ data metrics
• Generate real estate investment scores and appreciation predictions
• Deliver location-specific rental yield calculations
• Provide trending area analysis and investment indicators
• Comply with financial regulations based on your jurisdiction
• Customize content based on your region

You can disable location sharing through your device settings, though this may limit real estate analysis features.

3. How We Use Your Information

3.1 Service Provision and AI Processing

We use your information to:

• Provide financial insights and AI-powered predictions
• Generate technical and fundamental analysis scores with explanations
• Display real-time market data for your tracked assets
• Create portfolio analysis, risk assessments, and investment recommendations
• Deliver relevant financial news with sentiment analysis scores
• Send customized price alerts, trend change notifications, and trading signals
• Process real estate investment analysis using our proprietary algorithms
• Provide AI success rate tracking and confidence scoring
• Generate automated investment research reports and explanations

3.2 Automated Decision Making

Our AI systems process your data to provide:

• Buy/sell/hold recommendations with confidence ratings
• Risk factor assessments and portfolio optimization suggestions
• Trend change predictions and swing trade setup alerts
• Real estate appreciation forecasts and investment scoring
• Automated alert triggers based on your predefined criteria

You have the right to opt out of automated decision-making.

3.3 Personalization and Improvement

We use your data to:

• Customize your dashboard and user experience
• Improve our AI algorithms and prediction models
• Analyze usage patterns to enhance App functionality
• Provide customer support and technical assistance
• Conduct research and analytics to improve our services

3.4 Communication

We may use your contact information to:

• Send important service updates and security notices
• Provide customer support responses
• Share relevant financial insights (if you opt-in)
• Send marketing communications (with your consent)

4. Information Sharing and Disclosure

4.1 Third-Party Service Providers

We share information with trusted third-party providers who assist us in:

• Cloud hosting and data storage (AWS, Google Cloud)
• Analytics and crash reporting (Firebase Analytics, Crashlytics)
• Financial data aggregation (Plaid, Alpha Vantage, Yahoo Finance)
• Push notification services
• Customer support tools

These providers are contractually obligated to protect your information and use it only for the specified purposes.

4.2 Financial Data Sources and Providers

We integrate with legitimate financial data providers and may share aggregated, non-personal data with:

• Market Data Providers: Polygon.io, Yahoo Finance, Alpha Vantage, Bloomberg API (for real-time pricing)
• Cryptocurrency Data: Polygon.io, CoinGecko, CoinMarketCap (for crypto market data)
• Real Estate Data: Zillow, Realtor.com APIs (for property and market analysis)
• Economic Data: Federal Reserve Economic Data (FRED), government statistical agencies
• News Providers: Reuters, Associated Press, financial news aggregators

These integrations involve only the minimum data necessary to provide services and are governed by strict data sharing agreements.

4.3 Analytics and Performance Partners

We work with analytics providers to improve our services:

• Firebase Analytics: App usage and performance metrics
• Crashlytics: Error reporting and app stability monitoring
• Custom Analytics: Internal systems for AI model improvement (anonymized data only)

4.4 Payment Processors

For subscription services, we share necessary information with:

• Payment processors (Stripe, Apple App Store, Google Play Store)
• Fraud prevention services
• Subscription management platforms

Payment information is processed securely and we do not store complete payment card details.

4.5 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes, court orders, or government requests
• Protect our rights, property, or safety and that of our users
• Prevent fraud, security threats, or illegal activities
• Enforce our Terms of Service and other agreements
• Respond to claims that content violates third-party rights

4.6 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

5. Data Security

We implement comprehensive security measures appropriate for financial applications:

5.1 Technical Safeguards

• End-to-End Encryption: All data transmission uses TLS 1.3 encryption
• Advanced Encryption at Rest: AES-256 encryption for stored data
• Tokenization: Sensitive financial credentials are tokenized, not stored directly
• Multi-Factor Authentication: Available for all user accounts
• API Security: OAuth 2.0 and secure API tokens for third-party integrations
• Regular Penetration Testing: Quarterly security assessments by certified professionals

5.2 Operational Security

• Access Controls: Strict role-based access with principle of least privilege
• Employee Training: Regular security awareness training for all staff
• Incident Response Plan: 24/7 monitoring with automated threat detection
• Data Backup: Encrypted, geographically distributed backup systems
• Audit Logging: Comprehensive logging of all data access and modifications

5.3 Compliance and Monitoring

• SOC 2 Type II Compliance: Annual compliance audits
• Real-time Monitoring: Continuous monitoring for suspicious activities
• Fraud Detection: AI-powered anomaly detection systems
• Regular Updates: Automated security patches and updates

5.4 Data Breach Response

In the unlikely event of a data breach, we will:

• Notify affected users within 72 hours
• Provide clear information about what data was involved
• Offer identity monitoring services if applicable
• Work with law enforcement and regulators as required
• Implement additional safeguards to prevent future incidents

However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

6. Data Retention

We retain different types of information for varying periods based on legal requirements and business needs:

6.1 Account and Personal Data

• Active Accounts: Retained while your account is active
• Inactive Accounts: Deleted after 3 years of inactivity (unless legally required to retain)
• Account Deletion: Personal data deleted within 30 days of the account deletion request

6.2 Financial and Transaction Data

• Portfolio Data: Retained for 7 years after account closure (regulatory requirement)
• Transaction History: Maintained for 7 years for audit and compliance purposes
• Tax-Related Information: Retained as required by applicable tax laws

6.3 Usage and Analytics Data

• App Usage Data: Aggregated and anonymized after 2 years
• Log Files: Retained for 90 days for security and troubleshooting
• Crash Reports: Anonymized and retained for 1 year for improvement purposes

6.4 Marketing and Communication Data

• Email Communications: Retained until you unsubscribe or for 2 years if inactive
• Support Tickets: Retained for 3 years for quality assurance
• Marketing Preferences: Retained while the account is active

We may retain information longer where required by law, regulation, or to protect our legal rights.

7. Your Rights and Choices

7.1 Account Management

You can:

• Access and update your personal information through App settings
• View and modify your portfolio data and investment preferences
• Delete your account and request data deletion
• Export your portfolio data in standard formats (CSV, PDF)
• Modify notification preferences and alert settings
• Disconnect linked brokerage accounts at any time
• Change your subscription tier or cancel subscriptions

7.2 Privacy Rights

You have the right to:

• Access: Request a comprehensive copy of your personal information
• Correction: Update inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Portability: Receive your data in a machine-readable format
• Objection: Object to certain processing activities, including automated decision making
• Restriction: Limit how we process your data in certain circumstances
• Withdrawal of Consent: Withdraw consent for processing where we rely on consent as the legal basis

7.3 How to Exercise Your Rights

To exercise your privacy rights:

• In-App: Use the privacy settings in your account dashboard
• Email: Send requests to legal@assetwisp.com with subject "Privacy Rights Request"
• Include: Your full name, registered email, and specific request details
• Verification: We may request additional information to verify your identity
• Response Time: We will respond within 30 days (or as required by law)

7.4 Communication and Marketing Preferences

You can opt-out of:

• Marketing communications (via unsubscribe links or app settings)
• Non-essential push notifications (through App settings)
• Promotional emails and newsletters
• SMS notifications (where applicable)
• Analytics data collection (through device settings)

Note: You cannot opt-out of essential service communications related to your account, security, or legal requirements.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. When we transfer data internationally, we ensure appropriate safeguards are in place through:

• Adequacy decisions
• Standard contractual clauses
• Other legally recognized transfer mechanisms

9. Children's Privacy

Asset Wisp is not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will take steps to delete such information immediately.

10. AI and Machine Learning Data Processing

10.1 How We Use AI

Asset Wisp employs artificial intelligence and machine learning technologies to:

• Generate investment predictions and success rate calculations
• Perform technical and fundamental analysis of financial instruments
• Provide buy/sell/hold predictions with confidence ratings
• Analyze market sentiment from news and social media data
• Create personalized portfolio optimization suggestions
• Detect market trends and generate trading signals
• Process real estate investment data and appreciation forecasts

10.2 Data Used for AI Training

Our AI models are trained using:

• Historical Market Data: Publicly available financial data and price histories
• Aggregated User Patterns: Anonymized usage patterns and preferences
• News and Sentiment Data: Publicly available financial news and social media sentiment
• Economic Indicators: Public economic and financial data
• Performance Metrics: Success rates of predictions and recommendations (anonymized)

We do not use your personal financial information or individual portfolio data to train our general AI models.

10.3 AI Decision Transparency

You have the right to:

• Understand how AI recommendations are generated for your specific situation
• Request explanations for AI-generated investment suggestions
• Opt-out of automated decision making and request human review
• Access information about the data sources used in your AI recommendations
• Contest AI-generated decisions that significantly affect you

10.4 AI Model Improvement

We continuously improve our AI models using:

• Aggregated, anonymized performance data
• Public market data and economic indicators
• User feedback on prediction accuracy (optional participation)
• A/B testing of different model approaches (with user consent)

11. Third-Party Links and Services

Our App may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

11. Financial Regulatory Compliance

11.1 Investment Advisory Regulations

Asset Wisp provides educational content and general market analysis. Our AI-powered insights and predictions are for informational purposes only and do not constitute professional financial advice. We comply with applicable financial regulations including:

• Securities and Exchange Commission (SEC) guidelines
• Financial Industry Regulatory Authority (FINRA) rules
• Commodity Futures Trading Commission (CFTC) regulations (for commodities data)
• Anti-Money Laundering (AML) requirements where applicable

11.2 Data Handling for Financial Services

We maintain data practices that comply with financial industry standards:

• Record Keeping: Maintaining required records per financial regulations
• Audit Trails: Comprehensive logging for regulatory examinations
• Client Identification: Verification procedures as required by law
• Reporting: Compliance with applicable reporting requirements

11.3 International Financial Regulations

For users in different jurisdictions, we comply with local financial regulations including:

• European Union: Markets in Financial Instruments Directive (MiFID II)
• United Kingdom: Financial Conduct Authority (FCA) guidelines
• Canada: Investment Industry Regulatory Organization of Canada (IIROC)
• Australia: Australian Securities and Investments Commission (ASIC)

12. Regional Privacy Rights

12.1 European Users (GDPR)

If you are located in the European Economic Area, you have additional rights under the General Data Protection Regulation, including the right to lodge a complaint with your local supervisory authority.

12.2 California Users (CCPA)

California residents have the right to know what personal information is collected, sold, or disclosed, and the right to request deletion of personal information. We do not sell personal information to third parties.

13. Cookies and Similar Technologies

Asset Wisp may use cookies and similar tracking technologies to:

• Remember your preferences and login state
• Analyze App usage and performance
• Provide targeted content and recommendations
• Enable security features and fraud detection
• Facilitate social media integrations

You can control cookie preferences through your device settings, though this may affect App functionality. We use both session cookies (deleted when you close the app) and persistent cookies (remain until deleted or expired).

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will notify you of significant changes through:

• In-app notifications with prominent display
• Email notifications (to your registered email address)
• Updates posted in the App with effective date changes
• Push notifications for material changes affecting your rights

Your continued use of Asset Wisp after the effective date of modifications constitutes acceptance of the updated Privacy Policy. If you disagree with changes, you may delete your account before the effective date.

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: legal@assetwisp.com
• General Support: support@assetwisp.com

For data protection inquiries specific to your region, please specify your location when contacting us. We will respond to privacy-related requests within 30 days (or as required by applicable law).

16. Compliance and Certifications

Asset Wisp is designed to comply with:

• iOS App Store Review Guidelines and Privacy Requirements
• Google Play Developer Policy and Privacy Requirements
• General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Financial Industry Regulatory Authority (FINRA) guidelines
• Securities and Exchange Commission (SEC) regulations
• Payment Card Industry Data Security Standard (PCI DSS) for payment processing
• SOC 2 Type II security and availability standards
• ISO 27001 information security management standards
• Other applicable privacy, financial, and consumer protection regulations

We undergo regular compliance audits and maintain certifications relevant to financial technology services.