Privacy Policy

1. Introduction

FolioX Inc. ("FolioX", "we", "us", or "our") is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in connection with the FolioX platform (the "Platform"), in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Canadian provincial privacy legislation, as well as applicable US state privacy laws including the California Consumer Privacy Act (CCPA) where relevant.

2. Information We Collect

We collect the following categories of personal information:

• Account information: Name and email address collected at registration via our authentication provider (Clerk).
• Usage data: Pages visited, features accessed, and interaction patterns on the Platform, collected to improve our service.
• Communication data: Email address used to deliver signal notifications and platform updates.
• Future data: We intend to collect portfolio and investment preference data in the future to provide personalised insights. We will update this Policy and seek appropriate consent before doing so.

We do not currently collect payment card information. When subscription billing is introduced, payment processing will be handled by a third-party payment processor and we will not store payment card data directly.

3. Cookies and Similar Technologies

The Platform uses cookies and similar technologies for the following purposes:

• Authentication cookies: Set by our authentication provider (Clerk) to maintain your session and keep you logged in. These are strictly necessary for the Platform to function and cannot be disabled.
• Preference cookies: Used to store your Platform preferences, such as whether you have accepted our disclaimer.

We do not currently use advertising cookies, third-party tracking cookies, or analytics cookies that share data with external parties.

4. How We Use Your Information

We use your personal information for the following purposes:

• To create and manage your account;
• To deliver signal notifications and platform updates by email;
• To verify your eligibility and manage your trial or subscription period;
• To improve and develop the Platform; and
• To comply with applicable legal obligations.

5. Disclosure of Your Information

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

• Service providers: Third-party vendors who assist in operating the Platform, including Clerk (authentication), Resend (email delivery), and Vercel (hosting). These providers process data on our behalf and are contractually obligated to protect it.
• Legal requirements: Where required by applicable law, regulation, court order, or governmental authority.
• Business transfers: In connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations.

6. Data Retention

We retain your personal information for as long as your account is active or as necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements. Upon account deletion, we will delete or anonymise your personal information within a reasonable period, subject to applicable legal retention requirements.

7. Your Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of your personal information, subject to legal retention obligations;
• Withdraw consent to certain processing activities; and
• Lodge a complaint with your applicable privacy supervisory authority.

Canadian residents may contact the Office of the Privacy Commissioner of Canada. California residents have additional rights under the CCPA, including the right to know, delete, and opt out of the sale of personal information (we do not sell personal information).

To exercise any of these rights, please contact us at: privacy@foliox.ca

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

9. International Transfers

Your personal information may be processed and stored in jurisdictions outside Canada, including the United States, where our service providers operate. By using the Platform, you acknowledge that your information may be subject to the laws of those jurisdictions. We take steps to ensure that cross-border transfers are protected by appropriate safeguards.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes by email and by updating the effective date above. Your continued use of the Platform after any changes constitutes acceptance of the updated Policy.

11. Contact Us

For privacy-related inquiries, please contact our Privacy Officer at: privacy@foliox.ca

FolioX Inc.
Canada