Our Commitment to You

Portfolio Lab is a product of alphaAI Capital Management LLC (“alphaAI,” “we,” “our,” or “us”), an investment adviser registered with the Securities and Exchange Commission. This privacy policy describes how we collect, use, and protect your personal information when you use Portfolio Lab (“PL,” the “Service”).

We are committed to safeguarding your personal information. We do not sell your personal information to anyone. We protect the security and confidentiality of your data and make efforts to ensure it is used only for proper business purposes in connection with providing the Service.

If you also use alphaAI Capital’s Managed Portfolios service, the alphaAI Capital Privacy Policy governs the collection and use of your information in connection with that service. This policy covers only your use of Portfolio Lab.

Information We Collect About You

Account Information

When you create a Portfolio Lab account, we collect:

• Name
• Email address
• Password (stored in encrypted form)
• Authentication method (email/password, Google, or Apple)‍

Subscription and Billing Information

If you subscribe to a paid tier (Analyst or Quant), we collect:

• Billing name and address
• Payment method details (processed by Stripe; we do not store full card numbers)
• Subscription tier and billing period
• Transaction history‍

Strategy and Portfolio Data

When you use Portfolio Lab to build and manage strategies, we collect:

• Strategy type selections
• Asset selections (tickers)
• Build results, including optimization targets and performance metrics
• Paper Portfolio configurations and performance data
• Daily briefing engagement (opens, clicks)‍

Usage Data

We automatically collect information about how you interact with the Service:

• Pages visited, features used, and actions taken within the app
• Device and browser information (IP address, operating system, browser type)
• Session details (duration, referrer URLs, navigation paths)
• Performance data (page load times, errors encountered)‍

Information We Do NOT Collect

Portfolio Lab does not collect your Social Security number, date of birth, bank account information, brokerage credentials, or other sensitive financial information unless you separately enroll in alphaAI Capital’s Managed Portfolios service, which is governed by its own privacy policy and requires separate onboarding (including KYC verification).

How We Use Your Information

We use the information we collect for the following purposes:

• To provide, maintain, and improve the Service, including generating AI-optimized strategies, operating Paper Portfolios, and delivering daily briefings.
• To manage your account and process subscription payments.
• To communicate with you about the Service, including product updates, feature announcements, and support.
• To understand usage patterns and improve the user experience through analytics.
• To detect, prevent, and address technical issues, fraud, and security risks.
• To comply with legal and regulatory obligations.

Community Features and Anonymized Data

Portfolio Lab may use anonymized and aggregated data from your Builds and Paper Portfolios to power community features such as:

• Leaderboards showing top-performing Paper Portfolios (anonymized; no usernames or identifying information displayed)
• Trending assets (which tickers are most popular across all users)
• Popular Builds (which strategy type and asset combinations are most common)
• Personalized performance insights (e.g., “Your portfolio ranked in the top 15% this week”)‍

This data is anonymized before use in community features. Your username, email, and other identifying information are never displayed to other users. Community data is derived from aggregated patterns across all users and cannot be used to identify any individual.

We may also use anonymized and aggregated data for internal analysis, research, and to improve the Service. Anonymized data is not Personal Information.

Information We Share

We do not sell your personal information to anyone. We may share your information with the following parties for the purposes described below:

Service Providers

We share information with third-party service providers who assist us in operating the Service. These providers are contractually obligated to use your information only for the purposes of providing services to us and to maintain its confidentiality.

• Stripe, Inc. processes subscription payments. Stripe collects payment details (card number, billing address) directly and securely. We do not store your full payment details. For more information, see Stripe’s Privacy Policy.
• Alpaca Securities LLC provides paper trading services for Portfolio Lab’s Paper Portfolio feature. When you deploy a strategy to your Paper Portfolio, Alpaca executes simulated trades using real market data. Alpaca is a FINRA-registered broker-dealer. For more information, see Alpaca’s Privacy Policy.
• PostHog, Inc. provides product analytics. PostHog collects anonymized usage data (pages visited, features used, session details) to help us improve the Service. PostHog does not collect personally identifiable information such as names, email addresses, or financial details unless explicitly configured to do so. alphaAI does not use PostHog to collect sensitive personal information. For more information, see PostHog’s Privacy Policy.
• Email service provider (currently Mailchimp / SendGrid) delivers transactional and marketing emails on our behalf, including daily briefings, onboarding sequences, and product updates. Your email address and name are shared for this purpose.‍

Legal and Regulatory

We may disclose your information to comply with applicable law, respond to legal process (such as a subpoena or court order), protect our rights or the safety of others, investigate fraud, or respond to government requests.

Corporate Transactions

In the event of a merger, acquisition, reorganization, sale of assets, or similar corporate event, your information may be transferred as part of the transaction. We will notify you of any such change in ownership or control of your personal information.

With Your Consent

We may share your information for other purposes with your explicit consent.

Relationship to alphaAI Capital Managed Portfolios

Portfolio Lab includes a “Deploy with Real Money” feature that allows you to deploy strategies through alphaAI Capital’s Managed Portfolios service. If you choose to use this feature:

• You will be directed to the alphaAI Capital onboarding process, which requires separate account setup, KYC verification, and agreement to the alphaAI Capital Privacy Policy and advisory agreement.
• Additional personal information (including SSN, income, and bank account details) will be collected as part of that process and governed by the alphaAI Capital Privacy Policy.
• Your Portfolio Lab subscription and your Managed Portfolios account are separate. This privacy policy covers only your use of Portfolio Lab.‍

Data Security

We implement physical, procedural, and electronic safeguards to protect your personal information from unauthorized access, use, or disclosure. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication (including support for Google and Apple sign-in)
• Access controls limiting employee access to personal information
• Regular security reviews and monitoring‍

While we take reasonable precautions to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.

Cookies and Tracking Technologies

We use cookies, pixel tags, and similar technologies to operate the Service and understand usage patterns:

• Essential cookies are required for the Service to function (authentication, session management).
• Analytics cookies (via PostHog) help us understand how users interact with the Service. These collect anonymized data only.
• Marketing cookies may be used on the Portfolio Lab marketing site (portfoliolab.ai) to measure advertising effectiveness.‍

You may adjust your browser settings to block cookies, though this may impact the functionality of the Service.

Do Not Track

We do not collect personal information about your online activities over time and across different websites. Our Service does not respond to Do Not Track (“DNT”) signals.

Data Retention

We retain your information for as long as your account is active or as needed to provide the Service. We also retain information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

If you delete your account, we will delete or anonymize your personal information within a reasonable timeframe, except where retention is required by law. Anonymized and aggregated data (such as community Build metadata) may be retained indefinitely as it cannot be used to identify you.

Information About Former Users

alphaAI does not disclose, and does not intend to disclose, personal information to non-affiliated third parties with respect to persons who are no longer Portfolio Lab users, except as required by law.

Your Rights and Choices

• Access and update: You can access and update your account information through the Settings page in the app.
• Delete your account: You may request deletion of your account by contacting support@portfoliolab.ai. We will process your request within a reasonable timeframe.
• Email preferences: You may unsubscribe from marketing emails at any time using the unsubscribe link in any email. Transactional emails (e.g., payment confirmations, security alerts) cannot be unsubscribed from while your account is active.
• Cookie preferences: You may adjust your browser settings to block or delete cookies.
• Analytics opt-out: You may opt out of PostHog analytics tracking via your browser settings or privacy-focused browser extensions.‍

Children’s Privacy

Portfolio Lab is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

Changes to This Policy

We may update this privacy policy from time to time. If we make material changes, we will notify you by email or by posting a notice on the Service prior to the change becoming effective. Your continued use of the Service after the effective date of the revised policy constitutes your acceptance of the changes.

Contact Us

If you have questions about this privacy policy or our data practices, please contact us at:‍

Portfolio Lab by alphaAI Capital Management LLC

Email: support@portfoliolab.ai‍

You may also obtain a copy of this privacy policy at any time by visiting portfoliolab.ai/privacy or by contacting us at the email address above.

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