Privacy Policy

This Privacy Policy describes how Tengu LLC, the company that operates Wealthnow (“Wealthnow”, “we”, “our”), collects, uses, shares, and protects information when you visit wealthnow.io, create an account, or use the Wealthnow app or API (the “Service”).

Tengu LLC is not currently registered as an investment adviser with the SEC or any state. Tengu LLC is not a broker-dealer or a custodian. Your funds and securities remain with the brokerage or exchange you connect. We are responsible for the information you give us about yourself and your accounts, and this policy explains what we do with it.

We collect information you give us, information we receive from your brokerage and other providers when you connect them, and information about how you use the Service.

Information you give us directly.

• Account information: name, email address, and a password (stored hashed, never in plain text).
• Your investor profile, if you complete it: for example your goals, time horizon, income, the net worth and debts you report, the cash you want to keep, your experience, risk tolerance, tax details, and anything you ask us to avoid.
• Support, sales, careers, and waitlist messages you send us.
• Payment information when you buy a plan or make a purchase. Card details are handled by our payment processor and are not stored on our servers.

Information from your connected accounts. When you connect an account through a connection service (such as Plaid or SnapTrade) or directly with a broker or exchange (such as Alpaca, Kraken, Gemini, or Robinhood), we receive holdings, balances, orders, transactions, and the identifiers needed to read the account and send the orders you approve. From Plaid we receive account masks (the last digits of an account number), not full account or routing numbers. If you enter a broker API key, we store it encrypted. If you add a self-custody wallet, we store its public address, never a private key. When you place a trade, we receive the order and execution records.

Alfred, the assistant. We keep what you type or say to the assistant and its answers, and the assistant may save facts from your conversations (such as your preferences) to use later. If you use voice, we process your audio and a transcript of it. We may send your messages to our AI providers together with relevant information from your investor profile and connected accounts, such as holdings and balances, whether or not you attach anything to a message. Paper (simulated) balances are never presented to an AI provider as real money.

Orders and acknowledgments. We record the orders you approve or place and the disclosures you accept, with the date, your IP address, and your device information.

Information collected automatically.

• Log data: IP address, browser and device type, operating system, referring URL, pages viewed, and timestamps.
• Approximate location derived from your IP address.
• Cookies, local storage, and similar technologies described in our Cookie Policy.
• Product usage events, such as the pages and features you use, clicks, errors, and performance.
• Advertising identifiers: when you arrive from an ad, the ad click identifier and campaign tags, which we attach to your checkout.

Session recordings. We record your sessions on the Service with our analytics provider. A recording does not include what you type into password and credential fields, such as passwords, one-time codes, card numbers and security codes, and broker API keys and secrets. A value you submit from one of those fields can still appear in a recorded network request, as described below. Everything else is recorded: a recording can include everything else on your screen and everything else you type, including other form fields. Windows embedded from other companies, such as Plaid’s or Stripe’s sign-in and payment forms, are not recorded. When the analytics provider’s setting that captures network activity is on, a recording can also include the contents of requests and responses between your browser and our servers; the provider’s software removes sign-in headers (such as authorization headers and cookies) and replaces request or response bodies that contain words such as “password,” “token,” or “secret,” while other requests and responses, such as holdings, balances, and assistant messages, can be stored as they were sent. When you are signed in, recordings and usage events are linked to your account ID, email address, name, and plan. Recordings are kept for the retention period set in our analytics account, and anyone with access to that account can view them.

We use the information we collect to:

• Operate, maintain, and improve the Service, including sign-in, account management, and sending the orders you approve.
• Show you your accounts, portfolio, performance, and analytics.
• Provide Alfred, the assistant, including answers that use your investor profile and connected accounts.
• Process payments for plans and purchases.
• Understand how the Service is used and find problems, including by watching session recordings.
• Measure and improve our advertising.
• Communicate with you about the Service, including notices, product updates, and security alerts.
• Detect, investigate, and prevent fraud, abuse, market manipulation, and security incidents.
• Comply with our legal obligations and enforce our Terms of Service.

The Service is intended for people in the United States. If you use it from the European Economic Area or the United Kingdom, we rely on these legal bases to process your personal data:

• Performance of a contract, to operate the Service you signed up for.
• Legitimate interests, to keep the Service safe, prevent fraud, secure our systems, understand how the Service is used, and improve it.
• Consent, for marketing emails and any other use that requires it. We do not currently ask for consent before analytics, session recording, or advertising tools run; our Cookie Policy explains.
• Legal obligation, to comply with the law and respond to lawful requests.

We share information with these categories of service providers, and with the others listed below, only to run the Service and for the purposes described here.

• Account connections, brokers, and exchanges. Plaid and SnapTrade, the brokers and exchanges you connect directly (such as Alpaca, Kraken, Gemini, and Robinhood), and Kalshi, whose account we only read. They receive connection tokens, account identifiers, and the order instructions for orders you approve. Your broker holds your funds; we do not.
• AI providers. Anthropic runs Alfred, the assistant. OpenAI is a fallback for some features. Anthropic models through Amazon Web Services Bedrock write short portfolio summaries. ElevenLabs processes voice. They receive your messages and the relevant parts of your investor profile and account data, and, for voice, your audio and transcripts.
• Cloud hosting. Amazon Web Services hosts the Service and stores its data in the United States.
• Analytics and session recording. Our analytics provider (U.S. cloud) receives usage events and the session recordings described above, linked to your account when you are signed in.
• Advertising. Through the Meta Pixel, Meta receives the pages you view (including pages inside the app) and events such as signing up, viewing pricing, connecting a broker, starting checkout, and starting a subscription (with the plan’s price), and, when you are signed in, a copy of your email address that your browser hashes first. Through the Google Ads tag, Google receives a notice each time a page of wealthnow.io is loaded in your browser (a full page load, not each screen inside the app) and, when you sign up, connect a broker, or start a subscription or trial, a conversion event, which carries the plan’s price when you subscribe. Our Cookie Policy describes both.
• Payments. Stripe processes payments. Today the Stripe account that collects our fees is held by AMP FUEL LLC, so your payment records sit in that account; we are moving billing to a Stripe account in the name of Tengu LLC. Stripe receives any name you enter at checkout, your email address, billing address, plan, and payment status, and any ad click identifiers attached to your checkout.
• Email and alerts. Resend sends our email. If you turn on alerts in another messaging service (such as Discord), that service receives the alerts you choose.
• Internal team alerts. Our internal alert channel, on a workplace chat service (Slack or Discord), receives your email address when you sign up; your name, email address, and the start of your message when you contact us or apply for a job; and your email address, plan, and payment amount when you subscribe.
• Market-data providers receive the symbols we look up, not your personal information.
• Legal and safety. Regulators, law enforcement, courts, or others where we believe the law requires it or where it is needed to protect the rights, property, or safety of our users, the public, or us.
• Corporate transactions. A successor in a merger, acquisition, or sale of assets, subject to the law, including any consent the law requires from you.

These providers handle information for us under their terms of service with us, which govern how long they keep it and whether they may use it for any other purpose, such as improving their models. We do not sell your personal information for money. Our use of the Meta and Google advertising tools may be treated as a “sale” or “sharing” of personal information under some state laws.

Depending on where you live, you may have some or all of these rights over the personal information we hold about you:

• Access: ask for a copy of the personal information we hold about you.
• Correction: ask us to fix information that is inaccurate or incomplete.
• Deletion: ask us to delete your account and the personal information linked to it, subject to the records the law requires us to keep.
• Portability: ask for a copy of the personal information you gave us in a structured, machine-readable format.
• Objection or restriction: object to, or ask us to restrict, certain processing.
• Withdraw consent, where processing is based on your consent.
• No discrimination: if you live in California, we will not deny service or charge a different price because you exercised your rights.

To exercise any of these rights, email support@wealthnow.io. We may need to verify your identity before we respond.

We keep personal information while we have a relationship with you, and afterward only as long as we need it to:

• Comply with our legal, accounting, and reporting obligations (which may require us to keep trade-related records for several years).
• Resolve disputes and enforce our agreements.
• Keep the Service secure and protect against fraud or abuse.

When you disconnect a broker in the app, we stop using that connection, but we do not delete everything we stored for it. API keys you entered, and the sign-in tokens from Robinhood, E*TRADE, and Interactive Brokers, stay encrypted in our database after you disconnect, and we do not revoke those tokens at the broker. To end access completely, also revoke the key or connection at your broker. Session recordings stay with our analytics provider for the retention period set in our analytics account.

We encrypt data at rest using AES-256, and use TLS 1.2 or higher on every connection to Wealthnow. Brokerage API keys and access tokens are encrypted with AES-256-GCM before we store them, using a key held in AWS Secrets Manager.

No system is perfectly secure, and we cannot guarantee absolute security. Our Security page describes the controls we use.

The Service is not directed to anyone under 18. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us at support@wealthnow.io and we will take appropriate steps to delete it.

We are based in the United States and store and process information there. If you use the Service from outside the United States, your information is transferred to the United States and to the other countries where our service providers operate.

Before a material change to this Privacy Policy takes effect, we will give you at least 30 days’ advance notice by email and in the app, and the notice will list each change. We may correct typos or update contact details without advance notice, with a new “Last updated” date. We keep every earlier version of this policy and will send you a copy on request.

If you have questions about this Privacy Policy or how we handle your information, contact us at:

• Email: support@wealthnow.io
• Postal: Tengu LLC (address available on request)

This addition is not yet effective. We will publish its confirmed effective date here after notices are complete. That date will be at least 30 days after both email and in-app notification is complete. Until then, the policy above applies without this addition. The advance-notice requirement under “Changes to this policy” continues to apply.

What will change. We are adding the following explanation of information shared through AI assistant connections: tool inputs and results; authorized account data; the assistant provider’s role; sign-in tokens; disconnecting; advertising restrictions; and retention. The other sections of the policy are unchanged.

You can connect Wealthnow to an AI assistant or developer tool, such as Claude, ChatGPT, Cursor, or VS Code, through our Model Context Protocol (MCP) server at https://mcp.wealthnow.io/mcp. These connections do not let the assistant place brokerage orders or move money. Our Support page explains how to connect.

What we receive. When the assistant uses a Wealthnow tool, it sends us the tool’s name and the inputs it chose for that call, such as a ticker, a company name, or a date range. We return the data needed to answer. We do not receive your conversation with the assistant, your chat history, or files you share with it, except for whatever the assistant puts into a tool’s inputs. To answer, we may look up the symbols or companies in those inputs with our market-data providers.

Account data you authorize. When you connect, you sign in to your Wealthnow account and approve the connection. The assistant can then read your plan, your remaining credits, and what your plan includes, and its tool calls are billed to your plan. It does not get your password.

What the assistant’s provider receives. The data our tools return goes into your conversation with the assistant. The company that runs the assistant, such as Anthropic or OpenAI, handles that conversation under its own privacy policy, not this one.

Sign-in tokens. Connecting uses OAuth, so the assistant receives sign-in tokens instead of your password. Access tokens expire after one hour. Refresh tokens expire after 60 days and are replaced when used. We use one-way hashes to look up tokens and encrypt stored connection credentials, including the replacement token pair retained to handle a repeated refresh request. Each connection belongs to the app you approved. Disconnecting that app on our side stops its tokens from working on their next use.

How to disconnect. Remove Wealthnow in the assistant’s own settings. To end the connection on our side as well, open your Wealthnow dashboard at app.wealthnow.io, go to Overview, then Connected agents, and select Disconnect. Disconnecting ends that app’s access; your other connections and API keys keep working.

No selling. We do not sell the tool inputs or results that pass through these connections, and we do not share them with advertisers.

How long we keep it. Expired tokens are deleted automatically. A connection’s record is deleted when you disconnect it, or otherwise about 400 days after you last connected that app. We keep records of each tool call, such as the tool, the time, whether it succeeded, and the credits it used, to bill your plan, prevent abuse, and fix problems, and our server logs can include a call’s inputs. We keep those records as described in “How long we keep information” above.