Effective Date: May 26, 2026. Last Revised: October 5, 2026.
This Privacy Policy (this "Policy") describes how Eltrove ("Eltrove," "we," "us," or "our") collects, uses, discloses, retains, and protects Personal Information in connection with the Eltrove mobile application for Apple iOS (the "App"), the website located at https://eltrove.com (the "Website"), and all related services, features, and content that we make available through the App or the Website (together with the App and the Website, the "Service"). In this Policy, "you" and "your" refer to any individual who accesses or uses the Service.
This Policy should be read together with our Terms of Service (the "Terms"). Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms. By accessing or using the Service, you acknowledge that you have read and understood this Policy. Where applicable law requires your consent to a particular collection, use, or disclosure of Personal Information, we will request that consent separately and specifically, as described in this Policy.
For the purposes of this Policy:
Eltrove is a market-information service made available through the App, which is offered through the Apple App Store in the United States and Canada, and through the Website. The Service consists of the following principal features:
Eltrove does not execute trades, does not connect to or access brokerage accounts, does not hold or custody funds or securities, and does not provide individualized investment advice. Accordingly, we do not collect brokerage credentials, account numbers, positions, balances, or trading activity.
Public sign-in to the Service is available only through Sign in with Apple and Sign in with Google. We do not receive your Apple ID or Google account password. An email-and-password sign-in method exists solely to provide demonstration access to Apple's App Review team and is not offered to the public.
We do not receive or store your payment card number or other payment instrument details. Payments made through the App Store are processed by Apple, which holds your payment information.
The content of communications you send to us, including support requests and messages submitted through the Website's contact or waitlist forms, together with the email address and name you provide in them.
Only where you have given Consent, we collect Analytics Data, consisting of screen and page views, clicks and other interactions, Session Recordings, and diagnostic data, including crash reports and the timing and status of network requests made by the App. All text inputs are masked in Session Recordings. If you decline or do not respond, no Analytics Data is collected through the Website or the App.
Independently of Analytics Data, our servers record certain events relating to the operation of your Account, namely sign-up, sign-in, purchases and renewals reported by RevenueCat, Forecast requests, the number of alerts delivered, and server errors. These records are associated with your Account email address and are transmitted to PostHog, Inc., acting as our Service Provider, for the purposes of operating, securing, and troubleshooting the Service, as described in Section 5.
We collect Personal Information from the following sources: (a) directly from you, when you sign in, use the Service, change your settings, or contact us; (b) from Apple and Google, when you use Sign in with Apple or Sign in with Google; (c) from Apple and RevenueCat, with respect to purchases and subscription status; (d) automatically from your device or browser when you use the Service; and (e) from our Service Providers that operate infrastructure on our behalf.
The Insiders feature reproduces information about the individuals who file public securities-transaction disclosures (such as names, positions, and reported transactions). That information is obtained from publicly available government and regulatory records and is not collected from users of the Service.
We use Personal Information for the following business purposes:
We do not use Personal Information to deliver targeted or cross-context behavioral advertising, and the Service contains no advertising trackers.
On your first visit to the Website, a consent banner presents equally prominent "Accept" and "Decline" options. Unless and until you select "Accept," no analytics or session-recording scripts are loaded and no analytics cookies are set. If you select "Decline," those scripts are not loaded. In either case, the Website stores a strictly necessary local record of your choice so that the banner is not shown again. You may change your choice at any time through the "Cookie choices" link in the Website footer. Where you withdraw Consent, analytics collection stops and analytics cookies and local storage entries set by the analytics provider are cleared from your browser.
The Website also uses technologies that are strictly necessary for its operation, such as those that keep you signed in. Google Analytics is not used on the Website.
If your browser transmits a Global Privacy Control ("GPC") signal, we treat that signal as a decline of Consent and as a request to opt out of the sale or sharing of Personal Information. Analytics is not loaded in a browser that transmits a GPC signal.
In the App, analytics, Session Recording, and diagnostic data collection are disabled unless you select "Allow" in response to a one-time prompt presented after you sign in. Declining, or not responding, results in no Analytics Data being collected, and your choice does not affect your access to any feature of the App. You may change this choice at any time in the Privacy section of the You tab.
Analytics Data is processed by PostHog, Inc., located in the United States, as our Service Provider. Session Recordings are retained in accordance with the retention settings of our analytics provider, which currently provide for retention of up to thirty (30) days.
The Service publishes a public Scorecard that reports how Forecasts have performed. Forecasts you request may be included in the Scorecard and in aggregate statistics in anonymized form. Anonymized contributions do not include your name, email address, Account identifier, or any other information that identifies you, and other users cannot attribute any Forecast to you.
Contribution is enabled by default. You may opt out at any time by turning off the "Share my forecasts anonymously" setting in the App. Opting out applies to Forecasts requested after the change and does not affect your ability to use the Service.
We disclose Personal Information to the following categories of recipients, solely for the purposes described in this Policy:
Apple and Google also process Personal Information as independent controllers or businesses under their own terms and privacy policies when you use their sign-in, payment, or distribution services.
We may disclose Personal Information (a) where required by law, regulation, subpoena, court order, or other legal process; (b) where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Eltrove, our users, or others, or to investigate fraud or security incidents; and (c) to a successor or acquirer in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, subject to this Policy.
We do not sell Personal Information, and we do not share Personal Information for cross-context behavioral advertising, as the terms "sell" and "share" are defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), and comparable laws. We have not sold or shared Personal Information in the preceding twelve (12) months. We have no actual knowledge of selling or sharing the Personal Information of consumers under sixteen (16) years of age.
We retain Personal Information only for as long as reasonably necessary for the purposes for which it was collected, subject to the following:
Where we retain information in deidentified form, we maintain it in deidentified form and do not attempt to reidentify it, except as permitted by law.
We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information against loss, theft, and unauthorized access, use, disclosure, alteration, and destruction, including encryption of data in transit and access controls appropriate to the sensitivity of the information. No method of transmission over the internet or of electronic storage is completely secure, and we cannot guarantee absolute security. Where required by applicable law, we will notify affected individuals and the competent authorities of a security breach involving Personal Information.
You may delete your Account at any time in the App under the You tab. Deleting your Account deletes your Account data, subject to the limited retention described in Section 10. Deleting your Account does not cancel an Eltrove Plus subscription billed by Apple; you must cancel the subscription in your Apple ID subscription settings to stop future renewals. You may also request deletion by contacting us as described in Section 20.
This Section applies to residents of California and supplements the other provisions of this Policy.
In the preceding twelve (12) months, we have collected the following categories of Personal Information enumerated in the CCPA, from the sources described in Section 4, for the business purposes described in Section 5, and have disclosed each category for a business purpose to the categories of recipients described in Section 8:
To the extent we process sensitive personal information (such as Account log-in credentials), we do so only for purposes permitted under Cal. Code Regs. tit. 11, § 7027(m), such as providing the Service and ensuring security and integrity, and not for the purpose of inferring characteristics about you. Accordingly, we do not offer a separate right to limit the use of sensitive personal information beyond those permitted purposes.
Subject to the exceptions provided by law, you have the right to:
You may submit a request by emailing support@eltrove.com from the email address associated with your Account, or, for deletion, by deleting your Account in the App. We will verify your request by matching information you provide with information in our records, which may include confirming control of the email address associated with your Account. We will confirm receipt of a request within ten (10) business days and respond within forty-five (45) calendar days, which we may extend by a further forty-five (45) days where reasonably necessary, with notice to you.
You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide signed written permission from you, and may require you to verify your identity directly with us or to confirm that you provided the agent with permission, except where the agent holds a valid power of attorney under California Probate Code §§ 4121 to 4130.
Residents of other U.S. states with consumer privacy laws (including, as applicable, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and others) may have rights to confirm whether we process their Personal Information, to access, correct, delete, and obtain a portable copy of it, and to opt out of the sale of Personal Information, targeted advertising, and profiling in furtherance of decisions producing legal or similarly significant effects. We do not sell Personal Information, engage in targeted advertising, or engage in such profiling. To exercise any applicable right, contact us as described in Section 14.4. If we decline to take action on your request, you may appeal by replying to our decision or emailing support@eltrove.com with the subject line "Privacy Appeal." We will respond to an appeal within the period required by applicable law. If your appeal is denied, you may contact your state attorney general.
This Section applies to residents of Canada, including Quebec, and supplements the other provisions of this Policy, consistent with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and, for residents of Quebec, the Act respecting the protection of personal information in the private sector, as amended by Law 25.
The Service is hosted in the United States, and Personal Information is stored and processed in the United States. By using the Service from outside the United States, you understand that your Personal Information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your jurisdiction. The Service is directed to users in the United States and Canada only and is not directed to individuals in the European Economic Area, the United Kingdom, or Switzerland.
The Service is not directed to children, and you must be at least eighteen (18) years of age to use it. We do not knowingly collect Personal Information from children under thirteen (13) years of age, or from any individual under eighteen (18) years of age. If we learn that we have collected Personal Information from such an individual, we will delete it promptly. If you believe that we may have collected such information, please contact us at support@eltrove.com.
We may amend this Policy from time to time. When we do, we will revise the "Last Revised" date above. If we make a material change, we will provide notice through the Service or by email before the change takes effect, and, where required by applicable law, we will obtain your consent. Your continued use of the Service after a revised Policy takes effect constitutes your acknowledgment of the revised Policy.
For questions regarding this Policy, to exercise your rights, or to contact our Privacy Officer:
Eltrove
Attn: Privacy Officer
Website: https://eltrove.com
Email: support@eltrove.com