WealthAgent Privacy Policy

2. Scope

In this Policy, "WealthAgent", "we", "us", and "our" mean WealthAgent. "You" and "your" mean the individual who uses the Services or whose personal information is processed through the Services. "Services" means the WealthAgent services described above.

"Personal information" means information about an identifiable individual, including information that can reasonably identify someone on its own or when combined with other information. Financial information, income information, family information, account information, and planning assumptions can be sensitive personal information.

This Policy applies to personal information that WealthAgent controls. If you use WealthAgent as a professional subscriber to create or manage plans for clients or other third parties, you remain responsible for your own privacy, confidentiality, professional, regulatory, recordkeeping, and consent obligations to those people.

3. Canadian Privacy Laws

WealthAgent is designed to comply with applicable Canadian private-sector privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta's Personal Information Protection Act, British Columbia's Personal Information Protection Act, and Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25.

Where a substantially similar provincial private-sector law applies to personal information handled within that province, we apply that law. PIPEDA may still apply to personal information that is handled in interprovincial or international commercial activity, to federally regulated activities, or where no substantially similar provincial private-sector law applies.

Other provincial or territorial laws, professional rules, consumer protection laws, anti-spam rules, tax rules, court orders, or regulatory requirements may also apply to particular uses of the Services. Nothing in this Policy limits rights or obligations that cannot be limited under applicable law.

4. Accountability

WealthAgent is accountable for personal information under its control, including personal information transferred to service providers for processing on our behalf. We use privacy and security controls, internal access restrictions, contractual terms, and service-provider review processes intended to provide a level of protection appropriate to the sensitivity of the information.

Our privacy contact for questions, access requests, correction requests, deletion requests, portability requests, consent withdrawal, and complaints is:

Privacy Officer, WealthAgent
[email protected]

5. Consent

We collect, use, and disclose personal information with your consent, where required, or as otherwise permitted or required by law. Consent may be express or implied, depending on the sensitivity of the information, your reasonable expectations, and the context. Because WealthAgent handles financial planning information, we treat many categories of plan data as sensitive.

By creating an account, entering plan information, using AI-assisted features, starting checkout, contacting support, or otherwise using the Services, you consent to the collection, use, disclosure, processing, and retention described in this Policy.

You may withdraw consent, subject to legal or contractual restrictions and reasonable notice. Withdrawal may limit or prevent our ability to provide the Services. For example, we need account identity information to authenticate you, plan information to generate forecasts, and billing information to manage paid subscriptions.

If you provide personal information about a spouse, partner, child, dependent, beneficiary, client, household member, employee, or any other person, you represent that you have lawful authority and all required consent to provide that information to WealthAgent for the purposes described in this Policy.

6. Information We Collect

We collect the categories of personal information needed to provide the Services.

• Account and identity information: name, email address, authentication provider, OAuth or OpenID Connect subject identifiers, account subject ID, profile updates, roles, permissions, and account timestamps.
• Plan and household information: plan names, descriptions, household members, relationships, roles, birth dates, retirement dates, projected demise dates, gender where entered, citizenship and residency assumptions, province or territory, locale, currency, inflation assumptions, health-cost assumptions, and life-expectancy assumptions.
• Financial planning information: accounts, balances, investment holdings, ticker symbols, adjusted cost base, income sources, pensions, government benefits, expenses, budgets, assets, liabilities, tax treatment, schedules, beneficiaries, successors, survivor benefits, goals, withdrawal strategies, scenario changes, forecast outputs, tax estimates, stress tests, and related assumptions.
• AI-assisted planning information: chat session titles, user messages, assistant responses, planning updates, generated artifacts, citations, tool events, token usage, and limited client context needed to continue an assistant session.
• Billing and subscription information: billing customer records, access tier, lifecycle state, billing interval, Stripe customer IDs, Stripe subscription IDs, Stripe checkout session IDs, Stripe price and product IDs, invoice status, webhook event identifiers, and related billing event payloads.
• Support and communications information: emails, support requests, issue details, error codes, request IDs, feedback, preferences, and communications we exchange with you.
• Technical, security, and usage information: IP address, device and browser information, authentication token metadata, request paths, request IDs, timestamps, error logs, security events, usage limits, and service diagnostics.

We may create aggregated, anonymized, or de-identified information from personal information. We use such information only where it no longer reasonably identifies an individual or as otherwise permitted by law.

7. Sources

We collect personal information from these sources:

• directly from you when you create an account, enter plan data, or contact us;
• from authentication providers when you sign in, including identity claims such as name, email address, subject identifier, roles, and permissions;
• from payment and billing providers when you start checkout, manage a subscription, or when billing lifecycle events are sent to WealthAgent;
• from professional subscribers, collaborators, invited plan users, or other people who have authority to enter your information into a plan;
• automatically through server logs, security systems, and essential service tools.

8. How We Use Information

We use personal information for purposes a reasonable person would consider appropriate in the circumstances, including to:

• create, authenticate, secure, administer, and support your account;
• create, maintain, calculate, forecast, simulate, and display financial plans;
• generate retirement projections, cash-flow models, tax estimates, strategy outputs, stress tests, and reports;
• operate AI-assisted planning features, including assistant chat, tool execution, and scenario updates;
• process subscriptions, checkout, billing, cancellations, invoicing, entitlement checks, and payment-provider webhooks;
• invite and manage plan users, permissions, shared billing access, and professional subscriber workflows;
• respond to support requests, diagnose problems, and communicate service information;
• maintain security, prevent fraud, detect misuse, enforce terms, rate limits, and subscription limits;
• debug, test, maintain, and improve the Services using appropriate safeguards and minimization;
• meet legal, accounting, tax, audit, regulatory, dispute-resolution, and recordkeeping obligations.

We do not use personal information to make credit, insurance, employment, lending, investment suitability, tax filing, legal, or regulated professional decisions about you. WealthAgent outputs are informational planning outputs based on the information and assumptions provided through the Services.

9. AI-Assisted Features

WealthAgent may use OpenAI or other AI service providers to power assistant features. Before plan context is sent to the AI model, WealthAgent replaces display names with placeholder tokens such as member, account, income, expense, asset, liability, budget, goal, and plan placeholders. The AI request metadata uses non-PII identifiers, such as plan UUID and session UUID, for operational correlation.

Full AI prompt payloads are not persisted by WealthAgent as prompt records. User chat messages, assistant answers, tool events, generated artifacts, planning updates, token usage, and limited client context may be stored in WealthAgent so the assistant can continue a session, show history, enforce usage limits, and support service operation. Session messages may be pruned according to system limits.

AI service requests are logged for correlation and system analysis only. Since requests are anonymized before being sent, no PII is persisted with the AI service; only correlation UUIDs are retained.

We do not intentionally use your personal plan information to train a general WealthAgent AI model. If we want to use identifiable personal information for a new AI training or model-improvement purpose that is not necessary to provide the Services, we will seek consent where required by law.

10. Billing

WealthAgent uses Stripe for subscription checkout, subscription management, payment method updates, invoices, and billing lifecycle events. Stripe may collect and process payment card, bank, tax, address, invoice, and transaction information under its own terms and privacy notices.

WealthAgent stores billing records needed to determine access and reconcile Stripe events, such as Stripe customer IDs, subscription IDs, checkout session IDs, prices, products, subscription status, invoice status, and webhook event payloads. WealthAgent does not store full payment card numbers.

11. Sharing

We disclose personal information only as needed for the purposes described in this Policy or as permitted or required by law. This may include disclosure to:

• service providers that provide hosting, databases, encryption key management, authentication, payment processing, billing, AI processing, observability, logging, email, security, support, and infrastructure services;
• authorized plan users, collaborators, professional subscribers, household members, or billing customer members, according to the permissions and sharing choices in the Services;
• payment and billing providers to create checkout sessions, manage subscriptions, process invoices, update payment methods, reconcile events, and prevent fraud;
• professional advisers, auditors, insurers, legal counsel, regulators, courts, law-enforcement agencies, or government bodies where reasonably necessary or required;
• a successor or prospective successor in connection with a merger, acquisition, financing, reorganization, sale of assets, change of control, insolvency, or similar business transaction, subject to appropriate safeguards.

We do not sell personal information. We do not disclose personal information to third parties for their own third-party advertising or marketing lists.

12. Transfers

Personal information may be processed, stored, or accessed in Canada and in other countries where WealthAgent or its service providers operate, including the United States. Personal information handled outside your province, territory, or country may be subject to the laws of that jurisdiction.

When we transfer personal information to service providers, we use contractual and other safeguards intended to provide comparable protection while the information is being processed. Where Quebec law applies, we assess relevant privacy factors before entrusting personal information outside Quebec and use written arrangements where required.

13. Protection

WealthAgent uses safeguards appropriate to the sensitivity of the information, including technical, organizational, and administrative controls. Current safeguards include:

• field-level encryption at rest for direct user identity fields, including name, email, and OAuth identifier;
• per-user data encryption keys for identity fields, with key-encryption keys used to wrap those data encryption keys;
• deterministic HMAC email lookup digests instead of plaintext email lookup indexes;
• pseudonymous subject IDs for plan ownership links so database-only access does not directly resolve plan ownership to plaintext identity;
• field-level encryption for plan member names and financial entity display names for accounts, income, expenses, assets, and liabilities;
• service-layer decryption so plaintext identity fields are exposed only through authorized application paths and not through general model properties;
• authentication token validation through OpenID Connect and scoped plan permission checks for plan access;
• redaction of known sensitive fields, tokens, authorization headers, cookies, email addresses, account numbers, Social Insurance Numbers, and similar values from validation and error logs;
• anonymization of AI prompt context with placeholder tokens before submission to AI providers;
• Stripe webhook signature verification and idempotent billing event processing;
• environment-based secret management, production key separation, and a prohibition on committing production secrets to repository-managed files.

Some plan and forecast data must remain readable to authorized backend services so WealthAgent can calculate forecasts, run simulations, enforce permissions, and provide the Services without requiring a separate user unlock flow. Field-level encryption does not apply to every field, free-text field, assistant message, generated output, or operational record.

No internet, cloud, or software service can be guaranteed completely secure. You are responsible for protecting your devices, browsers, networks, passwords, exported files, printed reports, screenshots, and any information you choose to share outside WealthAgent.

14. Cookies And Similar Tools

WealthAgent and our identity, payment, hosting, security, and infrastructure providers may use cookies, local storage, session storage, tokens, or similar technologies for essential purposes such as sign-in, security, fraud prevention, session continuity, preferences, checkout, subscription management, diagnostics, and service performance.

The public marketing website is not intended to use third-party advertising cookies. If we introduce non-essential analytics, advertising, or tracking technologies that require consent, we will provide notice and choices required by applicable law.

15. Retention

We retain personal information only as long as necessary for the purposes identified in this Policy or as otherwise permitted or required by law. Retention periods depend on the type of information, sensitivity, account status, subscription status, legal requirements, dispute risk, security needs, backup cycles, and operational needs.

Account, plan, forecast, assistant, and support information is generally retained while your account or plan remains active or as needed to provide the Services. Billing, transaction, invoice, tax, audit, security, fraud-prevention, and legal records may be retained longer where required or appropriate.

When personal information is no longer required, we delete, erase, de-identify, or anonymize it using reasonable processes. Some information may remain temporarily in backups, logs, or disaster-recovery systems until those records expire or are overwritten.

16. Your Rights

Subject to legal limits, identity verification, and applicable exceptions, you may request:

• confirmation of whether WealthAgent holds personal information about you;
• access to your personal information and information about how it has been used or disclosed;
• correction of inaccurate, incomplete, or outdated personal information;
• deletion, erasure, or anonymization of personal information that is no longer required or that was not lawfully handled;
• withdrawal of consent, subject to legal and contractual restrictions;
• a copy of certain computerized personal information in a structured, commonly used technological format where required by law;
• information about automated processing that produces an output about you, where required by law;
• review of a privacy concern or complaint by WealthAgent's Privacy Officer.

Quebec residents may have additional rights under Quebec's private-sector privacy law, including portability rights for certain computerized personal information collected from them, rights related to automated decision processing, and rights to require cessation of dissemination, de-indexing, or re-indexing in limited circumstances. WealthAgent does not generally publish personal plan information to public search indexes.

Where a self-service setting is available, you may update certain information in the Services. For other requests, contact [email protected]. We may ask for information needed to verify your identity and locate your records.

17. Complaints

If you have a privacy concern, contact the Privacy Officer first so we can review and respond. Please include enough detail for us to understand the issue, but do not send passwords, full account numbers, Social Insurance Numbers, or sensitive documents by email.

If you are not satisfied with our response, you may have the right to complain to the Office of the Privacy Commissioner of Canada or to the privacy commissioner or regulator in your province or territory, including the Alberta OIPC, the B.C. OIPC, or Quebec's Commission d'accès à l'information where applicable.

18. Privacy Incidents

If we become aware of a breach of security safeguards or confidentiality incident involving personal information under our control, we will take reasonable steps to contain the incident, reduce the risk of harm, investigate, preserve required records, and prevent similar incidents.

Where required by law, we will notify affected individuals and applicable regulators, which may include the Office of the Privacy Commissioner of Canada, Quebec's Commission d'accès à l'information, Alberta's Office of the Information and Privacy Commissioner, or another regulator with jurisdiction. We assess reportability by considering factors such as sensitivity of the information, probability of misuse, risk of significant harm or serious injury, and legal requirements in the relevant jurisdiction.

19. Minors

The Services are not directed to children. You must be old enough to form a binding contract in your province, territory, state, or country of residence to create an account. If you enter information about a minor as part of a household, dependent, or beneficiary plan, you must have lawful authority and any consent required from a parent, tutor, guardian, or other authorized representative.

20. Professional Use

Professional subscribers who enter client or third-party information into WealthAgent are responsible for their own collection notices, client consents, engagement terms, professional obligations, regulatory obligations, confidentiality obligations, and recordkeeping obligations. You must not enter client information unless you are lawfully authorized to do so.

For client plan content that a professional subscriber enters into WealthAgent, WealthAgent generally acts as a service provider processing that information to provide, secure, support, and maintain the Services. WealthAgent may also process account, billing, security, legal, and service records for its own legitimate business and compliance purposes as described in this Policy.

21. Communications

We may send service, account, billing, security, legal, and support communications that are necessary or reasonably related to the Services. Where we send commercial electronic messages that require consent under Canada's Anti-Spam Legislation or other applicable law, we will obtain consent or rely on another permitted basis and provide an unsubscribe mechanism where required.

22. Changes

We may update this Policy from time to time. The updated Policy will be posted on this page with an updated effective date. If a change is material, we will provide notice as required by applicable law or through reasonable service channels. Where required, we will seek consent before using or disclosing personal information for a new purpose that is materially different from the purposes described when the information was collected.

23. Contact

Questions, requests, and complaints about this Policy or WealthAgent privacy practices can be sent to [email protected].

For general support, email [email protected]. Do not send passwords, full account numbers, Social Insurance Numbers, or sensitive financial documents by email.