Legal & Disclosures

Governing your access to Sinober’s financial-intelligence platform, analytical tools and CFO solutions, and explaining how we collect, use and protect personal information.

Terms of Use

01 · Eligibility
02 · Nature of the Services
03 · Financial Intelligence
04 · Client Control
05 · Independent Decisions
06 · Client Information
07 · AI & Technology
08 · Market Data
09 · Investment Risk
10 · Forward-Looking Information
11 · Accounts & Security
12 · Brokerage Integrations
13 · Third-Party Services
14 · CFO Solutions
15 · Capital Introductions
16 · Fees & Payments
17 · Communications
18 · Intellectual Property
19 · Use Restrictions
20 · Client Content
21 · Privacy
22 · Service Changes
23 · Termination
24 · Disclaimers
25 · Liability
26 · Indemnification
27 · Governing Law
28 · International Users
29 · Changes to Terms
30 · Miscellaneous
31 · Contact

Privacy Policy

01 · Data Controller
02 · Information We Collect
03 · Information Sources
04 · How We Use Data
05 · Financial Data & AI
06 · Legal Bases
07 · Data Disclosure
08 · Data Sharing & Opt-Out
09 · Cookies
10 · Data Retention
11 · Security
12 · Account Credentials
13 · Privacy Rights
14 · Rights Requests
15 · California Privacy
16 · Rhode Island Privacy
17 · U.S. State Privacy
18 · International Rights
19 · Data Transfers
20 · Marketing
21 · Children’s Privacy
22 · Business Clients
23 · De-Identified Data
24 · Financial Privacy
25 · Policy Changes
26 · Contact

Terms of Use

Effective Date: September 8, 2026 | Last Updated: September 8, 2026

These Terms of Use (“Terms”) govern your access to and use of the websites, applications, platforms, dashboards, software, analytical tools, reports, communications, content, and other products and services operated by Sinober Inc. under the Sinober name (collectively, the “Services”).

By accessing or using the Services, creating an account, purchasing or subscribing to a Service, clicking to accept these Terms, or otherwise indicating acceptance, you agree to be bound by these Terms, the Privacy Policy, the Disclosures & Legal Information made available by Sinober, and any additional written agreement applicable to a particular Service. If you do not agree, you must not use the Services.

1. Eligibility

You must be at least 18 years old and legally capable of entering into a binding agreement to use the Services. If you use the Services on behalf of a company, partnership, fund, institution, or other organization, you represent that you have authority to bind that organization to these Terms. Certain Services may be subject to additional eligibility, jurisdictional, financial, accreditation, verification, or regulatory requirements.

2. Nature of the Services

Sinober provides financial intelligence, analytical tools, market research, educational resources, financial and portfolio modeling, corporate-finance analysis, and illustrative investment and capital scenarios designed to support independent decision-making by individuals and businesses.

Depending on the Service, Sinober may use client-provided information, proprietary analytical methodologies, proprietary or third-party AI-assisted tools, market data, third-party information, and human analysis to generate financial intelligence and tailored analytical outputs. The precise scope of a paid Service may also be described in an order form, engagement letter, subscription agreement, statement of work, or other written agreement.

3. Financial Intelligence; No Investment Recommendation or Professional Advice

Unless expressly provided under a separate written agreement through an appropriately authorized person or entity, the Services are intended to provide informational, analytical, and educational support and are not intended to constitute individualized investment, securities, legal, tax, accounting, audit, or other regulated professional advice.

Portfolio allocations, financial models, market views, security analyses, investment scenarios, capital strategies, projections, forecasts, and similar outputs are illustrative or analytical in nature. Nothing made available through the Services should be understood as an instruction, recommendation, offer, or solicitation to purchase, sell, hold, allocate, rebalance, or otherwise transact in any security, financial instrument, digital asset, private investment, or other asset.

You are responsible for independently determining whether any investment, strategy, transaction, or other financial action is appropriate for your circumstances and, where appropriate, for consulting qualified professional advisers.

4. Non-Custodial Model and Client Control

Sinober operates its financial-intelligence services on a non-custodial basis. Sinober does not take possession, custody, ownership, or control of client securities, cash, digital assets, or other financial property through the Investor Program.

You remain in control of your brokerage accounts, bank accounts, digital-asset accounts, custodians, exchanges, and other financial relationships. Unless expressly authorized under a separate agreement and permitted by applicable law, Sinober does not exercise discretionary authority over your accounts and does not independently initiate or execute transactions on your behalf.

5. Independent Decisions, Research, and Transaction Execution

The Services are intended to supplement, not replace, your independent judgment. You are responsible for conducting your own research, analysis, and due diligence before making an investment, capital, or financial decision.

If you choose to act on information made available through the Services, you are responsible for determining whether, when, how, and to what extent to act, including the timing, size, price, structure, venue, method, and execution of any transaction.

Sinober does not control market prices, spreads, liquidity, order routing, execution quality, settlement, brokerage or exchange availability, transaction costs, trading interruptions, or third-party platform availability. Market conditions may change between the time an analysis is prepared and the time you act. To the fullest extent permitted by law, Sinober is not responsible for the execution, timing, pricing, or outcome of a transaction independently undertaken by you.

6. Client Information and Inputs

Certain Services may use information you provide, including investment objectives, portfolio information, risk preferences, financial circumstances, business information, investment horizons, liquidity requirements, assumptions, capital requirements, and other parameters.

You represent that information you provide is accurate, complete to the best of your knowledge, and lawfully provided. You acknowledge that the relevance and accuracy of Sinober’s outputs may depend materially on the quality, completeness, and timeliness of your information. Sinober is not responsible for errors or outcomes resulting from incomplete, outdated, inaccurate, or misleading information supplied by you or on your behalf.

7. Artificial Intelligence and Analytical Technology

Sinober may use proprietary AI tools, quantitative methodologies, automated processes, algorithms, analytical models, and third-party technology to assist with research, portfolio modeling, financial analysis, information processing, and the generation of financial intelligence.

AI-assisted and model-generated outputs may contain errors, omissions, incorrect assumptions, incomplete information, data limitations, or unexpected results. No AI system, model, or analytical methodology can identify every material risk, opportunity, or market development. The Services are designed to support human judgment and independent decision-making, not replace them.

8. Market Data and Third-Party Information

Sinober may use company disclosures, financial statements, market data, research, public records, databases, news sources, client-provided information, and third-party data or technology providers. Although Sinober seeks to use sources it considers appropriate, it does not guarantee that third-party information is complete, accurate, current, or free from error.

Information may be delayed, corrected, revised, restated, or rendered obsolete. Unless expressly agreed otherwise, Sinober is under no obligation to continuously update a previously delivered analysis, model, scenario, opinion, or other output after the date it was prepared.

9. Investment Risk and No Guarantee of Results

Investing and capital allocation involve risk, including the possibility of partial or total loss of principal. Risks may include market, liquidity, credit, interest-rate, currency, concentration, geopolitical, counterparty, regulatory, operational, technology, cybersecurity, valuation, and other risks.

Sinober makes no guarantee or promise regarding investment performance, preservation of capital, profitability, financing availability, fundraising success, achievement of a target return, or any other financial result. Past performance is not a guarantee of future results, and hypothetical, modeled, projected, and forward-looking outcomes may differ materially from actual results.

10. Hypothetical, Illustrative, and Forward-Looking Information

Sinober may provide hypothetical portfolios, asset allocations, forecasts, projections, expected returns, valuation ranges, business cases, financial models, sensitivity analyses, or other forward-looking information. Such information depends on assumptions, estimates, methodologies, market conditions, and judgment that may not materialize.

Hypothetical or modeled results do not represent actual trading results unless expressly identified as such. Any performance-related information should be considered together with the applicable methodology, assumptions, fees, limitations, time period, and risk disclosures.

11. Accounts and Account Security

Certain Services may require an account. You agree to provide accurate registration information and to maintain the confidentiality of your credentials. You are responsible for activity performed through your account to the extent permitted by law and must notify Sinober promptly if you believe your account or credentials have been compromised.

You may not share credentials in a manner that circumvents user limits, subscription restrictions, access controls, or security measures.

12. Brokerage and Financial-Account Integrations

You may not share credentials in a manner that circumvents user limits, subscription restrictions, access controls, or security measures.

13. Third-Party Services

The Services may link to, integrate with, rely upon, or display information from third-party websites, applications, market-data providers, brokers, custodians, banks, exchanges, payment processors, software providers, or other organizations. Sinober does not control those third parties, and their services may be governed by separate terms and privacy policies.

To the fullest extent permitted by law, Sinober is not responsible for the availability, financial condition, cybersecurity, custody practices, accuracy, pricing, execution quality, regulatory compliance, solvency, service interruptions, errors, or acts or omissions of independent third parties.

14. Corporate Finance and CFO Solutions

Sinober may provide businesses with financial intelligence and strategic support relating to treasury management, cash and liquidity management, financial analysis, capital allocation, capital strategy, business planning, fundraising preparation, transaction assessment, and related corporate-finance matters.

Unless expressly agreed otherwise and legally authorized, these Services do not constitute legal, tax, accounting, audit, underwriting, broker-dealer, placement-agent, or regulated investment-advisory services. Sinober does not guarantee the completion or outcome of any financing transaction, capital raise, acquisition, investment, restructuring, liquidity event, or other business objective.

15. Capital Introductions and Private Opportunities

Where legally permissible, Sinober may assist businesses with financing strategy, preparation of financial materials, capital-structure analysis, transaction preparation, and introductions to potential investors, lenders, financial institutions, or other capital providers.

Nothing appearing generally on the Services constitutes an offering or general solicitation of securities. Any private investment, fund, financing, or securities transaction may be governed by separate offering documents, eligibility or verification requirements, confidentiality obligations, risk disclosures, investor representations, and applicable securities laws.

Sinober will not undertake activity requiring broker-dealer, placement-agent, investment-adviser, or other regulatory registration except through an appropriately registered or authorized person or entity, or where an applicable exemption or other lawful basis permits the activity.

16. Subscriptions, Fees, and Payments

Prices and payment terms are those displayed at purchase or stated in the applicable agreement. You agree to pay applicable fees and taxes when due.

If a subscription automatically renews, the renewal term, billing frequency, price or method for determining the price, and cancellation method will be disclosed at or before purchase. Sinober may change pricing for future billing periods upon notice where required by law.

Fees already earned or relating to Services already provided may be non-refundable except where the applicable agreement or law provides otherwise. Third-party payment processors may process payments on Sinober’s behalf and may impose their own terms.

17. Electronic Communications

You consent to receive contractual notices, account communications, disclosures, invoices, and other service-related communications electronically. Marketing communications may be sent where permitted by law and may be discontinued through the unsubscribe method provided. You are responsible for maintaining accurate contact information.

18. Intellectual Property

The Services and their contents, including Sinober’s software, analytical frameworks, methodologies, financial models, research, reports, interfaces, branding, graphics, databases, designs, and proprietary technology, are owned by or licensed to Sinober and are protected by applicable intellectual-property laws.

Subject to these Terms and any applicable paid subscription or engagement, Sinober grants you a limited, personal or internal-business, non-exclusive, non-transferable, non-sublicensable, and revocable right to access and use the Services for their intended purpose. No ownership rights are transferred to you.

19. Restrictions on Use

You may not, except as expressly authorized or where prohibited by law from restricting such conduct:

copy, scrape, reproduce, republish, redistribute, resell, sublicense, or commercially exploit Sinober’s proprietary content or outputs;
reverse engineer, decompile, disassemble, or attempt to discover source code, model weights, proprietary algorithms, non-public methodologies, or security controls;
use automated systems to access the Services in a manner that interferes with their operation, circumvents technical restrictions, or imposes an unreasonable load;
use the Services for unlawful, fraudulent, manipulative, abusive, or deceptive conduct, including market manipulation, insider trading, sanctions evasion, or infringement of another person’s rights; or
misrepresent Sinober content as your own research, remove proprietary notices, or use the Services to build a competing product through systematic extraction of proprietary materials.

20. Client Content and Confidentiality

You retain ownership of information and materials you submit to Sinober. You grant Sinober a limited right to host, process, analyze, reproduce, and otherwise use submitted information as reasonably necessary to provide, secure, administer, and improve the Services, fulfill contractual obligations, comply with law, and exercise or defend legal rights.

Information designated confidential, or that reasonably should be understood as confidential, will be handled using reasonable safeguards and in accordance with applicable agreements and law. More specific confidentiality obligations in a signed nondisclosure agreement or client agreement will control where applicable.

You must not provide Sinober with material nonpublic information concerning publicly traded securities unless disclosure is authorized, necessary for a legitimate engagement, and handled under appropriate confidentiality and compliance procedures.

21. Privacy

Sinober’s collection and use of personal information are governed by the Privacy Policy included in this document and any supplemental privacy notice applicable to a particular Service or jurisdiction.

22. Service Availability and Changes

Sinober may modify, improve, update, suspend, or discontinue features of the Services from time to time. Sinober does not guarantee uninterrupted or error-free availability. Maintenance, security incidents, market-data interruptions, third-party outages, legal requirements, and circumstances beyond Sinober’s reasonable control may affect availability.

Where a material change affects a paid Service, Sinober will provide notice where required by the applicable agreement or law.

23. Suspension and Termination

Sinober may suspend or terminate access where reasonably necessary to address fraud, misuse, security concerns, violation of these Terms, non-payment, legal or regulatory obligations, or risks to Sinober, other users, or third parties.

You may stop using the Services at any time, subject to applicable subscription, payment, or engagement obligations. Provisions that by their nature should survive termination, including intellectual-property, confidentiality, risk, limitation-of-liability, indemnification, and dispute provisions, will survive.

24. Disclaimer of Warranties

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE.” SINOBER DISCLAIMS WARRANTIES, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, EXCEPT TO THE EXTENT SUCH WARRANTIES CANNOT LAWFULLY BE DISCLAIMED.

Sinober does not warrant that information will always be accurate, complete, current, uninterrupted, secure, or error-free, or that the Services will identify every relevant financial risk or opportunity. Nothing in this section limits rights or remedies that cannot lawfully be waived.

25. Limitation of Liability

To the fullest extent permitted by applicable law, Sinober Inc. and its affiliates, directors, officers, employees, contractors, and service providers will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits, lost investment opportunities, loss of business, or loss of data arising out of or relating to the Services.

To the fullest extent permitted by law, Sinober will not be responsible for losses arising from independent financial or investment decisions, market movements, execution timing or pricing, liquidity, third-party brokers or custodians, client-provided information, technology failures, or circumstances outside Sinober’s reasonable control.

Except for liabilities that cannot lawfully be limited, Sinober’s aggregate liability arising out of or relating to the Services will not exceed the greater of (a) the fees actually paid by you to Sinober for the applicable Service during the twelve months preceding the event giving rise to the claim or (b) US$100. Nothing in these Terms excludes or limits liability where such exclusion or limitation is prohibited by applicable law.

26. Indemnification

To the extent permitted by law, you agree to defend, indemnify, and hold harmless Sinober Inc. and its affiliates, directors, officers, employees, and service providers from third-party claims, liabilities, losses, and reasonable costs arising from your unlawful use of the Services, material violation of these Terms, infringement of another person’s rights, or material misrepresentation of information supplied by you. This provision does not require indemnification for conduct for which indemnification cannot lawfully be required.

27. Governing Law and Venue

These Terms are governed by the laws of the State of Delaware, without regard to conflict-of-law principles, except to the extent mandatory law provides otherwise. Subject to any non-waivable rights or jurisdictional requirements, the state and federal courts located in Delaware will have exclusive jurisdiction over disputes arising out of or relating to these Terms or the Services, and you consent to personal jurisdiction and venue in those courts.

28. International Users and Geographic Restrictions

The availability of the Services in a country or region does not mean that every Service is authorized, appropriate, or available there. Sinober may restrict or discontinue access to a Service in a jurisdiction where required by law or reasonably necessary for legal, regulatory, operational, or risk-management reasons. Users are responsible for complying with laws applicable to them.

29. Changes to These Terms

Sinober may update these Terms from time to time. Material changes will be communicated in a manner appropriate to the nature of the change and as required by law. The Last Updated date identifies the most recent revision. Continued use of the Services after revised Terms become effective constitutes acceptance where legally permissible.

30. Miscellaneous

If any provision of these Terms is determined to be invalid or unenforceable, the remaining provisions will remain effective to the fullest extent permitted by law. Failure to enforce a provision is not a waiver.

You may not assign or transfer your rights under these Terms without Sinober’s prior written consent, except where applicable law provides otherwise. Sinober may assign these Terms in connection with a merger, financing, restructuring, acquisition, sale of assets, or other corporate transaction.

These Terms, together with the Privacy Policy, Disclosures & Legal Information, and any applicable written service agreement, constitute the agreement governing your use of the Services. If a specific written agreement conflicts with these Terms, the specific written agreement will control to the extent of the conflict and as permitted by law.

31. Contact

Questions regarding these Terms may be sent to:

Sinober Inc.
legal@sinober.com

Privacy Policy

Effective Date: September 8, 2026 | Last Updated: September 8, 2026

Sinober Inc. respects the privacy of clients, prospective clients, website visitors, business contacts, and other users. This Privacy Policy explains how Sinober Inc. (“Sinober,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information when individuals access or use our websites, applications, platforms, dashboards, communications, and related Services.

This Privacy Policy should be read together with the Terms of Use, the Disclosures & Legal Information, and any supplemental privacy notice or written agreement applicable to a particular Service.

1. Data Controller and Contact

Sinober Inc. is the controller of personal information covered by this Privacy Policy except where a supplemental notice identifies another entity or relationship.

Questions, privacy requests, and other communications regarding this Privacy Policy may be sent to legal@sinober.com.

2. Personal Information We Collect

Depending on how you interact with Sinober and which Services you use, we may collect the following categories of personal information:

Identification and contact information. Name, email address, telephone number, country or region, mailing address, organization, job title, and other contact information.
Account and authentication information. Username, account identifier, authentication information, account preferences, subscription level, and service history.
Financial profile and investment information. Information you voluntarily provide such as investment objectives, stated risk preferences, investment horizon, asset-class preferences, portfolio holdings, approximate portfolio value, liquidity considerations, financial goals, and other portfolio or financial information.
Connected financial-account information. Where you choose to connect a supported broker, custodian, bank, exchange, or financial platform, Sinober or an integration provider may receive account identifiers, balances, holdings, positions, transaction data, and related information that you authorize the provider to make available.
Business and corporate-finance information. Financial statements, cash-flow information, forecasts, capital structures, treasury information, budgets, business plans, financing requirements, transaction data, corporate information, and other records supplied in connection with CFO Solutions or other business Services.
Identity and compliance information. Where required for a particular Service or transaction, information used for identity verification, eligibility, accreditation, sanctions screening, anti-money-laundering checks, or other legal or compliance purposes, including government-issued identification where necessary and lawful.
Communications. Emails, meeting information, support requests, feedback, survey responses, and other communications you send to us.
Payment and billing information. Billing details, payment status, invoice records, transaction identifiers, and limited payment information made available by payment processors. Full payment credentials may be collected and processed directly by third-party payment providers.
Technical and usage information. IP address, device type, browser, operating system, approximate location derived from IP, referring pages, pages or features viewed, timestamps, interactions, security logs, and diagnostic information.
Cookies and similar technologies. Information collected through cookies, pixels, local storage, software development kits, and similar technologies used for essential functionality, preferences, security, analytics, and, where applicable, marketing.
Derived information and inferences. Portfolio characteristics, risk indicators, analytical results, classifications, investment scenarios, or other inferences generated from information processed through the Services where such information relates to an identifiable individual.

3. Sources of Personal Information

We may obtain personal information directly from you; from an organization you represent; from connected financial institutions or platforms at your direction; from service providers; from payment processors; from publicly available sources; from market-data or business-information providers; and from your interactions with the Services.

Where required by applicable law, we will provide additional information regarding the source and categories of personal information obtained indirectly.

4. How We Use Personal Information

Sinober may use personal information for the following purposes:

to provide, operate, administer, and personalize the Services;
to generate requested financial intelligence, analytical outputs, portfolio analyses, financial models, and business analyses using client-supplied parameters;
to authenticate users, secure accounts, detect fraud or misuse, and maintain platform integrity;
to process subscriptions, invoices, payments, and related records;
to provide customer support and respond to requests or communications;
to operate financial-account connectivity and other integrations requested by users;
to maintain, test, develop, and improve Sinober’s systems, analytical methodologies, features, and user experience;
to conduct internal analytics, quality assurance, and service-performance measurement;
to comply with legal, regulatory, tax, accounting, security, recordkeeping, or contractual obligations;
to establish, exercise, or defend legal rights and claims;
to manage corporate transactions such as financings, reorganizations, mergers, acquisitions, or asset transfers; and
where permitted by law, to send market commentary, educational content, product updates, company news, press information, and other marketing communications.

5. Financial Information, AI, and Automated Processing

Sinober may use AI-assisted tools, quantitative methods, algorithms, and analytical models to process information and generate financial intelligence. Such processing may include the analysis of client-selected parameters, financial objectives, portfolio data, business information, and market data.

Sinober’s core analytical Services are designed to support human and client decision-making and are not intended to make solely automated decisions that produce legal or similarly significant effects on individuals.

Sinober does not use confidential client financial information, identifiable portfolio information, or confidential business information to train general-purpose AI models for use by unrelated customers unless the client authorizes that use or the information has been de-identified so that it cannot reasonably identify the client. Sinober may use aggregated or de-identified information to improve its Services, methodologies, and technology.

AI and automated systems can produce inaccurate, incomplete, or unexpected results. The use of AI does not alter the responsibilities, limitations, and risk disclosures applicable to the Services.

6. Legal Bases for Processing

Where applicable law requires a legal basis for processing personal information, Sinober may rely on one or more of the following:

performance of a contract or steps requested before entering into a contract;
Sinober’s legitimate interests in operating, securing, supporting, and improving the Services, preventing misuse, communicating with clients, and managing legitimate business operations, where those interests are not overridden by applicable privacy rights;
consent, where you have voluntarily agreed to specific processing and consent is legally required or appropriate;
compliance with legal, regulatory, court, law-enforcement, or other lawful obligations; and
establishment, exercise, or defense of legal claims or protection of the rights, property, and security of Sinober, its users, or others.

Where processing is based on consent, you may withdraw consent at any time, subject to applicable law and without affecting the lawfulness of processing that occurred before withdrawal.

7. How We Disclose Personal Information

Sinober may disclose personal information to the following categories of recipients where reasonably necessary and permitted by law:

Service providers. Cloud hosting, cybersecurity, data storage, software, analytics, customer-support, communications, payment-processing, identity-verification, and other providers that assist Sinober in operating the Services.
Financial institutions and integration providers. Brokers, custodians, banks, exchanges, and connectivity providers when you request account connectivity or related functionality.
Professional advisers. Lawyers, accountants, auditors, compliance advisers, insurers, and other advisers where reasonably necessary.
Affiliates. Sinober-affiliated entities where necessary to provide Services or operate the business, subject to applicable law and confidentiality obligations.
Corporate-transaction participants. Potential or actual investors, lenders, purchasers, acquirers, counterparties, and advisers in connection with a financing, merger, acquisition, restructuring, sale of assets, or similar transaction, subject to appropriate protections.
Governmental and legal recipients. Courts, regulators, law-enforcement authorities, governmental bodies, and other parties where disclosure is required or permitted by law or reasonably necessary to protect legal rights or security.
Recipients at your direction. Third parties when you request, direct, or expressly authorize disclosure.

Sinober does not sell personal information for monetary consideration.

Sinober may use analytics, advertising, or social-media technologies that, depending on the technology and applicable law, may be treated as “sharing” of personal information or processing for targeted advertising even when no money is exchanged. Where required by law, Sinober will provide an applicable opt-out mechanism and will honor legally recognized opt-out preference signals, such as Global Privacy Control, to the extent required.

Sinober does not sell confidential client financial information or confidential business information to data brokers or unrelated third parties for their independent marketing use.

9. Cookies and Similar Technologies

Sinober may use strictly necessary cookies and similar technologies for login, authentication, security, session management, and essential functionality; preference technologies to remember settings; analytics technologies to understand use of the Services; and, where used, marketing technologies to measure or support promotional activity.

Where consent is legally required, non-essential cookies will be used only after the required consent is obtained. Where available, users may review or modify cookie choices through Sinober’s cookie-preference controls. Browser and device settings may also allow users to limit certain technologies, although doing so may affect functionality.

10. Data Retention

Sinober retains personal information for no longer than reasonably necessary for the purposes for which it was collected, including providing Services, maintaining client and transaction records, satisfying contractual, tax, legal, regulatory, security, and compliance obligations, resolving disputes, preventing fraud, and enforcing agreements.

Retention periods vary depending on the nature and sensitivity of the information, the duration of the client relationship, applicable legal requirements, and legitimate business needs. When information is no longer required, Sinober will delete, anonymize, or otherwise dispose of it in accordance with applicable law and internal retention practices.

11. Information Security

Sinober uses administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, loss, or misuse. Depending on the nature of the information and Services, safeguards may include access controls, authentication, encryption, secure infrastructure, monitoring, logging, vendor controls, backups, and incident-response procedures.

No internet-based system or method of storage can guarantee absolute security. Users are responsible for protecting their credentials and should notify Sinober promptly of suspected unauthorized account activity.

12. Financial-Account Credentials

Where financial-account connectivity is offered, Sinober seeks to use secure institution or integration-provider authentication where technically available. Sinober does not require users to provide brokerage, bank, custodian, or exchange credentials directly to Sinober unless expressly disclosed and necessary for a supported integration.

Displaying, importing, or analyzing financial-account information does not give Sinober custody or ownership of the underlying assets.

13. Your Privacy Rights

Depending on your location and the law that applies, you may have rights to:

confirm whether Sinober processes your personal information and obtain access to certain information;
receive a copy of personal information in a portable format where required;
correct inaccurate personal information;
request deletion of personal information, subject to legal exceptions;
restrict or object to certain processing;
withdraw consent where processing is based on consent;
opt out of sale, sharing, targeted advertising, or certain profiling or automated decision-making where applicable;
limit certain uses or disclosures of sensitive personal information where applicable; and
appeal a decision concerning a privacy request where applicable.

Sinober will not unlawfully discriminate against an individual for exercising applicable privacy rights.

14. How to Exercise Privacy Rights

Privacy requests may be submitted to legal@sinober.com. Please describe the right you wish to exercise and provide sufficient information for Sinober to identify the relevant account or records.

Sinober may verify your identity before fulfilling a request and may request additional information where reasonably necessary for verification. Authorized agents may submit requests where permitted by law, subject to appropriate verification of their authority.

If applicable law provides a right to appeal a privacy-request decision, an appeal may be submitted to legal@sinober.com with the subject line “Privacy Appeal.”

15. California Privacy Notice

This section applies to California residents to the extent the California Consumer Privacy Act, as amended, applies to Sinober’s processing.

Sinober may collect the categories of personal information described in this Privacy Policy, including identifiers, customer-record information, commercial and financial information supplied by users, internet or electronic activity information, professional information, sensitive personal information where necessary, and inferences generated through financial analysis.

Sinober collects this information from the sources and for the purposes described in this Privacy Policy and may disclose it to the categories of recipients described above.

Subject to applicable exceptions, California residents may have rights to know or access personal information, correct inaccurate information, request deletion, receive information regarding collection and disclosure practices, opt out of sale or sharing, limit certain uses of sensitive personal information, and exercise rights applicable to automated decision-making. Sinober will honor applicable opt-out preference signals where required by law.

16. Rhode Island Privacy Rights

To the extent the Rhode Island Data Transparency and Privacy Protection Act applies to Sinober’s processing, eligible Rhode Island residents may have rights including access, correction, deletion, data portability, and opt-outs relating to targeted advertising, sale of personal data, and certain profiling.

Sinober will process valid Rhode Island privacy requests in accordance with applicable law. Certain financial institutions, affiliates, and information subject to specified federal financial-privacy laws may be exempt from some state-law requirements.

17. Other U.S. State Privacy Rights

Residents of other U.S. states may have privacy rights where Sinober is subject to the applicable state privacy law. Sinober will process valid requests in accordance with the law that applies, including any applicable right to appeal a denial or opt out of targeted advertising, sale, sharing, or certain profiling.

18. EEA, United Kingdom, and Similar International Rights

Where the European Union General Data Protection Regulation, United Kingdom data-protection law, or similar legislation applies, individuals may have rights to access, correct, erase, restrict, or object to processing; receive certain information in portable form; withdraw consent; and lodge a complaint with an applicable supervisory authority.

Where required, Sinober will provide information regarding the applicable legal basis for processing, recipients, retention, international transfers, and any additional rights required by law.

19. International Data Transfers

Sinober and its service providers may process information in countries other than the country in which an individual resides. Those countries may have different data-protection laws.

Where applicable law requires safeguards for international transfers, Sinober will use an appropriate lawful transfer mechanism, which may include adequacy decisions, approved contractual safeguards, or other mechanisms recognized by applicable law.

20. Marketing Communications

Where permitted by law and, where required, with consent, Sinober may send market commentary, educational materials, company news, press information, product updates, and similar communications.

You may unsubscribe from promotional emails through the unsubscribe mechanism included in those communications or by contacting legal@sinober.com. You may continue to receive transactional, account, security, legal, or service-related communications where necessary.

21. Children's Privacy

The Services are intended for adults and are not directed to individuals under 18. Sinober does not knowingly seek to collect personal information from children through the Services. If Sinober learns that personal information from a child has been collected contrary to applicable law, Sinober will take appropriate steps to delete or otherwise address the information.

22. Business Clients and Third-Party Personal Information

Business clients may provide information concerning employees, owners, directors, customers, counterparties, or other individuals. The business client is responsible for having an appropriate legal basis or authority and for providing any notices required before supplying such personal information to Sinober.

Sinober will process such information for the purposes of the applicable engagement, as described in this Privacy Policy, and as otherwise permitted by law.

23. De-Identified and Aggregated Information

Sinober may create aggregated, statistical, or de-identified information that does not reasonably identify an individual. Where required by law, Sinober will maintain such information in de-identified form and will not attempt to re-identify it except where legally permitted for purposes such as validating de-identification methods.

Aggregated and properly de-identified information may be used for analytics, research, security, service improvement, and development of financial-intelligence methodologies and technology.

24. Additional Financial-Privacy Notices

Certain Services, data, or relationships may be subject to additional privacy notices required by financial-services, consumer-protection, or other applicable laws. Where Sinober provides a supplemental privacy notice for a particular Service or category of information, that notice will apply to the extent of any conflict with this general Privacy Policy.

25. Changes to This Privacy Policy

Sinober may update this Privacy Policy as its Services, technology, legal requirements, and privacy practices evolve. If a change materially affects how personal information is used, Sinober will provide appropriate notice and seek consent where required by law. The Last Updated date identifies the most recent revision.

26. Contact

For questions about this Privacy Policy, Sinober’s data practices, or to exercise applicable privacy rights, contact:

Sinober Inc.
legal@sinober.com