Privacy Policy

Effective date: April 14, 2026

1. Information We Collect

When you create an account or use our platform, we may collect:

• Account information: name, email address, and authentication credentials.
• Investor profile information: date of birth, employment status, risk tolerance, loss tolerance, investment experience level, time horizon, trading frequency, annual income, liquid net worth, total net worth, tax status, primary investment goal, account value, maximum position size percentage, approved trading strategies, options allocation preferences, and leverage/short-selling preferences. This information is collected during onboarding and used to personalize your advisory experience and fulfill our suitability obligations.
• Usage data: analytics windows accessed, feature interactions, session duration, and performance metrics.
• Payment information: processed by Stripe. We do not store credit card numbers on our servers.
• Device and connection data: browser type, operating system, IP address, and connection timestamps.

2. How We Use Your Information

We use collected information to:

• Provide, maintain, and improve our investment advisory platform.
• Personalize your advisory experience: If you complete the suitability questionnaire, your investor profile data (risk tolerance, experience level, time horizon, net worth, investment goals, and trading preferences) is used to generate strategy considerations, portfolio risk analytics, and position sizing guidance tailored to your profile. Without a completed questionnaire, the system applies default Moderate risk tolerance settings for all users.
• Process subscription payments and manage your account.
• Send service-related communications (e.g., downtime notices, billing confirmations).
• Monitor platform performance and investigate technical issues.
• Comply with legal obligations, including SEC recordkeeping requirements.

3. Data Sharing

We do not sell your personal information. We may share data with:

• Payment processors: Stripe, for subscription billing.
• Infrastructure providers: hosting and content delivery services necessary to operate the platform.
• Legal authorities: when required by law or to protect our legal rights.

4. Data Retention

Your personal data is retained during your active subscription. Upon account deletion, we remove personal data within 30 days, except for the following records retained for five years as required by SEC Rule 204-2: (a) client account records and advisory agreements, (b) transaction and trade signal history delivered to your account, (c) suitability assessments and investor profile data used to generate recommendations, (d) billing and payment records, and (e) communications related to your advisory relationship. After the five-year retention period, these records are securely destroyed.

5. Security (Regulation S-P Safeguards Rule)

In compliance with Regulation S-P (17 CFR Part 248), Ohey Inc. maintains written policies and procedures to protect the security, confidentiality, and integrity of client records and information. Our safeguards include:

• Administrative safeguards: Employee training, access controls limited to authorized personnel on a need-to-know basis, and policies governing the handling of nonpublic personal information.
• Technical safeguards: Encrypted connections (TLS 1.2+), secure authentication (JWT with token rotation), hashed and salted password storage, database encryption at rest, and intrusion detection monitoring.
• Physical safeguards: Secure data center hosting with restricted physical access, redundant backups, and monitoring.

These safeguards are designed to protect against anticipated threats or hazards to the security or integrity of client records and information, protect against unauthorized access to or use of such records or information, and ensure the proper disposal of client information. No system is entirely secure, and we cannot guarantee absolute protection.

6. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal data.
• Object to or restrict certain data processing.
• Export your data in a portable format.

To exercise these rights, contact us at [email protected].

7. Cookies

We use essential cookies for authentication and session management. We do not use third-party advertising cookies.

8. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via email or an in-platform notice. Continued use of the platform constitutes acceptance of the revised policy.

9. Regulation S-P Privacy Notice

As a registered investment adviser, Ohey Inc. is required to provide this notice regarding our privacy practices under Regulation S-P. We do not disclose nonpublic personal information about our clients or former clients to any nonaffiliated third parties, except as permitted by law (e.g., to service providers who assist in operating our platform, or as required by regulatory authorities). Because we do not share your nonpublic personal information with nonaffiliated third parties for marketing purposes, you do not need to opt out.

10. California Privacy Rights (CCPA/CPRA)

Ohey Inc. is headquartered in Pleasanton, California. If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following rights:

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business purpose for collecting the information, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions (including SEC recordkeeping requirements under Rule 204-2).
• Right to Correct: You may request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising purposes.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Categories of personal information collected: Identifiers (name, email, IP address); financial information (income, net worth, account value); internet activity (usage data, feature interactions); professional information (employment status); protected classifications (date of birth); and inferences drawn from the above (risk profiles, suitability assessments).

Business purposes for collection: Providing personalized investment advisory services, processing payments, maintaining regulatory compliance, and platform security.

To exercise any of these rights, submit a verifiable consumer request to [email protected]. We will respond within 45 days. You may also designate an authorized agent to make a request on your behalf.

11. Contact

For privacy-related inquiries:

Ohey Inc.
Pleasanton, CA 94588
Email: [email protected]