Privacy Policy

ClarvenAI — Privacy Policy (Canada & United States)

Effective Date: August 22, 2026 Last Updated: August 31, 2026

In Short

We collect account information, product usage data, research data you choose to save, and payment metadata from our payment processor. We use this to operate ClarvenAI, process subscriptions, generate AI outputs, secure the Service, and improve the product.

ClarvenAI does not connect to your brokerage account. We do not collect brokerage account numbers, balances, or trade execution data — only what you choose to enter manually.

We do not sell your personal information, and we do not use your private research data to train AI models.

This summary is for convenience only. The full policy below governs.

1. Introduction

MJ Digital Ventures Inc., an Ontario corporation carrying on business as ClarvenAI ("ClarvenAI," "we," "us," or "our"), is committed to protecting the accuracy, security, and privacy of your personal information.

This Privacy Policy explains how we collect, use, disclose, store, and safeguard personal information in connection with the ClarvenAI website at clarvenai.com and all related services (the "Service"), in compliance with:

• Canada: the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), and applicable provincial laws including Quebec's Law 25
• United States: applicable state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and comparable laws in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other states as they come into force

By accessing or using ClarvenAI, you acknowledge that we collect, use, disclose, store, and protect personal information as described in this Privacy Policy. Where required by law, we will obtain your consent.

2. Information We Collect

We collect personal information to provide market intelligence, company research, AI-generated summaries, and account services.

A. Information You Provide

• Identity Data: name, email address
• Account & Profile Data: encrypted password credentials, display preferences, theme, notification and digest settings, onboarding responses
• Research Data: watchlists, saved tickers, portfolio holdings you choose to enter, research boards, decision journals, notes, checklists, and alert configurations
• AI Inputs: text prompts or queries you submit to Ask ClarvenAI (for example, a question about a company's risk factors)
• Support & Communications: feedback, support tickets, and other communications with us

Note on financial information: Portfolio holdings and watchlists are self-reported by you. ClarvenAI does not connect to your brokerage account and does not collect brokerage account numbers, account balances, or trade execution data.

Although watchlists, self-reported holdings, notes, and research boards are not generally classified as sensitive personal information under privacy laws, we treat them as confidential account information. We do not sell this information and do not use it for advertising or targeting.

B. Information Collected Automatically

• Technical Data: IP address, device type, operating system, browser type
• Usage Data: pages viewed, feature usage, session activity, error logs, crash diagnostics
• Email Engagement Data: whether digest and lifecycle emails are delivered, opened, or clicked
• Location Data: approximate location derived from IP address. We do not collect precise GPS location.

C. Payment Information

Subscriptions and payments are processed by Stripe. We receive limited billing metadata such as subscription status, plan, billing country, and the last four digits of a payment card. ClarvenAI does not store full payment card numbers or other sensitive payment credentials.

D. Information We Do Not Collect

We do not knowingly collect government identification numbers, health information, biometric data, precise geolocation, or information about racial or ethnic origin, religious beliefs, sexual orientation, or union membership.

3. How We Use Your Information

We use personal information for the following purposes:

• Service Delivery: to operate the platform, generate AI summaries and signal scores, and synchronize watchlists, boards, and alerts
• AI Processing: to transmit relevant financial content and your inputs to third-party AI providers for summarization and analysis
• Billing: to process subscriptions, trials, renewals, and refunds
• Security & Integrity: to authenticate users, prevent fraud, enforce trial and plan limits, and protect accounts
• Communications: to send transactional and account messages, and — where consent is provided or permitted by law — digests, product updates, and marketing communications
• Improvement & Analytics: to monitor performance, debug issues, measure feature usage, and improve the Service

Legal bases and consent: Some processing is necessary to provide the Service you have requested and to meet our legal and contractual obligations. In Canada, we otherwise rely on your consent, which may be express or implied depending on the sensitivity of the information and the purpose. You may withdraw consent as described in Section 9, though withdrawing consent may mean we can no longer provide some or all of the Service. Marketing and digest emails are sent only with consent consistent with CASL, and every such message includes an unsubscribe mechanism.

4. Artificial Intelligence & Data Privacy

ClarvenAI uses artificial intelligence technologies, including large language models ("LLMs"), to generate summaries, scores, and insights.

• Processing: Company filings, news, market data, and your submitted prompts may be processed by third-party AI providers, currently OpenAI.
• No Training on Your Data: We do not use your personal information, watchlists, research boards, notes, or prompts to train or fine-tune AI models, and we do not permit our AI providers to use them for training their models. Our use of OpenAI's API is subject to terms under which submitted content is not used for model training.
• Provider Retention: Our AI provider may retain submitted content for a limited period — typically up to thirty (30) days — solely for abuse monitoring and safety purposes, after which it is deleted, unless a longer period is required by law.
• Quality Monitoring: We may retain AI outputs and associated inputs for up to ninety (90) days to detect factual errors and inaccuracies ("hallucinations"), investigate reported problems, and improve system reliability. Access is limited to personnel who need it for these purposes.
• Automated Processing: Signal scores, opportunity scores, and similar outputs are generated automatically from public market and company data. They are not decisions about you, do not evaluate your personal characteristics, and have no legal or similarly significant effect on you.

5. Cookies and Similar Technologies

We use cookies and similar technologies to keep you signed in, remember preferences, secure the Service, and measure usage.

| Category | Purpose | Can you disable? | |---|---|---| | Strictly necessary | Authentication, session management, security, fraud prevention | No — the Service will not function | | Preferences | Theme, layout, saved display settings | Yes | | Analytics | Usage analytics and product measurement, including device and event-level activity | Yes |

We do not use cookies for advertising, retargeting, or building profiles about you across unrelated websites.

See Section 6, Your Privacy Choices, for how to control these.

6. Your Privacy Choices

Analytics and tracking

You can disable analytics and preference cookies through your browser settings, including by blocking third-party cookies or using private browsing. You can also install the Google Analytics Opt-out Browser Add-on, available from Google, to prevent Google Analytics from collecting data about your visits. Alternatively, email contact@clarvenai.com with the subject line "Opt Out" and we will process your request.

Disabling strictly necessary cookies will prevent you from signing in and using the Service.

Sale and sharing of personal information

We do not sell personal information for money. We do use analytics technologies that may be considered "sharing" or "targeted advertising" under certain U.S. state privacy laws, even though we do not use them for advertising. Where required by law, you may opt out of that sharing using the controls described above or by emailing contact@clarvenai.com with the subject line "Opt Out."

Email communications

You can opt out of digest and marketing emails at any time using the unsubscribe link in any such message or through your notification settings in the Service. You cannot opt out of essential transactional messages — such as billing, security, and account notices — while your account is active.

Browser signals

We do not currently respond to legacy "Do Not Track" browser headers, as no common standard has been adopted for them.

7. Sharing of Information

We do not sell your personal information.

A. Service Providers

We share personal information with third parties that process it on our behalf, under contracts requiring them to protect it and use it only for the purposes we specify:

| Provider | Purpose | Data involved | |---|---|---| | Vercel | Application hosting and content delivery | Technical and usage data | | Supabase | Database, authentication, and file storage | Account, research, and preference data | | Stripe | Payment processing and subscription billing | Billing metadata, email address | | OpenAI | AI summary and analysis generation | Prompts, company content | | Resend | Transactional, lifecycle, and digest email delivery | Name, email address, engagement data | | Google Analytics | Usage analytics and product measurement | Technical, device, and usage data, including IP-derived approximate location and event-level activity |

We also use third-party market data providers (including financial data, news, and filings vendors) to source public company information. These providers receive ticker and query parameters, not your identity.

This list reflects our providers as of the date above and may change. Material changes will be reflected in an update to this policy.

B. Public and Shared Content

If you choose to share a research board or similar content publicly through the Service, the content you share — and any notes or information you include in it — becomes accessible to anyone who has the link. Do not include confidential, personal, or sensitive information in shared content.

C. Business Transactions

In connection with a merger, acquisition, financing, restructuring, or sale of assets, personal information may be transferred as part of that transaction. We will notify you of any such transfer that materially affects how your information is handled.

D. Legal Requirements

We may disclose personal information where required to comply with applicable laws, regulations, subpoenas, court orders, or lawful requests from government authorities, or to establish, exercise, or defend legal claims.

8. International Data Transfers

ClarvenAI operates from Ontario, Canada. Our servers and service providers are located primarily in the United States, and personal information may be stored or processed there or in other jurisdictions.

For Canadian Users

By using the Service, you acknowledge that your personal information may be transferred to, stored in, and processed outside of Canada, including in the United States, where it may be subject to the laws of those jurisdictions and to lawful access requests by foreign courts, law enforcement, and government authorities.

For Quebec Residents

We have assessed that the personal information transferred outside Quebec receives adequate protection through contractual commitments with our service providers, taking into account the sensitivity of the information, the purposes of its use, and the legal framework applicable in the destination jurisdiction.

9. Your Privacy Rights

A. Canada (PIPEDA and Provincial Laws)

Canadian users have the right to:

• Access: request a copy of the personal information we hold about you
• Correction: request correction of inaccurate or incomplete information
• Withdraw Consent: withdraw consent for certain processing, subject to legal or contractual restrictions
• Complain: file a complaint with us, and if unsatisfied, with the Office of the Privacy Commissioner of Canada

Quebec Residents (Law 25) additionally have the right to:

• Data portability: receive your personal information in a structured, commonly used technological format
• Information about automated processing: be informed where a decision is based exclusively on automated processing (see Section 4)
• De-indexing: request that a hyperlink to your personal information be de-indexed in certain circumstances

B. United States

Subject to applicable state law, U.S. residents may have the right to:

• Right to Know / Access: request the categories and specific pieces of personal information collected, the sources, the purposes, and the categories of third parties it is disclosed to
• Right to Delete: request deletion of personal information, subject to legal exceptions
• Right to Correct: request correction of inaccurate personal information
• Right to Opt Out: opt out of the sale or sharing of personal information and of targeted advertising, as described in Section 6
• Right to Limit Sensitive Information Use: we do not collect or use sensitive personal information for purposes requiring this right
• Non-Discrimination: you will not receive discriminatory treatment for exercising privacy rights
• Appeal: in states that provide it, appeal a denial of a request by replying to our decision

C. How to Exercise Your Rights

Email contact@clarvenai.com with the subject line "Privacy Request." We will verify your identity using the email address associated with your account, respond within thirty (30) days where required by Canadian law and within forty-five (45) days where required by applicable U.S. state law, and may extend that period where permitted, with notice to you.

Authorized agents may submit requests on your behalf with written proof of authorization.

Many rights can be exercised directly in the Service: you can update your profile, adjust notification and digest settings, and delete watchlists, boards, and notes. To close your account, email contact@clarvenai.com and we will delete it for you.

Deleting an item or your account removes it from active systems. Copies may persist temporarily in encrypted backups, security logs, or records retained for legal, accounting, fraud-prevention, or dispute-resolution purposes, as described in Section 10. One record is retained on an ongoing basis rather than temporarily: a minimal trial eligibility record, described in Section 10, which allows us to enforce the one-free-trial-per-person limit. It contains no research data and no account content.

10. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this policy, including legal, accounting, and operational requirements.

| Data type | Retention | |---|---| | Account and profile data | Duration of your account, then deleted or anonymized within 90 days of account deletion | | Research data (watchlists, boards, notes, holdings) | Duration of your account, then deleted within 90 days of account deletion | | AI prompts and outputs | Up to 90 days for quality monitoring, then deleted or anonymized | | Email send and engagement logs | Up to 24 months | | Billing and tax records | Retained as required by Canadian tax and corporate law, generally seven (7) years | | Security and access logs | Up to 12 months | | Trial eligibility record | Retained on an ongoing basis after account deletion — see below | | Encrypted backups | Rolling window, generally not exceeding 90 days |

Trial eligibility record

ClarvenAI offers one free trial per person. To enforce that limit, we retain a minimal record that a trial was previously taken. This record consists of a normalized form of the email address used at signup, the date the first trial began, and a count of how many times that address has registered. It is retained after the associated account is deleted.

The email address is stored in normalized form, meaning common variations that reach the same mailbox — such as dots or plus-tags in Gmail addresses — are treated as a single address. Variations of the same mailbox therefore share one trial.

This record is retained on an ongoing basis rather than for a fixed period, because a time-limited record would allow the trial limit to be bypassed simply by waiting. It contains no research data, no account content, no billing details, and no usage history. It is used only to determine trial eligibility and to prevent trial abuse, and is not used for marketing, analytics, or any other purpose.

We rely on our legitimate interest in preventing fraud and abuse of the Service to retain this record, and where consent is the applicable basis under Canadian law, on the fraud-prevention exception to withdrawal of consent. If you would like this record erased, email contact@clarvenai.com with the subject line "Privacy Request." We will honour the request where we are not otherwise required or permitted to retain it, and we will tell you if erasing it means you would become eligible for a further trial.

Following account deletion, we may retain limited records where required to comply with legal obligations, resolve disputes, prevent fraud or trial abuse, or enforce our agreements.

11. Security Safeguards

We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, or disclosure. These include encryption of data in transit, encrypted storage of authentication credentials, access controls limiting who can access production systems, and reliance on established infrastructure providers.

No system is completely secure, and you acknowledge the inherent risks of transmitting information online.

Breach Notification: If a breach of security safeguards occurs that creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by PIPEDA, the Commission d'accès à l'information du Québec where Law 25 applies, and applicable U.S. state authorities, without unreasonable delay.

12. Children's Privacy

The Service is intended for individuals aged 18 and older and is not directed to children.

We do not knowingly collect personal information from children under 13 in the United States, or from minors where parental consent would be required under applicable Canadian law, including individuals under 14 in Quebec. If we become aware that we have collected such information, we will delete it promptly. If you believe a child has provided us with personal information, contact us at contact@clarvenai.com.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The "Last Updated" date at the top reflects the most recent revision. Material changes will be communicated through the Service or by email at least fourteen (14) days before taking effect. Continued use of ClarvenAI after updates take effect constitutes acceptance of the revised policy.

14. Contact Us and Privacy Officer

For questions, requests, or complaints regarding this Privacy Policy, or to exercise your privacy rights, contact:

ClarvenAI — Legal & Privacy Attn: Privacy Officer MJ Digital Ventures Inc. (o/a ClarvenAI) Email: contact@clarvenai.com

For Quebec residents, the individual responsible for the protection of personal information is the Privacy Officer identified above.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca, or, for Quebec residents, the Commission d'accès à l'information du Québec at cai.gouv.qc.ca.