Privacy Policy

Last updated: June 2026

Zenly Financial, Inc., operating as Zenly™ ("we", "us", or "our") is committed to protecting your privacy. This policy explains what information we collect, how we use it, and your rights. By using the Service, you agree to the practices described here.

1. Information We Collect

We collect information you provide directly and information generated through your use of the Service:

• Account data: Email address and authentication credentials, managed via Supabase.
• Brokerage connections: Read-only access to your holdings, positions, and account balances via SnapTrade's OAuth integration. We never store your brokerage login credentials.
• Portfolio snapshots: Periodic snapshots of your portfolio value to power the historical tracking feature.
• Usage and telemetry data: Pages visited, features used, API response times, and error logs collected via Logfire to diagnose issues and improve the Service.
• Preferences: Display settings, watchlist contents, and other user-configured preferences stored to personalize your experience.

2. AI Features and Data Processing

Zenly includes AI-powered analysis and commentary features. When you use these features, relevant portfolio data (such as holdings, tickers, sector exposure, and performance figures) may be transmitted to a third-party AI language model provider (currently Anthropic, PBC) to generate the response. This data is sent solely to produce the output you requested and is governed by Anthropic's data usage and privacy policies.

We do not use your portfolio data to train AI models. AI-generated content is for informational purposes only and does not constitute financial advice.

3. How We Use Your Information

• To provide, maintain, and improve the Zenly Service.
• To display your portfolio data, analytics, and historical charts.
• To generate AI-powered commentary and analysis when you request it.
• To communicate with you about your account, important Service updates, or material changes to these policies.
• To diagnose technical problems, monitor performance, and ensure Service reliability.
• To comply with legal obligations.

4. Third-Party Services

Zenly integrates with the following third-party services. Each provider has its own privacy policy governing data they collect and process:

5. Data Storage and Security

Your data is stored securely using Supabase (PostgreSQL), hosted on infrastructure that encrypts data at rest and in transit using industry-standard protocols. Brokerage connections use read-only OAuth tokens provided by SnapTrade we cannot initiate trades or withdrawals on your behalf.

While we implement reasonable security measures, no transmission over the internet or electronic storage system is 100% secure. We cannot guarantee absolute security of your data.

6. Cookies

We use the following types of cookies:

• Authentication cookies: Set by Supabase to maintain your login session. These are strictly necessary for the Service to function and cannot be disabled.
• Preference cookies: Used to remember your display settings and UI preferences.

We do not use advertising cookies, cross-site tracking cookies, or cookies for behavioral profiling. We do not sell cookie data to third parties.

Do Not Track: We respect Do Not Track ("DNT") browser signals. When DNT is enabled, we do not engage in cross-site tracking.

7. Data Retention

We retain your data for as long as your account is active. When you delete your account, your profile, portfolio data, and brokerage connections are removed from our systems within 30 days. Anonymized aggregate usage statistics and application logs may be retained for longer periods for operational purposes.

8. Data Breach Notification

In the event of a data breach that is reasonably likely to result in a risk to your rights and freedoms, we will notify affected users by email within 72 hours of becoming aware of the breach, to the extent practicable. The notification will describe the nature of the breach, the data affected, and the steps we are taking to address it.

9. Your Rights

You have the following rights with respect to your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data (you may also delete your account directly from the dashboard).
• Portability: Request your data in a structured, machine-readable format.
• Objection: Object to certain types of processing, including processing for direct marketing.

To exercise any of these rights, contact us at support@zenly-financial.com. We will respond within 30 days.

10. GDPR European Users

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the following additional provisions apply:

Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract performance: Processing necessary to provide the Service you have signed up for (account management, displaying your portfolio, brokerage connections).
• Legitimate interests: Diagnosing errors, improving the Service, and maintaining security, where these interests are not overridden by your rights.
• Consent: For AI-powered features that transmit portfolio data to third-party AI providers. You may withdraw consent at any time by not using those features.
• Legal obligation: Where processing is required to comply with applicable law.

International Data Transfers

Zenly is operated from the United States. If you are located in the EEA, your data may be transferred to and processed in the United States and other countries that may not offer the same level of data protection as your home country. We rely on Standard Contractual Clauses (SCCs) and the data processing agreements with our sub-processors (Supabase, SnapTrade, Anthropic) to ensure adequate safeguards for such transfers.

Data Protection Rights

In addition to the rights described in Section 9, EEA users have the right to lodge a complaint with your local supervisory authority if you believe we have processed your data unlawfully.

11. CCPA California Users

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with the following additional rights:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources, our business purpose for collecting it, 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.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

We do not sell or share your personal information with third parties for cross-context behavioral advertising. The data shared with sub-processors listed in Section 4 is shared solely for the purpose of operating the Service on our behalf.

To submit a CCPA rights request, contact us at support@zenly-financial.com.

12. Children's Privacy

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us at support@zenly-financial.com and we will delete it promptly.

13. Changes to This Policy

We may update this policy from time to time. For material changes, we will notify you by email or by posting a prominent notice on the Service at least 30 days before the change takes effect. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the Service after the effective date of an updated policy constitutes acceptance of the changes.

14. Contact

Questions or requests regarding this policy? Reach us at support@zenly-financial.com.