Privacy Policy

Last updated: July 5, 2026

Cirvia ("Cirvia", "we", "us", or "our") provides an AI portfolio analysis service for individual investors. This Privacy Policy explains what personal information we collect, why we collect it, how we use, share, and protect it, and the choices and rights you have. It is written to align with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). By creating an account or using Cirvia, you consent to the collection, use, and disclosure of your information as described here.

1. Accountability

Cirvia is responsible for personal information under its control. Questions, requests, and privacy complaints can be directed to our privacy contact at fazalhassan@live.ca.

2. Information we collect

• Account information. When you sign in, our authentication provider stores your email address and a unique account identifier.
• Brokerage holdings data. With your authorization, we retrieve read-only account, position, transaction, and balance information from your connected brokerage through SnapTrade.
• Usage and technical data. We log your interactions with the service (such as questions you ask and digests generated), along with limited technical data (such as timestamps and request metadata) needed to operate and secure it.
• Communications. If you contact us, we keep your messages and contact details to respond.

3. Information we do NOT collect

• Your brokerage username, password, or other login credentials — you authenticate directly with your brokerage inside SnapTrade's secure portal; those credentials never pass through or reach Cirvia.
• Payment card details, if and when paid plans are offered — these would be handled directly by a third-party payment processor, not stored by Cirvia.

4. Purposes and how we use your information

• To provide the service — syncing your holdings, generating your daily digest and macro alerts, and answering your questions.
• To secure, maintain, debug, and improve the service.
• To communicate with you about your account, support requests, and service updates.
• To comply with legal obligations.

We use your information only for the purposes identified here or for which you provide consent. We do not sell your personal information, and we do not use your holdings data for advertising.

5. Consent

We collect, use, and disclose your personal information with your consent. You provide consent by creating an account and by connecting your brokerage. You may withdraw consent at any time by disconnecting your brokerage and/or closing your account (see Section 9); withdrawing consent may limit or end your ability to use the service.

6. Automated processing and AI

Cirvia uses artificial intelligence to generate analysis, summaries, and alerts from your holdings and public market data. This output is informational only and does not constitute automated decision-making that produces legal or similarly significant effects about you. AI output may be inaccurate or incomplete and should not be solely relied upon.

7. Service providers and disclosure

We share the minimum information necessary with service providers that process data on our behalf to operate Cirvia, each bound by their own terms and privacy and security commitments:

• SnapTrade — secure brokerage connectivity (read-only holdings).
• Supabase — authentication and database hosting.
• Anthropic — the AI model that generates analysis (we send relevant portfolio context and public news; we do not send your brokerage credentials).
• Finnhub and other market-data providers — public market and news data.
• Railway — application hosting.

We may also disclose information if required by law, to enforce our Terms, or to protect the rights, property, or safety of Cirvia, our users, or others. If Cirvia is involved in a merger, acquisition, or asset sale, information may be transferred subject to this policy.

8. International storage and transfer

Cirvia and its service providers may store and process your information on servers located in the United States and other countries. As a result, your information may be subject to the laws of those jurisdictions, including lawful access requests by courts or authorities. By using Cirvia, you consent to this transfer, storage, and processing outside your province or country of residence.

9. Retention and deletion

We retain your information for as long as your account is active or as needed to provide the service and meet legal, accounting, or reporting requirements. You may request deletion of your account and associated data at any time by emailing fazalhassan@live.ca; we will delete or de-identify it within a reasonable period, except where retention is required by law. Disconnecting your brokerage stops further data retrieval immediately.

10. Safeguards

• Brokerage credentials are never seen or stored by Cirvia.
• Brokerage connection secrets are encrypted at rest.
• Each account's data is isolated at the database level using row-level security, so one user cannot access another user's information.
• Data is transmitted over encrypted (TLS) connections.

No method of transmission or storage is completely secure. In the event of a data breach that poses a real risk of significant harm, we will notify affected individuals and the appropriate authorities as required by applicable law.

11. Cookies and tracking

Our marketing pages do not use advertising or cross-site tracking cookies. The application uses only the cookies and tokens strictly necessary to keep you signed in and to operate the service securely.

12. Your rights

Subject to applicable law (including PIPEDA), you may request to access, correct, or delete your personal information, and to withdraw consent. To exercise these rights, contact fazalhassan@live.ca. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

13. Children

Cirvia is intended for adults (18+) and is not directed to children. We do not knowingly collect personal information from anyone under 18.

14. Third-party links

Our site and service may link to third-party websites or services (such as SnapTrade). Their privacy practices are governed by their own policies, not this one.

15. Changes to this policy

We may update this policy from time to time. Material changes will be reflected by the "Last updated" date above and, where appropriate, communicated to you. Your continued use after changes take effect constitutes acceptance.

16. Contact

Questions about this policy or your data? Email fazalhassan@live.ca.