Privacy Policy

Effective date: August 4, 2026

This Privacy Policy explains how Adjustibl Inc. (Adjustibl, we, us) handles personal information in connection with our websites, applications, and related services (the Services).

1. Accountability and contact

Adjustibl's Privacy Officer is accountable for our privacy practices. Questions, complaints, and requests for access, correction, export, deletion, or withdrawal of optional consent may be sent to privacy@adjustibl.com or through the public Support page. We may verify identity before completing a request.

2. Information we handle

We handle account information received through Google Sign-In, such as email address, verified status, display name, profile image, and stable provider identifier. We also handle records you upload or enter, including portfolio, account, instrument, transaction, currency, date, quantity, amount, description, classification, correction, calculation, import, and source-traceability information. Uploaded material can contain information you did not intend to provide; review files before submission.

We collect necessary technical, security, and usage information such as session identifiers, authentication and audit events, request metadata, hashed client evidence where used, and operational logs. We do not request brokerage credentials and do not connect to brokerage accounts as part of the current Services.

3. Cookies and browser storage

Adjustibl currently uses only essential cookies and similar technologies needed for Google authentication, session security, request protection, and operation of the Services. The private application uses limited local browser storage to remember a non-sensitive navigation preference, such as the last account opened. At the effective date of this policy, Adjustibl does not use advertising cookies or third-party behavioural analytics in the Services. If that changes, we will update this policy and introduce any choice or consent mechanism required for the new technology.

4. How we use information

We use personal information to authenticate users; provide, operate, secure, maintain, evaluate, and support the Services; import, normalize, validate, reconcile, calculate, and present records; respond to requests; investigate incidents and abuse; administer access and future subscriptions; comply with law; and improve reliability and product quality within the purposes described here.

Authorized personnel may access production information on a need-to-know basis when reasonably necessary to operate, secure, support, debug, maintain, or meet legal obligations for the Services. Company ownership is not permission for casual browsing or unrelated use.

5. Current providers, hosting, and international processing

Google provides account authentication and supplies the limited Google profile information described above. Amazon Web Services (AWS) provides the deployed application, database, storage, security, logging, secrets-management, and system-email infrastructure. Production information is hosted and processed in the United States in the AWS region selected for the Services and may therefore be subject to United States law. Adjustibl uses AWS Simple Email Service to deliver necessary service messages. If a paid feature is enabled, a payment provider such as Stripe may process the information required for checkout, receipts, billing, and subscription administration under its own privacy terms.

We may use additional providers for professional advice, incident response, customer support, or other operational functions where reasonably necessary. We require providers acting on our behalf to handle information only for authorized purposes and with protections appropriate to their role. We do not sell personal information.

We may also disclose information to authorities where required or permitted by law; to protect rights, safety, security, or the Services; to professional advisers under appropriate duties; in connection with a protected financing, merger, reorganization, or sale; or to another party at your direction.

6. User-connected assistants

The Services may let you connect or invoke a third-party assistant, such as ChatGPT, Claude, or another compatible service, through the Model Context Protocol (MCP). Adjustibl does not operate a backend AI processor for this feature. When you connect or invoke an assistant, you direct Adjustibl to make the selected information needed for your request available to that assistant and to carry out requested actions within the permissions you grant.

Depending on your request and granted permissions, selected information may include portfolio and account details, instrument attributes, transaction types, dates, quantities, amounts, currencies, descriptions, classifications, validation facts, calculations, reports, and request context. A connected assistant does not receive your brokerage credentials or access to a brokerage account through Adjustibl. It also does not receive Gmail, Google Drive, Google Calendar, Google Contacts, payment information, or other Google account content. Google Sign-In remains limited to the account information described in section 2.

The assistant and its provider are selected or controlled by you and do not act as Adjustibl's service provider for this connection. Their own terms, privacy practices, processing locations, retention periods, training settings, and account controls apply after they receive information. Adjustibl does not control their subsequent handling and cannot promise that they will not retain the information or use it to improve or train models. Disconnecting an assistant prevents future access through the connection but may not delete information already received by the provider. Review the provider's settings and policies before connecting it.

7. Anonymized and aggregated information

We may create information that is genuinely anonymized or aggregated so it cannot reasonably be associated with an individual, and use it for analytics, research, evaluation, testing, machine learning, model development, and product and service improvement. We do not treat information as anonymous merely because a name, email address, account number, or user identifier has been removed.

Before production-derived information is used in an anonymized research, evaluation, or training dataset, Adjustibl will apply documented transformations and access restrictions appropriate to the data and assess whether individuals can reasonably be singled out or linked using the remaining attributes and other reasonably available information.

8. Retention and deletion

We retain account and transaction information while needed to provide the Services and for documented legal, security, accounting, audit, dispute, and operational purposes. Raw uploads, normalized records, support and feedback records, logs, backups, anonymized datasets, and connected-assistant authorization or access records may have different retention periods. We delete or anonymize information when it is no longer reasonably required for its documented purpose, subject to technical, legal, security, and backup constraints. A connected-assistant provider may separately retain information already disclosed under its own terms and settings.

Account deletion is distinct from cancellation of a future paid subscription. After a verified deletion request, limited legal-acceptance evidence may be retained to demonstrate the agreement and comply with legal obligations; security evidence and backups may also remain for bounded periods. Access to retained evidence is restricted and it is not used for ordinary product activity.

9. Safeguards

We use administrative, technical, and organizational safeguards appropriate to the information. Deployed AWS databases and object storage use encryption at rest, and the Services use encryption in transit. Other measures include named access, authentication, managed secrets, access restrictions, logging, controlled exports, data minimization, and separation of production from development where implemented. No system is completely secure.

10. Your choices and responsibilities

You are responsible for the accuracy of submitted records and for having authority to provide them. Subject to applicable law, you may request access, correction, export, or deletion and may withdraw an optional consent for future processing. Withdrawing an optional consent does not invalidate prior authorized processing or prevent limited legally required retention.

Product-update and promotional email consent is optional and separate from accepting the Terms or receiving necessary account, security, support, billing, or service messages. You can change the product-update preference in Settings. Mere use of the Services does not grant optional marketing or identifiable-data model-training consent.

Connecting or invoking a third-party assistant directs Adjustibl to make selected information available and carry out requested actions within the permissions you grant. This direction is separate from consent to use identifiable or reasonably linkable records for model training.

11. Changes

We may update this policy and will publish a new effective date. We will provide additional notice and request acknowledgement or consent where a material change requires it.

12. Children

The Services are intended only for people who have reached the age of majority where they live and are not directed to children. Contact the Privacy Officer if you believe a child provided information improperly.