Advisor Intelligence Privacy Policy

This Privacy Policy explains how Altcoin Capital LLC ("Altcoin Capital," "we," "us," or "our") collects, uses, discloses, retains, and protects information in connection with Advisor Intelligence, a product developed and operated by Altcoin Capital LLC, including its related websites, applications, tools, and services (collectively, the "Service").

Advisor Intelligence is designed primarily for financial professionals and is designed to operate using de-identified situation information rather than information identifying individual clients or prospective clients.

1. Information We Collect

We may collect the following categories of information.

Account and professional information. This may include your name, email address, firm or company, professional role, account credentials, and other information you provide when creating or maintaining an account.

De-identified situation profiles. Financial professionals may create profiles using a reference label and generalized information about a client's or prospective client's circumstances.

This may include:

• Age bands or approximate age.
• Approximate asset ranges.
• General financial circumstances.
• Financial goals and objectives.
• Client concerns.
• Risk considerations.
• Planning needs.
• Other generalized information relevant to the feature being used.

Advisor Intelligence does not request, and its features are not designed to receive:

• Client names.
• Social Security numbers or other government-issued identification numbers.
• Financial account numbers.
• Client email addresses, telephone numbers, or other contact information.
• Exact dates of birth.
• Complete client files or account statements.
• Passwords or credentials.

Reference labels should not contain a client's name or other identifying information.

Advisor Intelligence may use technical measures intended to prevent submission of certain identifying information, but those measures are not infallible.

Conversation and practice information. We process information submitted during conversation simulations, meeting preparation, practice exercises, case analysis, evaluations, and other interactive features.

Voice audio. When you use voice-enabled features, microphone audio may be transmitted and processed to provide realtime communication and speech recognition.

Transcripts and evaluations. Advisor Intelligence may create and retain transcripts, conversation histories, evaluations, scores, observations, and other session-related information.

Usage and technical information. We may collect information regarding your interaction with the Service, including features used, session activity, device and browser information, IP address, logs, and diagnostic information.

Sponsored-access and event information. If you receive access through a continuing education program, carrier, wholesaler, conference, firm, or other sponsor, we may record the program or event through which access was provided and the applicable access period.

2. How We Use Information

We may use information to:

• Provide, operate, maintain, and improve Advisor Intelligence.
• Authenticate users and administer accounts.
• Generate meeting-preparation materials, conversation simulations, transcripts, evaluations, analyses, and other requested outputs.
• Provide realtime voice functionality.
• Personalize Service functionality.
• Provide customer support.
• Monitor performance, reliability, security, and appropriate use.
• Detect, investigate, and prevent fraud, security incidents, abuse, and violations of our Terms.
• Understand how features are used and improve the Service.
• Communicate with users regarding accounts, updates, and administrative matters.
• Administer continuing education and sponsored-access programs.
• Comply with applicable legal and regulatory obligations.

Advisor Intelligence does not sell identifiable personal information for monetary consideration.

Advisor Intelligence is not designed to collect identifiable client information for marketing to clients, and Altcoin Capital does not use de-identified situation profiles to contact or market directly to the underlying client or prospective client.

3. Artificial Intelligence, Voice, and Technology Providers

Advisor Intelligence relies on third-party technology providers to provide portions of the Service.

Depending on the functionality used, information may be processed as follows:

OpenAI

Used to power simulated client interactions. OpenAI may receive conversation text, persona instructions, and relevant de-identified situation context needed to generate simulated responses.

Deepgram

Used for speech-to-text processing. Deepgram receives microphone audio submitted during voice-enabled sessions so speech can be transcribed.

ElevenLabs

Used to generate simulated-client voice output. ElevenLabs receives text generated for the simulated client's responses so that audio can be produced.

LiveKit Cloud

Used to provide realtime audio and communication infrastructure. LiveKit processes audio streams and related technical information necessary to support realtime interactions.

Render

Used to host portions of the realtime voice service. Render may process information handled by that service, including audio, conversation data, and related technical information.

Base44

Used as the application platform supporting Advisor Intelligence. Base44 may process account information, de-identified situation profiles, cases, transcripts, application data, and related Service information.

Anthropic

Used through Base44 functionality to analyze conversation sessions. Anthropic may receive session transcripts and related context necessary to generate evaluations and analyses.

Third-party providers operate under their own terms, privacy policies, technical configurations, retention practices, and data-processing arrangements.

4. AI Training and Provider Data Use

Altcoin Capital seeks to limit the use of information submitted through Advisor Intelligence for third-party model training where providers make relevant contractual or technical controls available.

As of the effective date of this Privacy Policy:

• Advisor Intelligence has opted out of Deepgram's model-improvement program for submitted audio.
• Advisor Intelligence disables request logging through its configured ElevenLabs service where that setting is available and applicable.
• OpenAI states that content submitted through its API is not used to train its models by default.
• Anthropic's applicable commercial terms state that customer content submitted through its commercial services is not used to train its models except as otherwise permitted under those terms or agreed with the customer.

Provider terms, configurations, products, and data practices may change. Altcoin Capital may also change providers or technical architecture over time.

Altcoin Capital does not represent that every third-party provider supporting Advisor Intelligence is contractually prohibited from using information for every form of service improvement, processing, retention, or other use permitted by the provider's applicable terms.

In particular, Advisor Intelligence currently relies on Base44 for application infrastructure. Information processed through Base44 is subject to the applicable contractual terms and technical configurations governing that service. Altcoin Capital continues to evaluate available contractual and technical controls relating to such processing.

Our use of de-identified situation profiles is intended, in part, to reduce the amount and sensitivity of information transmitted through Advisor Intelligence and its supporting technology providers.

Users should not submit identifying client information or information unnecessary for the functionality being used.

5. Sponsored and Complimentary Access

Advisor Intelligence may provide complimentary access in connection with continuing education programs, conferences, carriers, wholesalers, firms, or other organizations.

We may maintain information identifying the event, sponsor, program, or source through which access was provided for purposes including:

• Activating and administering access.
• Determining the applicable access period.
• Managing the program.
• Measuring internal program participation and effectiveness.
• Understanding how users discover Advisor Intelligence.

The duration of complimentary access may vary by event, sponsor, or program and will be communicated at or before activation.

Altcoin Capital does not currently provide sponsors with access to individual Advisor Intelligence activity or sponsor analytics concerning topics practiced, client-concern categories, situation profiles, conversations, transcripts, evaluations, or planning opportunities.

Sponsorship or provision of complimentary access does not give a sponsor ownership of a user's Advisor Intelligence account or access to the user's individual activity.

If sponsor-related analytics or information-sharing features are introduced in the future, this Privacy Policy will be updated as appropriate, and any required notices or choices will be provided before such functionality applies.

6. How We Disclose Information

We may disclose information in the following circumstances.

Service providers. We disclose information to technology providers that perform functions necessary to operate Advisor Intelligence, including application hosting, artificial intelligence processing, speech recognition, voice generation, realtime communications, authentication, analytics, infrastructure, communications, and security.

At your direction. We may disclose information when you specifically request or authorize us to do so.

Legal and security purposes. We may disclose information when reasonably necessary to comply with applicable law, regulation, legal process, or governmental request; enforce our agreements; investigate fraud or security incidents; protect the Service; or protect the rights, property, or safety of Altcoin Capital, our users, or others.

Business transactions. Information may be transferred in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, subject to applicable law.

We do not sell personal information for monetary consideration.

7. Data Retention

We retain information for as long as reasonably necessary to provide Advisor Intelligence, maintain accounts, support requested functionality, satisfy legitimate business and recordkeeping requirements, resolve disputes, maintain security, enforce agreements, and comply with applicable law.

Different categories of information may be retained for different periods.

You may delete certain information through available Service functionality or request deletion of eligible information associated with your account.

Deletion requests may be subject to exceptions where retention is reasonably necessary for:

• Security and fraud prevention.
• Legal or regulatory compliance.
• Dispute resolution.
• Enforcement of agreements.
• Backup integrity.
• Other legitimate business purposes permitted by law.

Information stored in backups may remain for a limited period until those backups are overwritten or deleted through ordinary system processes.

Third-party providers may maintain information according to their own applicable retention practices and contractual arrangements.

8. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, acquisition, disclosure, alteration, loss, or destruction.

These measures may include authentication, access controls, encryption where appropriate, restricted administrative access, infrastructure protections, logging, monitoring, and security controls provided by our technology providers.

Advisor Intelligence's de-identification architecture and technical measures intended to restrict submission of certain identifying information form part of our approach to reducing data risk.

However, no internet-based service, artificial intelligence system, security control, or method of electronic storage can be guaranteed to be completely secure.

If we become aware of a security incident involving personal information, we will investigate and provide notifications where required by applicable law.

Advisor Intelligence does not currently represent that it maintains SOC 2, ISO 27001, or another independent information-security certification unless such certification is expressly stated by Altcoin Capital.

9. Your Privacy Rights and Choices

Depending on applicable law, you may have rights concerning personal information we maintain about you, including rights to:

• Request access to personal information.
• Request correction of inaccurate information.
• Request deletion of eligible personal information.
• Obtain information regarding how personal information is processed.
• Obtain a copy of certain personal information where required.
• Withdraw consent where processing is based on consent.
• Exercise other rights provided by applicable law.

We may need to verify your identity before fulfilling certain requests.

Because Advisor Intelligence is designed to use de-identified situation profiles rather than identifiable client records, we may be unable to associate a particular situation profile with an underlying individual without additional information from the financial professional who created it.

10. Cookies, Analytics, and Similar Technologies

Advisor Intelligence may use cookies, local storage, analytics technologies, and similar tools to authenticate users, maintain sessions, remember preferences, understand Service usage, diagnose technical issues, improve performance, and protect the Service.

Where required by applicable law, appropriate choices regarding non-essential technologies will be provided.

11. Children's Privacy

Advisor Intelligence is intended for financial professionals and is not directed to children.

We do not knowingly solicit personal information directly from children through the Service.

Users should not enter identifying information concerning minors into Advisor Intelligence.

Generalized, de-identified situation information concerning a household that includes a minor should be submitted only where the financial professional is authorized to use the information, the information is reasonably necessary for a legitimate professional purpose, and applicable privacy and consent requirements have been satisfied.

12. Financial and Regulatory Responsibilities

Advisor Intelligence provides technology tools for financial professionals.

Financial professionals and their firms remain responsible for determining their own regulatory, privacy, supervision, books-and-records, confidentiality, suitability, fiduciary, and compliance obligations when using the Service.

Use of Advisor Intelligence does not replace a firm's required books-and-records systems, supervisory systems, compliance procedures, or other required systems unless the firm independently determines that a particular use satisfies its applicable requirements.

Financial professionals should comply with their firm's policies governing third-party technology, artificial intelligence, communications, recordkeeping, and information handling.

13. International Processing and Data Transfers

Altcoin Capital LLC and technology providers supporting Advisor Intelligence may process information in the United States and other jurisdictions in which those providers operate.

Information may therefore be transferred to and processed in jurisdictions other than the jurisdiction in which a user is located.

Where applicable law requires particular safeguards for cross-border transfers, we will use legally required mechanisms where applicable to our processing.

14. Business Transfers

If Altcoin Capital LLC or Advisor Intelligence is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, information associated with the Service may be transferred as part of that transaction, subject to applicable law and appropriate confidentiality obligations.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to Advisor Intelligence, our technology providers, our practices, legal requirements, or other circumstances.

When material changes are made, we will provide notice where required by applicable law and update the effective date.

Where appropriate, users may be required to review or acknowledge an updated Privacy Policy before continuing to use Advisor Intelligence.

We may maintain records showing the version presented to a user and the date and time it was acknowledged.