PROPHIT PRIVACY POLICY

Last updated: July 28, 2026

Prophit Inc. ("Prophit," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard personal information when you use the Prophit mobile application (the "App"), visit our websites (including prophit.inc and related pages), create an account, interact with our customer support channels, or otherwise use our related services (collectively, the "Services"). This Privacy Policy is intended to give you a clear and specific understanding of our practices. Where prior versions of our privacy disclosures were shorter or less detailed, this Policy expands those disclosures so that they align with how the Services actually operate.

By accessing or using the Services, you acknowledge that you have read this Privacy Policy. If you do not agree with our practices, do not use the Services. Capitalized terms used but not defined in this Privacy Policy have the meanings given in our Terms of Service. For questions, contact us at support@prophit.investments.

1. WHO WE ARE

Prophit Inc. is a Delaware corporation with its principal mailing address at 131 Continental Dr, Suite 305, Newark, DE 19713. Prophit operates a software and technology platform that provides investment education, market news and analysis, search and discovery tools, an AI-powered educational assistant, social and engagement features, and, where you choose to use it, an integration with a third-party brokerage that allows you to place real, self-directed orders in your own brokerage account. Leaderboards, points, rankings, and badges within the App are simulated or points-based and do not reflect real trading results.

Prophit Inc. is not a registered investment advisor, broker-dealer, bank, custodian, clearing firm, or member of FINRA, SIPC, or any similar self-regulatory organization. Prophit does not hold, custody, receive, execute, clear, or settle funds or securities. To the extent the App facilitates a connection to a third-party brokerage account, brokerage services are provided by independent financial institutions under their own terms and privacy policies, as described in Section 5 and Section 7.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information we collect through:

  • The Prophit mobile application for iOS and Android;
  • Our websites and landing pages, including pages used for early access, downloads, and marketing;
  • Account registration, authentication, and profile management;
  • Customer support, feedback, and related communications;
  • Push notifications and in-app messaging that we send;
  • Analytics, advertising measurement, and diagnostic tooling described in this Policy; and
  • Integrations you choose to enable, including brokerage account connection and subscription purchases.

This Privacy Policy does not govern the privacy practices of third parties that operate independently of Prophit, including Open to the Public Investing, Inc. ("Public Investing"), Apex Clearing Corporation, Apple, Google, Meta Platforms, Inc., our authentication provider, our product analytics provider, our subscription management provider, our market data providers, or our AI model providers. Those parties' practices are governed by their own policies. When you open or fund a brokerage account, or when you complete identity verification for that account, you are also subject to the brokerage's privacy policy and customer agreements.

3. INFORMATION WE COLLECT

We collect personal information in three primary ways: (a) information you provide directly; (b) information collected automatically when you use the Services; and (c) information we receive from third parties. The categories below describe the types of information we actually collect in connection with the Services. Not every category applies to every user. The information collected depends on how you use the App, which permissions you grant, whether you subscribe, whether you connect a brokerage account, and which features you use.

3.1 Account and Identity Information You Provide

When you create or maintain an account, we may collect:

  • Email address;
  • Username;
  • First name and last name;
  • Optional profile picture (selected from your photo library or otherwise uploaded);
  • Your account identifier associated with your authentication account;
  • Account creation date and related account metadata;
  • Public-profile visibility preference (whether aspects of your profile are visible to other users);
  • A subscription application user identifier used for entitlement management; and
  • Brokerage-linked status indicating whether your Prophit account has been connected to a third-party brokerage account.

Authentication credentials (such as passwords or social sign-in tokens) are handled through our authentication provider, which stores those credentials and related legal-acceptance metadata necessary to operate your account. Prophit receives and stores account identifiers and profile fields needed to operate the Services.

3.2 Authentication and Login Telemetry

We collect authentication-related telemetry, including login timestamps and related account-access events, to secure accounts, detect suspicious activity, support customer service, and maintain auditability of account access.

3.3 Investing, Portfolio, and Trading-Related Information

Depending on the features you use, we may collect:

  • Portfolio names and portfolio settings;
  • Holdings and related portfolio composition data;
  • Liked and disliked symbols;
  • Watchlists;
  • Leaderboard, points, and ranking activity, which is simulated or points-based and does not reflect actual trading results;
  • Order records, which may include symbol, side (buy or sell), order type, quantity, notional amount, status, and fill price; and
  • Order failure records, including diagnostic details needed to understand why an order attempt failed.

Order records and related trading information may relate to brokerage-connected activity that is initiated through the App but executed, cleared, and custodied by third-party brokerage and clearing firms. Prophit does not custody user funds or securities.

3.4 Preferences, Discovery, and Search History

We may collect:

  • Industry and topic preferences that you set or that are inferred from in-app activity;
  • Discovery and swipe-related interaction signals used to personalize educational feeds; and
  • Search history, including query text and timestamps.

Search queries may include free-text descriptions of companies, concepts, industries, or other topics you choose to explore. Voice search, if you enable microphone and speech-recognition permissions, converts spoken queries to text so we can process the resulting search query.

3.5 Artificial Intelligence Assistant Information

If you use the AI assistant (sometimes referred to in product surfaces as "Pete" or similar branding), we may collect:

  • Conversation threads;
  • Individual messages you send and responses returned;
  • Symbols or companies discussed in a conversation; and
  • Feedback you provide on AI responses (for example, ratings or free-text comments).

User prompts and relevant context needed to generate a response are transmitted to one or more of our AI model providers as described in Section 5. You should not submit information in AI chats that you do not want processed for that purpose.

3.6 Social, Groups, Referrals, and Sharing

If you use social or sharing features, we may collect:

  • Group names and group memberships;
  • Referral relationships linking referring and referred users;
  • Shared portfolios and related share metadata; and
  • Content you choose to share within the App or export for sharing outside the App (for example, referral images saved to your media library).

3.7 Subscription and Entitlement Information

If you purchase or redeem a subscription or related entitlement, we may collect:

  • Entitlement status;
  • Expiry dates;
  • Trial and reward state;
  • Webhook event payloads from our subscription management provider related to purchases, renewals, cancellations, billing issues, and restorations;
  • Credit windows; and
  • Unlock records associated with paid or rewarded features.

Payment card details for App Store purchases are processed by Apple. Prophit does not receive your full payment card number from Apple for standard in-app purchases. Our subscription management provider helps us determine what features you are entitled to use and may forward certain purchase events for advertising measurement as described in Section 5.

3.8 Engagement, Notifications, and Rewards

We may collect:

  • Streaks and daily check-in activity;
  • Achievements and reward grants;
  • Push notification device tokens and platform (for example, iOS or Android);
  • Notification preferences; and
  • A log of notifications sent, which may include title and body text, delivery metadata, and related timestamps.

3.9 Support and Feedback

When you contact us or submit in-app feedback, we collect the content of your message, the contact information you provide, and any attachments or diagnostic details you choose to include. This may include information about bugs, feature requests, account issues, or brokerage-connection problems.

3.10 Brokerage Connection and Identity-Verification Information

If you choose to connect or open a brokerage account through the App, we may collect and process:

  • Encrypted OAuth access and refresh tokens used to maintain the brokerage connection;
  • Brokerage user and account identifiers; and
  • Account status information returned by the brokerage integration.

Onboarding information required for identity verification — including legal name, date of birth, residential address, and government identification numbers such as a Social Security number — may be collected in the App solely to transmit to the brokerage for its KYC/AML and account-approval process. That identity-verification information is collected for brokerage onboarding, not for Prophit's independent marketing, analytics, or product-personalization purposes.

PROPHIT TRANSMITS IDENTITY-VERIFICATION INFORMATION COLLECTED FOR BROKERAGE ONBOARDING TO THE BROKERAGE (AND, AS APPLICABLE, ITS CLEARING FIRM OR IDENTITY-VERIFICATION VENDORS) FOR KYC/AML AND ACCOUNT-APPROVAL PURPOSES. PROPHIT DOES NOT USE THAT IDENTITY-VERIFICATION INFORMATION FOR ANY OTHER PURPOSE. TO THE EXTENT TECHNICALLY FEASIBLE, PROPHIT TREATS SUCH INFORMATION AS PASS-THROUGH DATA FOR THE BROKERAGE RELATIONSHIP AND DOES NOT RETAIN GOVERNMENT IDENTIFICATION NUMBERS FOR PROPHIT'S OWN ONGOING PRODUCT USE. ANY LIMITED TRANSIENT PROCESSING OR LOGGING THAT MAY OCCUR AS PART OF TRANSMISSION, SECURITY, FRAUD PREVENTION, OR TROUBLESHOOTING IS RESTRICTED TO THOSE OPERATIONAL PURPOSES AND IS NOT USED TO BUILD MARKETING PROFILES.

Brokerage services are provided by Open to the Public Investing, Inc. ("Public Investing"), a registered broker-dealer and member of FINRA and SIPC, with clearing and execution by Apex Clearing Corporation. Public Holdings, Inc. is the parent company of Public Investing and is not itself the broker-dealer. Your brokerage relationship, including custody of assets, trade execution, tax reporting, and regulatory identity verification, is governed by Public Investing's and Apex Clearing's agreements and privacy policies.

3.11 Device, Technical, and Diagnostic Information Collected Automatically

When you use the Services, we and our service providers automatically collect:

  • Device type and operating system;
  • Device model;
  • App version and build number;
  • Unique device identifiers, including Identifier for Vendor (IDFV) and, if you grant App Tracking Transparency permission on iOS, the advertising identifier (IDFA);
  • IP address;
  • Locale, timezone, and environment indicators (for example, production versus development builds);
  • Crash reports; and
  • Diagnostic and performance data used to maintain reliability and investigate defects.

3.12 Approximate Location Derived from IP Address and Device Settings

We derive approximate location information such as city, region, country, and timezone from IP address and device settings. We use this information to provide relevant market hours, localize content, support fraud and abuse prevention, and understand aggregate geographic usage.

PROPHIT DOES NOT REQUEST OR COLLECT GPS OR PRECISE LOCATION. THE APP DOES NOT INCLUDE A LOCATION PERMISSION IN ITS MANIFEST, AND WE DO NOT USE THE DEVICE'S GPS TO TRACK YOUR MOVEMENTS.

3.13 Biometric Information — Not Collected by Prophit

You may choose to enable Face ID, Touch ID, fingerprint unlock, or other on-device biometric authentication features provided by your device's operating system. Prophit does not collect biometric identifiers or biometric information.

PROPHIT INC. DOES NOT COLLECT, STORE, TRANSMIT, RETAIN, SELL, LEASE, TRADE, PROFIT FROM, OR OTHERWISE HAVE ACCESS TO YOUR BIOMETRIC IDENTIFIERS, BIOMETRIC INFORMATION, BIOMETRIC TEMPLATES, FINGERPRINTS, FACIAL GEOMETRY, VOICEPRINTS, RETINA OR IRIS SCANS, OR ANY OTHER BIOMETRIC DATA, WHETHER OR NOT ENCRYPTED. ALL BIOMETRIC CAPTURE, PROCESSING, MATCHING, AND STORAGE OCCURS ENTIRELY ON YOUR DEVICE WITHIN THE OPERATING SYSTEM'S SECURE HARDWARE ENCLAVE, UNDER THE CONTROL OF THE OPERATING SYSTEM PROVIDER. THE APP RECEIVES ONLY A BINARY SUCCESS-OR-FAILURE SIGNAL INDICATING WHETHER AUTHENTICATION SUCCEEDED. NOTHING IN THIS PRIVACY POLICY SHALL BE CONSTRUED AS PROPHIT INC. COLLECTING, CAPTURING, POSSESSING, RECEIVING THROUGH TRADE, OR OTHERWISE OBTAINING BIOMETRIC IDENTIFIERS OR BIOMETRIC INFORMATION WITHIN THE MEANING OF THE ILLINOIS BIOMETRIC INFORMATION PRIVACY ACT (740 ILCS 14), THE TEXAS CAPTURE OR USE OF BIOMETRIC IDENTIFIER ACT, THE WASHINGTON BIOMETRIC PRIVACY ACT, OR ANY SIMILAR LAW. PROPHIT HAS NO BIOMETRIC RETENTION OR DESTRUCTION SCHEDULE BECAUSE IT HOLDS NO BIOMETRIC DATA.

3.14 Website Visitor Information

When you visit our websites or marketing pages, we may collect:

  • Pages visited;
  • Referring URL;
  • Browser and device type;
  • IP address; and
  • Any information you submit through an early-access form or similar web form, such as email address and any optional fields you complete.

Website analytics and form submissions help us understand demand, operate waitlists or early-access programs, and improve our web properties. Website practices may evolve as our web surfaces expand; material changes will be reflected in updates to this Policy.

3.15 Information We Receive from Third Parties

We may receive personal information from:

  • Our authentication provider, regarding authentication status, account identifiers, and related identity metadata;
  • Apple and our subscription management provider, regarding subscription purchases, restorations, cancellations, and entitlement state;
  • Meta Platforms, Inc., regarding advertising campaign performance and attribution signals related to Prophit's own ads;
  • Public Investing and related brokerage infrastructure, regarding connection status, account identifiers, and limited account-status information necessary to operate the integration;
  • Our market data providers, regarding publicly available company, pricing, fundamentals, and news data (generally not personal information about you, except insofar as your requests are associated with your account);
  • Our AI model providers, regarding service delivery, safety, and operational responses to prompts you submit; and
  • Other users, when they refer you, add you to a group, or share content that identifies you.

3.16 Categories of Personal Information (Summary)

For ease of reading, the information described above falls into categories such as:

  • Identifiers (for example, name, email, username, account identifier, device identifiers, IP address);
  • Customer records and profile information (for example, profile picture, visibility settings);
  • Commercial information (for example, subscription status, purchase events, entitlement history);
  • Internet or other electronic network activity (for example, app events, screen views, search history, notification logs);
  • Approximate geolocation (city/region/country/timezone derived from IP and settings, not GPS);
  • Audio information only transiently if you use voice search (microphone audio used to generate a text query; Prophit does not operate a separate voiceprint identification system);
  • Inferences drawn from the foregoing (for example, preference or engagement signals); and
  • Sensitive personal information only in limited contexts, such as government identification numbers collected solely for transmission to the brokerage for KYC/AML, or account login credentials handled through our authentication provider.

4. HOW WE USE YOUR INFORMATION

We use personal information for the following purposes. Each purpose below is mapped to the categories of information commonly used for that purpose.

4.1 Provide and Operate the Services

We use account, portfolio, preference, search, AI, social, subscription, engagement, brokerage-connection, and device information to:

  • Create and maintain your account;
  • Authenticate you and protect account access;
  • Display portfolios, holdings, watchlists, and educational feeds;
  • Process search and discovery requests;
  • Operate leaderboards, points, rankings, badges, and related simulated and educational features;
  • Deliver AI assistant responses;
  • Enable groups, referrals, sharing, streaks, achievements, and notifications; and
  • Maintain brokerage-connection status and related product surfaces.

4.2 Personalize Educational Content and Product Experience

We use preferences, discovery interactions, search history, engagement signals, approximate location (for market hours and localization), and limited profile information to personalize educational content, ordering of discovery experiences, and in-app messaging. Personalization in the App is an analytical interpretation of limited inputs and publicly available company information. It is not personalized investment advice.

4.3 Process Subscriptions and Entitlements

We use subscription and commercial information, together with identifiers needed to match purchases to accounts, to determine feature access, restore purchases, manage trials and rewards, and troubleshoot billing entitlement issues through Apple and our subscription management provider.

4.4 Measure and Improve the Product Through Analytics

We use product analytics, including through our product analytics provider as described in Section 5.2, to understand feature adoption, diagnose friction, evaluate experiments and feature flags, monitor errors, and improve the App. This includes screen views, typed product events, application errors and exceptions, feature-flag evaluations, and AI/LLM interaction traces.

4.5 Measure and Optimize Prophit's Own Advertising Campaigns

We use device identifiers (including IDFA only with App Tracking Transparency permission on iOS), app events, and related commercial signals to measure whether Prophit's own ads on Meta platforms (including Facebook and Instagram) are effective, and to optimize those campaigns. Prophit displays no third-party advertising inside the App. Advertising measurement is about Prophit's own user-acquisition campaigns, not about hosting ads for other companies inside the product.

4.6 Communicate with You

We use contact information, notification tokens, preferences, and support content to:

  • Send transactional messages related to your account;
  • Deliver push notifications you have enabled;
  • Respond to support and feedback requests; and
  • Send service-related notices, including material updates to legal terms where appropriate.

4.7 Secure the Services and Prevent Fraud or Abuse

We use authentication telemetry, device and technical data, IP-derived signals, brokerage-connection metadata, and support communications to detect, investigate, and prevent fraud, unauthorized access, abuse, and security incidents.

4.8 Comply with Law and Enforce Our Terms

We use relevant categories of information as needed to comply with applicable law, respond to lawful requests, enforce our Terms of Service, and protect the rights, property, and safety of Prophit, our users, and others.

4.9 Research, Development, and Aggregated Insights

We may use de-identified or aggregated information to understand aggregate usage trends, develop new educational features, and improve performance. Where we create aggregated or de-identified datasets, we maintain them in a form that is not reasonably linkable to an individual and do not attempt to re-identify them, except as permitted by law for testing or compliance.

4.10 Brokerage Facilitation and KYC Pass-Through

We use brokerage-connection tokens, brokerage identifiers, account status, and identity-verification information that you submit for brokerage onboarding solely to facilitate the connection or account-opening flow with Public Investing (and related clearing or verification infrastructure), and not for unrelated Prophit marketing purposes.

5. HOW WE SHARE YOUR INFORMATION

We share personal information with service providers and partners that help us operate the Services. We do not sell personal information to data brokers for monetary consideration. Certain advertising-measurement disclosures may constitute a "sale" or "share" under some state privacy laws; see Section 6.

We organize our recipients by purpose below. Where a recipient is a service provider, we require it to use personal information only to provide services to us or as otherwise permitted by our agreements and applicable law, except where the recipient also acts as an independent controller (for example, a brokerage with which you have a direct customer relationship, or Meta when processing advertising measurement data under its own policies).

5.1 Authentication and Account Management

We share account and authentication-related information with our authentication provider for user authentication, account management, identity services, and storage of credentials and legal-acceptance metadata associated with your account.

5.2 Product Analytics

We use our product analytics provider to receive detailed product analytics so we can operate and improve the App. Prior shorter privacy notices understated the depth of this processing. The following describes it more completely and honestly:

  • Session replay is enabled. Recordings generally capture on-screen text and images so we can understand how the App is used. Password fields are always masked. Sandboxed system views (such as photo and contact pickers) remain masked. We also intentionally redact certain sensitive screens, including authentication forms and account-deletion flows. Log capture is disabled. Network telemetry capture is disabled.
  • Person profiles are keyed to your account identifier and may include email address, name, first name, email domain, username, signup date, signup method, and referring user ID, plus bucketed usage and portfolio-value ranges.
  • Every event carries app version, build number, platform, operating system, device model, locale, timezone, and environment.
  • We capture screen views; roughly one hundred ten typed product events; application errors and exceptions; feature-flag evaluations; and AI/LLM interaction traces.
  • Anonymous pre-signup events are merged into the user's profile at sign-in through aliasing.

This product analytics processing is used for Prophit's product improvement. It is not used to display third-party advertisements in the App.

5.3 Advertising Measurement and Campaign Optimization — Meta Platforms, Inc.

We share device identifiers and app events with Meta Platforms, Inc. for measurement and optimization of Prophit's own advertising campaigns only. Events may include installs, opens, completed registration, subscription activity, and brokerage funding status. On iOS, the advertising identifier (IDFA) is used only if you grant App Tracking Transparency permission. If you deny tracking, we send only limited privacy-preserving events where allowed, including via Apple's SKAdNetwork. Prophit displays no third-party advertising in the App. Meta's use of data is also governed by Meta's Data Policy at https://www.facebook.com/privacy/policy/.

5.4 Subscriptions and In-App Purchases

We share information as needed with Apple and our subscription management provider to process in-app purchases and subscriptions, restore purchases, manage entitlements, and troubleshoot billing state. Our subscription management provider may forward purchase events to Meta for campaign measurement as described in Section 5.3.

5.5 Brokerage — Public Investing and Apex Clearing

If you choose to open or connect a brokerage account, information is shared with Open to the Public Investing, Inc. ("Public Investing"), a registered broker-dealer and member of FINRA and SIPC, with clearing and execution by Apex Clearing Corporation. Public Holdings, Inc. is the parent company and is not the broker-dealer. Shared information may include account-connection tokens, brokerage identifiers, account status, and identity-verification information you submit for KYC/AML and account approval. Your direct customer relationship for brokerage services is with Public Investing (and, as applicable, Apex Clearing), not with Prophit.

5.6 Market Data

We use our market data providers to obtain market data, fundamentals, news, and related financial information displayed in the App. Your use of market-data features may cause requests associated with your session or account to be processed in connection with retrieving that data. Market data itself is generally public company and market information rather than information about you.

5.7 Artificial Intelligence Features

When you use the AI assistant, user prompts and relevant context are transmitted to one or more of our AI model providers so they can generate responses. Do not include information in prompts that you are not comfortable transmitting for that purpose. Our AI model providers process prompts to deliver the feature and may process data under their terms and data-processing terms with Prophit.

5.8 Cloud Infrastructure

We use our cloud infrastructure provider for databases, caching, object storage, and secrets management. Personal information processed by the Services is stored in the United States on that provider's infrastructure and related systems we control or contract for.

5.9 Application Updates and Push Delivery

We use our application update and push delivery provider for over-the-air application updates and for push notification delivery infrastructure that works with Apple Push Notification service (APNs) and Firebase Cloud Messaging (FCM) as platform push transports. Device tokens and notification payloads are processed as needed to deliver updates and notifications you have enabled.

5.10 Additional Disclosures

We may also share information:

  • With professional advisors (such as lawyers, auditors, or insurers) under confidentiality obligations;
  • With vendors that provide operational support such as email delivery or customer-support tooling, where used;
  • With your consent; or
  • As otherwise described at the time of collection.

A current list of the specific service providers Prophit uses is available on request at support@prophit.investments.

6. SALE, SHARING, AND TARGETED ADVERTISING

PROPHIT DOES NOT SELL PERSONAL INFORMATION FOR MONETARY CONSIDERATION TO DATA BROKERS OR OTHER THIRD PARTIES FOR THEIR INDEPENDENT COMMERCIAL EXPLOITATION.

However, under some state privacy laws, "sale," "share," or "targeted advertising" / "cross-context behavioral advertising" are defined broadly. Certain advertising-measurement disclosures to Meta — including sharing of device identifiers and app events used to measure and optimize Prophit's own ad campaigns — may constitute a "sale" or "share" under those laws, even though no money is paid to Prophit specifically for selling a list of consumer profiles, and even though Prophit does not display third-party ads in the App.

If you want to opt out of sale, sharing, or targeted advertising / cross-context behavioral advertising as those terms are defined under applicable state law, contact us at support@prophit.investments with the subject line "Privacy Opt-Out," and use the device-level controls described in Section 16. Where required, we also honor Global Privacy Control and other recognized universal opt-out mechanisms.

7. COMPENSATION FROM PUBLIC INVESTING

Prophit may receive compensation from Public Investing when a user opens a new brokerage account through Prophit. This compensation is a fixed per-account marketing payment. It is not based on order flow, transaction volume, trades, or account balances. This arrangement creates a conflict of interest because Prophit has a financial incentive to encourage users to open brokerage accounts through the integration. Full details of the commercial relationship and related disclosures are set out in our Terms of Service. This Privacy Policy describes the personal-information flows associated with brokerage connection; it does not replace the conflict-of-interest disclosures in the Terms.

8. LEGAL DISCLOSURES AND LAW ENFORCEMENT

We may disclose personal information if we believe in good faith that disclosure is required or appropriate to:

  • Comply with applicable law, regulation, legal process, or governmental request, including subpoenas, court orders, and law-enforcement demands;
  • Enforce our Terms of Service and other agreements;
  • Detect, prevent, or address fraud, security, or technical issues;
  • Protect the rights, property, or safety of Prophit, our users, or the public; or
  • Respond to claims that content or conduct violates the rights of third parties.

Where legally permitted and reasonably practicable, we may attempt to provide notice of legal demands for personal information, unless notice is prohibited or would be ineffective or unsafe.

9. BUSINESS TRANSFERS

If Prophit is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal information may be transferred as part of that transaction, subject to standard confidentiality arrangements and applicable law. We will require the successor to honor privacy commitments consistent with this Privacy Policy, or we will provide notice and any choices required by law.

10. DATA RETENTION

We retain personal information for as long as reasonably necessary to provide the Services, maintain the security and integrity of the Services, comply with legal obligations, resolve disputes, enforce agreements, and for other legitimate business purposes described in this Policy. Retention is not one-size-fits-all. The following describes our actual retention approaches by category. Where a range is given, the longer end typically applies when the data remains relevant to an active account, an unresolved dispute, a security investigation, or a legal hold.

10.1 Account and Identity Data

We retain account and identity information for the life of the account and for a reasonable period after account closure or deletion request — typically up to twenty-four (24) months after closure — unless a longer period is required for legal compliance, fraud prevention, dispute resolution, or accounting. Certain authentication records maintained by our authentication provider may be retained according to that provider's retention practices and our agreements with the provider.

10.2 Authentication Telemetry

Login timestamps and related authentication telemetry are typically retained for approximately twelve (12) to thirty-six (36) months for security, abuse-prevention, and support purposes, unless needed longer for an active investigation or legal obligation.

10.3 Portfolio, Trading, and Preference Data

Portfolio names, holdings, likes and dislikes, watchlists, order records, order failure records, industry and topic preferences, and search history are generally retained for the life of the account so the product continues to function as you expect. After account deletion, we delete or de-identify this data within approximately ninety (90) days, subject to backups, legal holds, and residual copies in disaster-recovery systems that are overwritten on a rolling basis.

10.4 AI Conversations and Feedback

AI conversation threads, messages, symbols discussed, and feedback are generally retained for the life of the account to provide conversation history and improve support quality, unless you delete specific content where the product allows or you request deletion. After account deletion, we delete or de-identify AI conversation data within approximately ninety (90) days, subject to the same backup and legal-hold caveats. Our AI model providers may retain prompts for a limited period under their agreements with us for abuse monitoring, security, and service delivery; we configure provider retention according to available controls and our contracts.

10.5 Social, Referral, and Sharing Data

Group memberships, referral relationships, and shared-portfolio records are retained for the life of the relevant relationship or account. After deletion requests, we remove or de-identify these records within approximately ninety (90) days, except where retention is needed to prevent fraud (for example, abuse of referral rewards) for a longer period of up to twenty-four (24) months.

10.6 Subscription and Entitlement Records

Subscription entitlement status, trial and reward state, unlock records, and subscription-management webhook payloads are retained for the life of the account and for a period afterward sufficient for accounting, tax, chargeback, and subscription-restoration needs — typically up to seven (7) years for commercial transaction records where bookkeeping or legal retention requirements apply, and shorter periods for ephemeral webhook payloads that are needed only for reconciliation.

10.7 Engagement, Notification, and Device-Token Data

Streaks, check-ins, achievements, reward grants, notification preferences, notification logs, and push device tokens are generally retained for the life of the account or until the token becomes invalid. Notification logs may be retained for approximately twelve (12) to twenty-four (24) months for deliverability debugging and abuse prevention. Invalid device tokens are removed on a rolling basis when push delivery failures indicate the token is no longer valid.

10.8 Support and Feedback

Support and feedback records are typically retained for approximately twenty-four (24) to thirty-six (36) months after the ticket or submission is closed, and longer if needed for ongoing disputes, safety issues, or legal claims.

10.9 Brokerage Connection Tokens and Identifiers

Encrypted OAuth access and refresh tokens, brokerage user and account identifiers, and account status are retained while the brokerage connection remains active and for a short wind-down period after disconnection — typically up to ninety (90) days — unless needed longer for security investigation, fraud prevention, or legal compliance. When you disconnect or we delete the connection at your request, we delete or invalidate tokens so they can no longer be used to access the brokerage relationship through Prophit.

10.10 Identity-Verification Information for Brokerage KYC

Legal name, date of birth, residential address, and government identification numbers collected in the App for brokerage onboarding are transmitted to the brokerage for KYC/AML and account approval. Prophit does not use that information for other purposes. Prophit does not retain government identification numbers for Prophit's own ongoing product databases. Any transient processing artifacts created during transmission are deleted when no longer needed for security, troubleshooting, or compliance, and in any event are not used to build marketing profiles.

10.11 Device, Diagnostic, and Analytics Data

Device and technical logs, crash reports, and diagnostic data are typically retained for approximately thirty (30) days to twenty-four (24) months depending on severity and system. Product analytics events and person-profile properties associated with an identified user are retained for the life of the analytics workspace retention configuration applicable to our product analytics project and are deleted or de-identified upon verified deletion requests to the extent technically feasible within our product analytics systems and our downstream systems. Aggregated analytics may be retained indefinitely.

10.12 Advertising Measurement Events

App events and identifiers shared with Meta for advertising measurement may be retained by Meta under Meta's policies. Prophit retains its own campaign-configuration and high-level performance records for approximately twenty-four (24) to thirty-six (36) months for marketing analytics and budget accountability.

10.13 Website Visitor Data

Website logs and early-access form submissions are typically retained for approximately twelve (12) to thirty-six (36) months, unless a shorter period is configured for server logs or a longer period is required for waitlist operations or legal compliance.

10.14 Backups, Archives, and Legal Holds

Deletion from production systems does not always mean immediate erasure from encrypted backups. Backup systems are overwritten on a rolling schedule. If information is subject to a legal hold, we retain it until the hold is released, then apply the ordinary deletion process.

11. SECURITY MEASURES

We implement technical and organizational measures designed to protect personal information, including:

  • Encryption in transit using modern transport-layer security for network communications between the App and our backends;
  • Encryption at rest for data stored in our cloud databases and storage systems;
  • AES-256 encryption of brokerage OAuth tokens;
  • Secure on-device storage of sensitive credentials and tokens in the device keychain / secure storage mechanisms provided by the operating system and our secure-storage libraries;
  • Token-based API authorization using credentials issued by our authentication provider so that API requests can be authenticated without embedding long-lived passwords in the App;
  • Access controls limiting employee and contractor access to personal information on a need-to-know basis; and
  • Monitoring, logging, and operational practices intended to detect and respond to suspicious activity.
NO METHOD OF TRANSMISSION OVER THE INTERNET OR METHOD OF ELECTRONIC STORAGE IS COMPLETELY SECURE. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE ABSOLUTE SECURITY. YOU ARE ALSO RESPONSIBLE FOR MAINTAINING THE SECURITY OF YOUR DEVICE AND ACCOUNT CREDENTIALS.

If you believe your account has been compromised, contact us immediately at support@prophit.investments.

12. SECURITY INCIDENT NOTIFICATION

If we become aware of a security incident involving personal information that requires notification under applicable law, we will notify affected individuals and regulators as required by law. Notification timing, content, and method will follow the requirements of the jurisdictions that apply to the incident and the affected individuals. Where permitted and appropriate, we may provide notice through the email associated with your account, through in-app notice, through our website, or through other reasonable means. We may also take steps to contain, investigate, and remediate the incident, including resetting credentials, invalidating tokens, or requiring re-authentication.

13. YOUR PRIVACY RIGHTS

Depending on your state of residence and applicable law, you may have some or all of the following rights with respect to personal information we hold about you:

  • Right to know / access — to confirm whether we process your personal information and to obtain a copy of the categories and specific pieces of personal information we have collected, the sources of that information, the purposes for processing, and the categories of third parties with whom we share it;
  • Right to correct — to request that we correct inaccurate personal information about you;
  • Right to delete — to request that we delete personal information we have collected about you, subject to exceptions permitted by applicable law (for example, where retention is necessary to comply with a legal obligation, complete a transaction you requested, detect security incidents, or exercise legal rights);
  • Right to portability — to receive a copy of your personal information in a portable and, to the extent technically feasible, machine-readable format;
  • Right to opt out of "sale" or "sharing" of personal information, and to opt out of targeted advertising or "cross-context behavioral advertising" — although we do not sell personal information for monetary consideration, certain advertising-measurement sharing with Meta may constitute a "sale" or "share" under some state laws;
  • Right to opt out of profiling that produces legal or similarly significant effects concerning you;
  • Right to limit use of sensitive personal information, where applicable;
  • Right to non-discrimination for exercising any of these rights; and
  • Right to appeal an adverse decision we make on a privacy request, where required by your state's law.

These rights are not absolute. Applicable law may permit or require us to deny a request in whole or in part. If we deny a request, we will explain the reasons and, where required, how to appeal.

14. STATE-SPECIFIC PRIVACY RIGHTS

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, or any other U.S. state with a comprehensive consumer privacy law in effect, you may have additional rights under that state's law. Depending on the state, those laws may include the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), the Utah Consumer Privacy Act ("UCPA"), the Texas Data Privacy and Security Act ("TDPSA"), the Oregon Consumer Privacy Act ("OCPA"), and other comparable state laws.

14.1 California Residents (CCPA/CPRA)

California residents have the right to know what personal information we collect, use, disclose, and "sell" or "share" (as those terms are defined under the CCPA/CPRA); the right to delete and correct personal information; the right to limit the use and disclosure of "sensitive personal information"; the right to opt out of "sales" and "sharing" for cross-context behavioral advertising; and the right to non-discrimination for exercising these rights.

We do not knowingly "sell" personal information for monetary consideration. Certain sharing of personal information with advertising measurement partners, specifically Meta for Prophit's own campaign measurement, may constitute a "sale" or "share" as those terms are broadly defined under the CCPA/CPRA. To opt out, contact us at support@prophit.investments or use a Global Privacy Control ("GPC") signal where supported. We do not knowingly collect, "sell," or "share" personal information of consumers under the age of sixteen (16) without affirmative authorization. Because the Services are intended only for users eighteen (18) and older, we do not knowingly collect personal information from anyone under eighteen (18).

The categories of personal information we collect, the purposes for which we collect them, the categories of sources, and the categories of third parties with which we share them are described in Sections 3 through 5. Retention is described in Section 10.

14.2 California "Shine the Light"

Under California Civil Code section 1798.83 ("Shine the Light"), California residents may request information regarding our disclosure of personal information to third parties for the third parties' direct marketing purposes. We do not currently disclose personal information to third parties for those parties' own direct marketing purposes.

14.3 Universal Opt-Out Mechanisms

Where required by applicable state law (including in California, Colorado, Connecticut, Texas, Oregon, and other states that recognize such mechanisms), we honor recognized universal opt-out mechanisms such as the Global Privacy Control (GPC) and other legally recognized opt-out preference signals for sale, sharing, or targeted advertising, to the extent such signals are technically received and reasonably associable with a consumer and browser or device.

14.4 Other State Rights

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island may have rights to access, correct, delete, obtain a portable copy of personal information, opt out of targeted advertising, opt out of sale, and opt out of certain profiling, as well as appeal rights, subject to the scope and definitions of each state's law. The practical steps for exercising these rights are the same: contact us as described in Section 15. Where a state law uses different terminology (for example, "targeted advertising" versus "sharing"), we will apply the request to the advertising-measurement practices described in this Policy to the extent required by that law.

15. HOW TO EXERCISE YOUR RIGHTS

To exercise any privacy right, email support@prophit.investments with:

  • Your full name;
  • The email address associated with your Prophit account;
  • Your state of residence; and
  • A clear description of your request (for example, access, deletion, correction, portability, or opt-out of sale/sharing/targeted advertising).

15.1 Verification

We may need to verify your identity before fulfilling certain requests. Verification may include confirming control of the email address on the account, asking for additional account information, or taking other steps reasonably necessary to prevent fraudulent requests. If we cannot verify your identity to a reasonable degree of certainty, we may deny the request.

15.2 Authorized Agents

You may designate an authorized agent to make a request on your behalf where permitted by law. We may require proof of the agent's authority, such as a power of attorney or signed permission, and may still need to verify your identity directly.

15.3 Response Timing

We will respond within the timeframe required by applicable law. Under many state privacy laws, that timeframe is generally forty-five (45) days, with a possible additional forty-five (45)-day extension where permitted and needed. If we extend the time, we will inform you of the extension and the reason.

15.4 Appeals

If we deny your request and your state's law provides an appeal right, our response will include instructions for how to appeal. If an appeal is denied, you may have the right to contact your state attorney general or another regulator.

15.5 Non-Discrimination

We will not discriminate against you for exercising privacy rights, including by denying goods or services, charging different prices, or providing a different level of service, except as permitted by law (for example, where differences are reasonably related to the value of the data).

For the fastest response on privacy requests, email support@prophit.investments with "Privacy Request" in the subject line and include the information listed above.

16. OPT-OUT AND CONTROL MECHANISMS

In addition to rights requests, you can control certain processing directly:

16.1 App Tracking Transparency (iOS)

Deny the App Tracking Transparency prompt when shown, or later change Settings > Privacy & Security > Tracking > Prophit. If tracking is denied, we do not access your IDFA for advertising measurement and rely only on limited privacy-preserving measurement where allowed, including SKAdNetwork.

16.2 Push Notifications

Disable push notifications in the App's settings and/or in your device settings. If you disable notifications, we may still retain historical notification logs as described in Section 10 until deleted under ordinary retention or upon a deletion request.

16.3 Analytics

Contact us at support@prophit.investments to request opt-out of product analytics associated with your account, to the extent technically feasible. Some minimal operational logging needed to provide the Services and secure accounts may continue.

16.4 Marketing Email

If you receive marketing emails from us, you may unsubscribe using the link in the email or by contacting support@prophit.investments. Transactional emails about your account, security, or legal notices may still be sent as needed.

16.5 Personalized Advertising Measurement / Sale or Sharing Opt-Out

Use device tracking controls, GPC where applicable, and/or email us at support@prophit.investments with the subject line "Privacy Opt-Out."

16.6 Biometric Unlock

Biometric unlock is optional. To disable Face ID, Touch ID, or fingerprint unlock for the App, use your device settings and the App's authentication settings. Disabling biometric unlock does not delete biometric templates from your device because those templates are stored by the operating system, not by Prophit. To modify or delete enrolled biometric data on the device, use your device settings (for example, on iOS: Settings > Face ID & Passcode or Settings > Touch ID & Passcode).

16.7 Approximate Location

Because we do not request GPS location permission, there is no location-permission toggle for Prophit in device settings for precise location. Approximate location derived from IP address is inherent to network communication. If you do not wish for IP-derived approximate location to be associated with your account, you may request account deletion.

17. DEVICE PERMISSIONS

The App requests certain device permissions. Each permission is requested for a specific purpose. You can grant or deny permissions; denying a permission may limit the related feature.

17.1 Permissions We Request

  • Microphone — used so you can talk to the AI assistant and search by voice for stocks and concepts;
  • Speech recognition — used to convert spoken queries to text so the App can run search and assistant features on the resulting text;
  • Face ID / biometric unlock — used to unlock the App and help protect access to your portfolio; biometric matching occurs on-device only, and Prophit receives only success or failure;
  • App Tracking Transparency — used to measure which of Prophit's own ads brought you to the App and to improve advertising measurement; your activity is not sold as a data-broker list;
  • Push notifications — used to deliver alerts about the product, engagement features, and service notices if you opt in;
  • Photo library — used when you choose a profile picture; and
  • Media library — used when you save referral images or similar shareable images to your device.

17.2 Android Permissions

On Android, the App may request biometric permission, fingerprint permission, and record-audio permission, corresponding to biometric unlock and voice features described above.

17.3 Permissions We Do Not Request

PROPHIT DOES NOT REQUEST LOCATION, CONTACTS, CALENDAR, OR HEALTH DATA PERMISSIONS. WE DO NOT COLLECT GPS OR PRECISE LOCATION, DO NOT ACCESS YOUR CONTACTS OR CALENDAR, AND DO NOT COLLECT HEALTH OR FITNESS DATA.

18. BIOMETRIC AUTHENTICATION

This Section restates and expands the biometric disclosures that are critical to understanding what the App does and does not do.

You may choose to enable Face ID, Touch ID, or other on-device biometric authentication features provided by your device's operating system to unlock or authenticate within the App. Prophit Inc. does not collect, store, transmit, retain, sell, lease, trade, profit from, or otherwise have access to your biometric identifiers, biometric information, biometric templates, fingerprints, facial geometry, voiceprints, retina or iris scans, or any other biometric data, whether or not encrypted. All biometric capture, processing, matching, and storage occurs entirely on your device within the operating system's secure hardware enclave (such as Apple's Secure Enclave), under the control of the operating system provider (such as Apple Inc. or the applicable Android device manufacturer / OS provider) and subject to that provider's terms and policies. The App receives only a binary success-or-failure signal from the operating system indicating whether the authentication attempt matched the data enrolled on your device. We have no biometric-data retention schedule or destruction policy because we do not possess any biometric identifiers or biometric information. To disable, modify, reset, or delete your enrolled biometric data, please use your device's settings. Nothing in this Privacy Policy shall be construed as Prophit Inc. collecting, capturing, possessing, receiving through trade, or otherwise obtaining biometric identifiers or biometric information within the meaning of the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code § 503.001), the Washington Biometric Privacy Act (RCW 19.375), or any similar law.

19. CHILDREN'S PRIVACY

The App and Services are for users eighteen (18) years of age and older. Prophit does not knowingly collect personal information from anyone under eighteen (18). If we learn that we have collected personal information from a person under eighteen (18), we will delete it promptly. If you believe a minor has provided personal information to us, contact support@prophit.investments so we can take appropriate steps.

20. UNITED STATES ONLY; WHERE WE STORE DATA

The App and Services are offered only in the United States and its territories. Prophit does not offer, market, advertise, or intend the App to be used by persons located in the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions outside the United States. Personal information processed in connection with the Services is stored in the United States, including on infrastructure operated by our cloud infrastructure provider located in the United States.

If you access the Services from outside the United States, any information you provide will be handled in the United States and may be subject to U.S. law. Unauthorized access from non-U.S. jurisdictions is at your own risk and may violate our Terms of Service.

21. THIRD-PARTY LINKS AND SERVICES

The App and websites may contain links to third-party websites, applications, or services, and may display third-party market data, news, or brokerage interfaces. We do not control and are not responsible for the privacy practices of those third parties. Your use of third-party services is governed by their terms and privacy policies. This includes, without limitation, Public Investing, Apex Clearing, Apple, Meta, our AI model providers, and any external sites you open from the App. We encourage you to review the privacy policies of any third party whose services you use.

Some third-party interfaces, including brokerage account opening, identity verification, and bank-connection flows operated by Public Investing, are presented inside the App rather than in a separate browser. Although these screens appear within the App, they are operated by Public Investing and the providers it chooses, under their privacy policies and not this one. Prophit does not receive, observe, record, or store what you enter on those screens, including credentials, bank login details, and identity-verification documents. Prophit receives only the limited connection and account-status information described in Section 5.5.

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this Policy. For material changes, we will provide additional notice as required by law, which may include in-app notice, email notice, or another reasonable method. Your continued use of the Services after an updated Privacy Policy becomes effective constitutes acceptance of the updated Policy, except where applicable law requires a different form of consent. If you do not agree to material changes, you should stop using the Services and may request account deletion.

23. CONTACT INFORMATION

For questions about this Privacy Policy, to exercise privacy rights, or to request access, correction, deletion, portability, or opt-out, contact us at:

Prophit Inc.

Email: support@prophit.investments

Address: 131 Continental Dr, Suite 305, Newark, DE 19713

For California residents, you may also contact the California Department of Consumer Affairs:

California Department of Consumer Affairs

1625 North Market Blvd., Suite N 112

Sacramento, CA 95834

Phone: (916) 445-1254 or (800) 952-5210

24. APPLE APP STORE PRIVACY LABEL SUMMARY

Apple requires developers to provide a privacy nutrition label describing certain data collection and tracking practices. The following is a plain-language summary of the categories declared in our Apple privacy manifest (`PrivacyInfo.xcprivacy`) and related App Store disclosures. This summary is provided for transparency and is not a substitute for Apple's label in the App Store, which may be updated as Apple's taxonomy or our practices change.

24.1 Tracking

Our privacy manifest declares that the App engages in tracking as Apple defines that term. Tracking-related collection is used for analytics and for Prophit's own developer advertising / advertising measurement (not for displaying third-party ads in the App).

24.2 Data Used to Track You

Consistent with our privacy manifest, the following categories may be used to track you as Apple defines tracking:

  • Device ID — collected for analytics and developer advertising / advertising measurement purposes; not declared as linked to your identity in the privacy manifest's Device ID entry;
  • Product interaction — collected for analytics and developer advertising / advertising measurement purposes; not declared as linked to your identity in that manifest entry; and
  • Purchase history — collected for analytics, developer advertising / advertising measurement, and app functionality, and declared as linked to your identity.

24.3 Data Linked to Your Identity

Consistent with our privacy manifest, the following categories are declared as linked to your identity:

  • User ID — used for app functionality;
  • Email address — used for app functionality; and
  • Purchase history — used for app functionality and also for analytics and developer advertising / advertising measurement, and also declared as used for tracking.

24.4 Data Not Used to Track You (as Declared)

  • Crash data — collected for app functionality, declared as not linked to identity and not used for tracking in the privacy manifest.

24.5 Important Context for the Label

Apple's privacy label taxonomy is narrower and more formalized than this Privacy Policy. This Policy provides the fuller narrative of what we collect and why, including session replay and person profiles maintained by our product analytics provider, Meta advertising measurement, brokerage KYC pass-through, AI prompt transmission, and the many product databases that support portfolios, search, notifications, referrals, and support. If there is any ambiguity between a short App Store label and this Privacy Policy, this Privacy Policy is intended to be the more complete description of our practices, while the App Store label remains the disclosure formatted for Apple's required categories.

25. ADDITIONAL DISCLOSURES FOR TRANSPARENCY

25.1 No Third-Party Advertising Inventory in the App

Prophit does not sell advertising inventory inside the App to third-party advertisers. The Meta integration described in this Policy is for measuring and optimizing Prophit's own campaigns that promote Prophit on Meta-owned platforms.

25.2 De-Identified and Aggregated Data

We may create and use de-identified or aggregated data for analytics, research, and business operations. We take reasonable measures designed to ensure that de-identified data cannot reasonably be used to identify you, and we do not attempt to re-identify de-identified data except as permitted by law.

25.3 Automated Processing and Feature Flags

We use automated processing, including feature flags and analytics-driven configuration, to operate experiments, roll out features, and personalize educational experiences. We do not use automated processing to make legal or similarly significant decisions about you such as credit eligibility determinations. If you believe profiling of a kind that produces legal or similarly significant effects is occurring and you wish to opt out where the law provides that right, contact us as described in Section 15.

25.4 Relationship to Terms of Service

This Privacy Policy is part of our overall legal framework together with our Terms of Service. In the event of a conflict about privacy practices, this Privacy Policy controls as to privacy disclosures. In the event of a conflict about brokerage compensation, account eligibility, arbitration, or other contractual terms, the Terms of Service control as to those subjects.

26. DEFINITIONS

For purposes of this Privacy Policy:

  • "Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined under applicable law.
  • "Process" or "processing" means any operation performed on personal information, including collection, use, storage, disclosure, analysis, deletion, or de-identification.
  • "Sell," "share," and "targeted advertising" have the meanings given under applicable state privacy laws and, as used in this Policy, are discussed specifically in relation to advertising-measurement disclosures to Meta.
  • "Services" means the App, websites, and related Prophit services described in this Policy.
  • "Sensitive personal information" has the meaning given under applicable law and, in our context, may include government identification numbers collected solely for brokerage KYC pass-through and authentication credentials handled by our authentication provider.
  • "Track" or "tracking," when used in the Apple privacy-label sense, refers to Apple's App Store definition involving linking data collected from the App with third-party data for targeted advertising or advertising-measurement purposes.