Privacy Policy

Last updated: May 31, 2026

This Privacy Policy explains how AI PORTFOLIOS, LLC (“AI Portfolios,” “we,” “us,” or “our”) collects, uses, shares, and protects information about you when you visit our website at aiportfolios.com, use our iOS application, or otherwise use the AI Portfolios consulting and trading services (collectively, the “Services”). AI Portfolios provides AI-assisted financial consulting and, for eligible subscribers, autonomous portfolio management, supported by a licensed Registered Investment Adviser (“RIA”).

The Services are currently offered only to individuals located in the United States who are 18 years of age or older. In compliance with SEC Rule 203A-2(e), AI Portfolios operates strictly as an internet investment adviser, providing digital investment advisory services on an ongoing basis to clients exclusively through our operational interactive website, mobile application, or digital platforms. The firm maintains no non-internet or physical advisory relationships.

1. Scope of This Policy

This Policy applies to personal information we collect through our marketing website, mobile application, AI chat interface, consultation reports, and trading dashboard. It does not apply to the independent privacy practices of third parties whose services we integrate with, including your bank, brokerage, or other linked institutions, each of which maintains its own privacy policy.

2. Information We Collect

The categories of information we collect depend on which parts of the Services you use. They include the following.

2.1 Information You Provide Directly

  • Identity and contact information, such as your name, date of birth, state of residence, email address, and login credentials.
  • Financial profile information, such as income and employment details, assets (liquid, investment, real estate, and other), liabilities, insurance coverage, dependents, and estate-planning information.
  • Goals and preferences, such as your investment objectives, time horizon, liquidity needs, selected risk tier (Conservative, Moderate, or Aggressive), and preferred or excluded asset classes.
  • Tax information, such as filing status, tax bracket, and use of tax-advantaged accounts.
  • Communications, including the messages, questions, and information you share through the AI chat interface and any correspondence with our support team.

2.2 Information From Connected Financial Accounts

With your authorization, we use Plaid to securely connect to your bank, brokerage, retirement, and other financial accounts. Through this connection we may receive account balances, holdings, transaction history, and liability information. For Pro-tier subscribers, we also connect to your brokerage account (for example, Alpaca, Interactive Brokers, or Apex) and may receive trade history, cost basis, tax-lot data, and order and execution details. Where held-away account management is enabled, we use Pontera to manage assets in external 401(k) or 403(b) accounts without taking custody of those assets.

2.3 Information Collected Automatically

  • Device and technical data, such as device type, operating system, app version, IP address, and identifiers used for authentication and security.
  • Usage data, such as features accessed, chat sessions, content viewed, notification interactions, and dashboard activity.
  • Cookies and similar technologies on our website, as described in Section 9 below.

2.4 Information From Market and Data Providers

We obtain market, economic, and reference data from third-party providers (for example, Polygon.io, Tiingo, and Yahoo Finance) to power analysis and monitoring. This data is generally not personal to you, but it is combined with your profile to generate personalized output.

3. How We Use Your Information

We use the information we collect to:

  • Build and maintain your financial profile and generate personalized consultation reports, strategy recommendations, and action lists;
  • Monitor your portfolio and market conditions and send proactive alerts and notifications;
  • For Pro-tier subscribers, detect economic regime shifts and execute autonomous trades within the parameters you approve, including tax-loss harvesting and rebalancing;
  • Generate performance analytics and tax documents (such as a 1099-B summary equivalent);
  • Operate, secure, personalize, and improve the Services;
  • Communicate with you about your account, subscription, and support requests;
  • Comply with our legal, regulatory, and recordkeeping obligations, including SEC and FINRA requirements and the maintenance of audit trails; and
  • Detect, prevent, and respond to fraud, security incidents, and misuse.

4. Automated Processing and Artificial Intelligence

The Services are powered by artificial intelligence. We send relevant profile, portfolio, and conversation data to Anthropic’s Claude API to generate advice, reports, and chat responses, and we use proprietary and open-source models to detect economic regimes and inform strategy. For Pro-tier subscribers, automated systems may execute trades in your accounts without seeking your approval before each individual trade, subject to the guardrails and parameters you authorize. You can pause autonomous trading at any time as described in our Terms & Conditions. We apply automated compliance filtering to AI-generated output before it is delivered to you.

5. How We Share Your Information

We do not sell your personal information. We share information only as described below:

  • Service providers and partners who perform functions on our behalf, including Plaid (account aggregation), Anthropic (AI processing), Polygon.io / Tiingo / Yahoo Finance (market data), brokerage partners such as Alpaca, Interactive Brokers, and Apex (trade execution), Pontera (held-away account management), Amazon Web Services (hosting and storage), and email and push-notification providers (such as SendGrid / AWS SES and Apple Push Notification service).
  • Our affiliated partner Registered Investment Adviser, to provide advisory services and meet supervisory and compliance obligations.
  • Legal and regulatory recipients, when required to comply with law, regulation, legal process, or a government or regulatory request, or to protect rights, safety, and the integrity of the Services.
  • In a business transaction, such as a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections.

We require our service providers to protect your information and to use it only for the purposes for which we engage them.

6. Data Retention

We retain personal information for as long as needed to provide the Services and for legitimate business and legal purposes. Certain records, including trade records, recommendations, and compliance audit trails, are retained for a minimum of seven (7) years to satisfy regulatory books-and-records requirements. When information is no longer required, we delete or de-identify it in accordance with our retention schedule.

7. How We Protect Your Information

We maintain administrative, technical, and physical safeguards designed to protect your information, including AES-256 encryption of data at rest, TLS 1.3 encryption in transit, secure storage of financial-account tokens in the iOS Keychain, optional biometric authentication, and policies that exclude personally identifiable information from system logs. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your Rights and Choices

  • Access and correction. You can view and update much of your profile information directly within the app, and you may request access to or correction of other information we hold.
  • Deletion. You may request deletion of your account and associated information, subject to records we are legally required to retain.
  • Disconnecting accounts. You may disconnect linked financial accounts (for example, through Plaid) at any time, which will limit the functionality of the Services.
  • Notifications. You can manage push and email notification preferences in your settings.
  • Pausing autonomous trading. Pro-tier subscribers can pause autonomous trading at any time within the app or dashboard.

To exercise any of these rights, contact us at info@aiportfolios.com. We will respond as required by applicable law.

9. Cookies and Tracking on Our Website

Our website uses cookies and similar technologies to operate the site, remember your preferences, secure your session, and understand how the site is used. You can control cookies through your browser settings and any cookie controls we provide on the site. Some features may not function properly if cookies are disabled.

10. State Privacy Rights

AI Portfolios, LLC is a limited liability company organized under the laws of the State of Delaware. Depending on your state of residence (including California, Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy frameworks), you may possess additional legal rights regarding your personal information. 

10.1 Your Rights Under State Frameworks

Subject to specific state-level definitions and statutory exceptions, your rights generally include:

  • The Right to Know and Access: You have the right to confirm whether we are processing your personal data and to access the specific pieces of personal information we have collected about you.
  • The Right to Delete: You have the right to request the deletion of personal information collected from or about you, subject to certain legal and regulatory books-and-records retention mandates.
  • The Right to Correct: You have the right to request that we correct inaccuracies in the personal information we maintain about you.
  • The Right to Opt-Out: You have the right to opt-out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
  • The Right to Non-Discrimination: We will not discriminate or retaliate against you in pricing, service availability, or platform features for exercising any of your protected privacy rights.

10.2 Data Sale and Behavioral Advertising Disclosures

We do not sell your personal information or share your personal data with third parties for cross-context behavioral or targeted advertising purposes. Therefore, an opt-out mechanism for the sale or sharing of data is not required on our platform.

10.3 How to Exercise Your Rights

To submit a verifiable request to exercise any of these applicable state rights, please contact our compliance desk at info@aiportfolios.com. We will review and respond to your request within the legally mandated timeframes required by your state of residence. 

11. Children’s Privacy

The Services are intended only for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected such information, we will delete it.

12. Third-Party Links and Services

Our Services may link to or integrate with third-party websites and services. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated Policy with a revised “Last updated” date and, where required, provide additional notice. Your continued use of the Services after the effective date of an updated Policy constitutes acceptance of the changes.

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

AI PORTFOLIOS, LLC

Email: info@aiportfolios.com