Privacy Policy

HiLo Platform Inc. — d/b/a HiLo Finance

This Privacy Policy reflects HiLo Finance's product architecture: in-house real-time chat (no third-party chat vendor), public stock/options discussion groups, stock and options symbol tagging in chat, Mentor-provided trade ideas with optional SnapTrade brokerage verification, market/options data and news from Massive, Twelve Data, Alpha Vantage, and Benzinga, and mobile (iOS/Android) and desktop (Windows/macOS) applications. Sections 4 and 5 describe Podcasts and Audiorooms, which are included in this Policy in advance of launch and are NOT YET ENABLED on the Platform; HiLo will provide notice before either feature becomes active.

Introduction

HiLo Platform Inc., a Delaware corporation, doing business as HiLo Finance ("HiLo," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile and desktop applications, available on iOS, Android, Windows, and macOS (collectively, the "App" or "Platform"). By using the Platform, you consent to the data practices described in this Policy.

California Residents: If you are a California resident, additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), apply. See Section 11 below.

1. Information We Collect

1.1 Information you provide

• Account information: phone number, username, first name, last name, email address
• Profile information: profile picture, bio, trading experience, investment preferences
• Payment information: for Web Payment subscriptions, billing address and payment method details (processed by Stripe; we do not store full card numbers); for In-App Payment subscriptions, a transaction/receipt identifier and subscription status provided by Apple or Google (we do not receive or store your payment method for these purchases)
• Communications: messages, posts, and comments you send in Direct Messages, Mentor channels, and Public Chats, including any stock or options ticker symbols you tag
• Media: photos and videos you upload to your profile or share in chats
• Support requests: information you provide when contacting customer support

1.2 Automatically collected information

• Device information: device type, operating system, unique device identifiers, mobile network information
• Usage data: features used, screens viewed, time spent, interactions with content and with Public Chats
• Log data: IP address, access times, crash reports, error logs (collected via Sentry)
• Approximate location based on IP address (not precise GPS location)

1.3 Information from third parties

• SnapTrade (Passiv Inc.) — Mentors only: brokerage trade execution data (symbol, instrument type, side, price, quantity, execution timestamp, order ID, account identifier), received via SnapTrade webhooks for trade verification. Brokerage login credentials are never shared with HiLo.
• Mixpanel and Sentry: aggregated usage and diagnostic statistics

1.4 Sensitive personal information

Some of what we collect is "sensitive personal information" under California law: the contents of your Direct Messages (which we store but are not the intended recipient of) and, for Mentors who connect a brokerage account, SnapTrade account tokens, brokerage authorization references, and trade execution data. We use sensitive personal information only to provide the Platform, verify Mentor trade alerts, keep the Platform secure, and comply with law. We do not use it to infer characteristics about you and do not sell or share it. Because we use it only for these purposes, California law does not require us to offer a separate "Limit the Use of My Sensitive Personal Information" option.

2. How We Use Your Information

2.1 Platform functionality

• Authenticate your identity via SMS one-time password (Twilio)
• Create and manage your account and profile
• Operate our in-house chat system, including Direct Messages, Mentor channels, and Public Chats
• Display quotes and market/options data via Massive, Twelve Data, and Alpha Vantage, and news via Alpha Vantage and Benzinga
• Process subscription payments via Stripe (Web Payment) or, on mobile, via Apple In-App Purchase / Google Play Billing (In-App Payment)
• For Mentors who opt in, verify trade alerts against brokerage execution data received from SnapTrade
• Send push notifications (trade alerts, chat mentions, messages)

2.2 Improvement, analytics, and security

• Analyze usage patterns (Mixpanel) and diagnose errors (Sentry) to improve the Platform
• Detect and prevent fraud, abuse, market manipulation, and security threats, including in Public Chats
• Enforce our Terms of Service and community moderation rules

2.3 Legal and regulatory

• Comply with legal obligations and respond to regulatory or law enforcement requests
• Maintain records as required by applicable securities recordkeeping rules

2.4 Automated and AI features

We use automated tools, including machine-learning models, to moderate content, detect fraud and market manipulation, tag symbols, and generate displays from Platform content and market data. We do not use your content to train AI models. Content processed by AI features (public chat messages for sentiment and symbol tags, market data, and questions you ask the HiLo AI Agent) is sent to xAI, Inc., which under our zero-data-retention configuration and its terms does not train on it and does not retain it after processing. Market briefing text is sent to ElevenLabs, Inc. for synthetic audio. The contents of Direct Messages are not processed by AI features. We do not provide your personal information to third parties for their own model training, and we do not make decisions with legal or similarly significant effects about you using solely automated means.

3. Public Chats and Community Content

The Platform includes Public Chats: stock- and market-focused discussion groups that any user may create or join. Public Chats are moderated by group admins and moderators, who set group-specific rules, approve or remove members, and remove content or members that violate those rules or our Terms of Service. Admins and moderators need not be HiLo staff or Mentors — any user granted moderator status for a given group may act in that role for that group only.

No expectation of privacy in Public Chats. Messages you post in a Public Chat, including any stock or options ticker symbols you tag, are visible to all current members of that group and may remain visible to future members and moderators. Do not post information in a Public Chat that you do not want seen by other members of that group.

Symbol tags are not verified. Tagging a stock or option symbol in a chat message is a user-generated annotation. HiLo does not verify, endorse, or curate tagged content, and a tag does not constitute a recommendation by HiLo.

Moderator and admin access. Group admins and moderators can see messages posted within groups they moderate for the purpose of enforcing group rules. Because moderators are ordinary users (not HiLo personnel), HiLo does not treat moderator access as HiLo employee access; HiLo may still retain moderation logs (removed messages, removed members, and the reason) for trust-and-safety and legal-compliance purposes even after removal from general view.

HiLo platform-level oversight. Independent of group-level moderation, HiLo may review, restrict, or remove any Public Chat content or group at its discretion, including for suspected market manipulation, coordinated inauthentic behavior, or legal/regulatory risk.

4. Podcasts (Reserved — Not Yet Enabled)

This Section describes HiLo's planned Podcasts feature, included here for advance legal review. Podcasts are NOT currently enabled on the Platform. HiLo will update this Policy's effective date and provide in-app notice before Podcasts becomes active.

What we will collect. If you publish a podcast, we will collect the audio files, show notes, artwork, titles, and descriptions you upload, and, if applicable, sponsor/advertiser information you disclose in your episodes. If you listen to podcasts, we will collect listening activity (episodes played, duration) associated with your account.

Hosting. Podcast audio and related files will be hosted using Cloudflare (Cloudflare, Inc.) infrastructure.

Advertising. HiLo may display advertisements on Podcasts listing/browse pages (not injected into episode playback) and may share a portion of related ad revenue with podcasters, subject to a separate Podcaster Agreement.

Sponsor content. Podcasters may include sponsored segments within their own episodes; HiLo requires disclosure of paid/sponsored content under the Podcaster Agreement, but does not independently verify every sponsor claim.

5. Audiorooms (Reserved — Not Yet Enabled)

This Section describes HiLo's planned Audiorooms feature (live audio discussions), included here for advance legal review. Audiorooms are NOT currently enabled on the Platform. HiLo will update this Policy's effective date and provide in-app notice before Audiorooms becomes active.

What we will collect. If you host or speak in an Audiorooms session, we will collect your live audio, which may be recorded and retained for content-moderation, trust-and-safety, and legal/regulatory compliance purposes, even though the room itself is live and time-bound. By hosting, speaking in, or joining a session you consent to being recorded.

Visibility. Audio in an Audiorooms session is audible to all room participants in real time; recordings, if made, will be accessible to HiLo's Trust & Safety team and may be produced in response to legal process.

Moderation. Room hosts and HiLo may remove participants or end a session for violations of the Terms of Service, including suspected market manipulation or unlicensed investment advice conducted live.

6. Data Sharing and Disclosure

We do not sell your personal information to third parties. We share data with the service providers below, each of which is contractually required to protect your data and use it only for the specified purpose. Each is a "service provider" or "contractor" under California law and may not use your information for its own purposes.

6.1 Legal requirements. We may disclose your information if required by law, regulation, or legal process, including subpoenas, court orders, government requests, and SEC, FINRA, CFTC, or state securities regulator inquiries.

6.2 Business transfers. If HiLo is involved in a merger, acquisition, or asset sale, your information may be transferred to the acquiring entity, and you will be notified via email or in-app notice.

6.3 Other users and Mentors. Your username, profile information, and the content you post are visible to other users as described in Section 3. A Mentor you subscribe to can see your username and the messages you send in that Mentor's channel or in Direct Messages with the Mentor. Mentors are independent and may use that information only to provide their content on the Platform; they are not permitted to export it or contact you off-Platform. If you are a Mentor and opt in, your connected brokerage holdings, portfolio value, and returns are displayed on your profile to users who view it, and your Transparency Score (based on verification rate, posting consistency, and activity) is displayed publicly.

7. Data Security

• Encryption: data in transit encrypted via TLS/SSL; data at rest encrypted in MongoDB Atlas, on Cloudflare R2 (uploaded media), and on AWS infrastructure (ElastiCache)
• Authentication: phone-based OTP login, secure token-based API access
• Access controls: role-based access restrictions; limited employee access to personal data and to Public Chat moderation tools
• Monitoring: automated security monitoring via Sentry and internal tooling

No system is 100% secure. Despite our efforts, no data transmission or storage system is completely secure, and you acknowledge this inherent risk by using the Platform.

8. Data Retention

• Active accounts: data retained for the duration of your account plus 30 days
• Closed accounts: most data deleted within 30 days of account closure, except as described below
• Public Chat content: messages you post in Public Chats may persist in the group for other members to view even after you leave the group or delete your account, though your personal identifiers will be disassociated where feasible
• Chat messages and trade alerts: retained for up to three years after they are sent, including messages you delete, for fraud and manipulation detection, dispute resolution, and legal compliance, and then deleted
• Legal/compliance retention: SnapTrade-derived Mentor trade-verification records and related audit logs may be retained longer to comply with applicable securities recordkeeping rules
• Backups: deleted according to standard backup rotation schedules (up to 90 days)

9. Your Privacy Rights

9.1 Access, right to know, and correction. You may access and update most of your profile information within the App. You may also request a copy of the personal information we hold about you, including the categories and specific pieces, the sources, the purposes, and the categories of third parties we disclosed it to, and request correction of inaccurate information, by emailing [email protected]. We will verify your identity, usually by confirming control of the phone number or email on your account, and respond within 45 days (extendable once by 45 days with notice).

9.2 Data deletion. You may delete specific content or your entire account and associated personal data at any time via in-app account-deletion tools, or by emailing [email protected]. We will complete deletion within 30 days, except where retention is required by law or is necessary to preserve the integrity of a Public Chat for other members (see Section 8).

9.3 Marketing opt-out. Unsubscribe via any marketing email, in-app settings, or by emailing [email protected].

9.4 Push notification opt-out. Disable push notifications in device settings or in the App.

9.5 Sale, sharing, and targeted advertising. We do not sell your personal information, share it for cross-context behavioral advertising, or use it for targeted advertising. If we begin displaying third-party advertising (see Section 4), we will add a "Do Not Sell or Share My Personal Information" option and honor Global Privacy Control browser signals before any such sharing starts.

9.6 Appeals. If we deny a privacy request, you may appeal by replying to our decision. We will respond within 45 days and, if we still deny the request, tell you how to contact your state attorney general.

10. Children's Privacy

The Platform is not intended for users under 18. We do not knowingly collect personal information from children. If you believe a child under 18 has provided us with personal information, contact [email protected] and we will delete the account.

11. California Consumer Privacy Act (CCPA/CPRA) Rights

If you are a California resident, you have the right to: (a) know the categories and specific pieces of personal information we have collected about you; (b) delete personal information we have collected from you, subject to certain exceptions; (c) correct inaccurate personal information; and (d) non-discrimination for exercising your rights. We do not sell personal information, and do not currently share personal information for cross-context behavioral advertising as defined by the CPRA; if that changes, this Policy will be updated with an opt-out mechanism before any such sharing begins.

In the last 12 months we have collected these categories of personal information: identifiers (name, username, phone number, email, device identifiers, IP address); commercial information (subscription and payment history); internet or network activity (usage and log data); approximate geolocation derived from IP address; audio (Audiorooms recordings, once enabled); the content you post and send; professional information you choose to provide (trading experience); financial information (Mentors only: SnapTrade trade execution data); and the sensitive personal information described in Section 1.4. We collect it from you, from your device, and (for Mentors) from SnapTrade. We use it for the purposes in Section 2, disclose it for business purposes to the service providers in Section 6, and retain it for the periods in Section 8. We do not use or disclose sensitive personal information for purposes beyond those permitted by California law.

To exercise your rights to know, delete, or correct, email [email protected] or use the in-app account-deletion tool for deletion requests. We will verify your identity and respond within the time required by law. You may designate an authorized agent to submit a request on your behalf by providing written authorization.

11.1 Other U.S. state privacy rights. If you live in Virginia, Colorado, Connecticut, Texas, Oregon, or another state with a consumer privacy law, you have similar rights to access, correct, delete, and obtain a copy of your personal information and to opt out of targeted advertising, sales, and profiling for significant decisions (none of which we currently do). Use the contact methods in Section 9. You may appeal a denial as described in Section 9.6.

12. International Users

The Platform is operated from the United States. If you access the Platform from outside the U.S., your information will be transferred to, stored, and processed in the U.S., which may not have data protection laws as comprehensive as your home country.

13. Third-Party Links

The Platform may contain links to third-party websites or services (including brokerage platforms accessed via SnapTrade, or Massive/Twelve Data/Alpha Vantage/Benzinga content). We are not responsible for the privacy practices of third parties, and encourage you to review their privacy policies.

14. Changes to This Privacy Policy

We may update this Policy from time to time. Minor changes are effective immediately upon posting; material changes are effective 30 days after notice via email or in-app notification. Continued use of the Platform after changes take effect constitutes acceptance. We review this Policy at least once every 12 months and update the "Last updated" date above when we change it.

15. Contact Us

HiLo Platform Inc. (d/b/a HiLo Finance) — San Jose, CA 95118 — United States

Privacy inquiries: [email protected] | General support: [email protected]