d/b/a HiLo Finance
Effective Date: September 2, 2026 | Version: 3.0 | Last Updated: September 22, 2026
This Privacy Policy reflects HiLo Finance's product architecture: in-house real-time chat (no third-party chat vendor), public stock/options discussion groups, stock and options symbol tagging in chat, Mentor-provided trade ideas with optional SnapTrade brokerage verification, market/options data and news from Massive, Twelve Data, Alpha Vantage, and Benzinga, and mobile (iOS/Android) and desktop (Windows/macOS) applications. Sections 4 and 5 describe Podcasts and Audiorooms, which are included in this Policy in advance of launch and are NOT YET ENABLED on the Platform; HiLo will provide notice before either feature becomes active.
HiLo Platform Inc., a Delaware corporation, doing business as HiLo Finance ("HiLo," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile and desktop applications, available on iOS, Android, Windows, and macOS (collectively, the "App" or "Platform"). By using the Platform, you consent to the data practices described in this Policy.
California Residents: If you are a California resident, additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), apply. See Section 11 below.
Some of what we collect is "sensitive personal information" under California law: the contents of your Direct Messages (which we store but are not the intended recipient of) and, for Mentors who connect a brokerage account, SnapTrade account tokens, brokerage authorization references, and trade execution data. We use sensitive personal information only to provide the Platform, verify Mentor trade alerts, keep the Platform secure, and comply with law. We do not use it to infer characteristics about you and do not sell or share it. Because we use it only for these purposes, California law does not require us to offer a separate "Limit the Use of My Sensitive Personal Information" option.
We use automated tools, including machine-learning models, to moderate content, detect fraud and market manipulation, tag symbols, and generate displays from Platform content and market data. We do not use your content to train AI models. Content processed by AI features (public chat messages for sentiment and symbol tags, market data, and questions you ask the HiLo AI Agent) is sent to xAI, Inc., which under our zero-data-retention configuration and its terms does not train on it and does not retain it after processing. Market briefing text is sent to ElevenLabs, Inc. for synthetic audio. The contents of Direct Messages are not processed by AI features. We do not provide your personal information to third parties for their own model training, and we do not make decisions with legal or similarly significant effects about you using solely automated means.
The Platform includes Public Chats: stock- and market-focused discussion groups that any user may create or join. Public Chats are moderated by group admins and moderators, who set group-specific rules, approve or remove members, and remove content or members that violate those rules or our Terms of Service. Admins and moderators need not be HiLo staff or Mentors — any user granted moderator status for a given group may act in that role for that group only.
No expectation of privacy in Public Chats. Messages you post in a Public Chat, including any stock or options ticker symbols you tag, are visible to all current members of that group and may remain visible to future members and moderators. Do not post information in a Public Chat that you do not want seen by other members of that group.
Symbol tags are not verified. Tagging a stock or option symbol in a chat message is a user-generated annotation. HiLo does not verify, endorse, or curate tagged content, and a tag does not constitute a recommendation by HiLo.
Moderator and admin access. Group admins and moderators can see messages posted within groups they moderate for the purpose of enforcing group rules. Because moderators are ordinary users (not HiLo personnel), HiLo does not treat moderator access as HiLo employee access; HiLo may still retain moderation logs (removed messages, removed members, and the reason) for trust-and-safety and legal-compliance purposes even after removal from general view.
HiLo platform-level oversight. Independent of group-level moderation, HiLo may review, restrict, or remove any Public Chat content or group at its discretion, including for suspected market manipulation, coordinated inauthentic behavior, or legal/regulatory risk.
This Section describes HiLo's planned Podcasts feature, included here for advance legal review. Podcasts are NOT currently enabled on the Platform. HiLo will update this Policy's effective date and provide in-app notice before Podcasts becomes active.
What we will collect. If you publish a podcast, we will collect the audio files, show notes, artwork, titles, and descriptions you upload, and, if applicable, sponsor/advertiser information you disclose in your episodes. If you listen to podcasts, we will collect listening activity (episodes played, duration) associated with your account.
Hosting. Podcast audio and related files will be hosted using Cloudflare (Cloudflare, Inc.) infrastructure.
Advertising. HiLo may display advertisements on Podcasts listing/browse pages (not injected into episode playback) and may share a portion of related ad revenue with podcasters, subject to a separate Podcaster Agreement.
Sponsor content. Podcasters may include sponsored segments within their own episodes; HiLo requires disclosure of paid/sponsored content under the Podcaster Agreement, but does not independently verify every sponsor claim.
This Section describes HiLo's planned Audiorooms feature (live audio discussions), included here for advance legal review. Audiorooms are NOT currently enabled on the Platform. HiLo will update this Policy's effective date and provide in-app notice before Audiorooms becomes active.
What we will collect. If you host or speak in an Audiorooms session, we will collect your live audio, which may be recorded and retained for content-moderation, trust-and-safety, and legal/regulatory compliance purposes, even though the room itself is live and time-bound. By hosting, speaking in, or joining a session you consent to being recorded.
Visibility. Audio in an Audiorooms session is audible to all room participants in real time; recordings, if made, will be accessible to HiLo's Trust & Safety team and may be produced in response to legal process.
Moderation. Room hosts and HiLo may remove participants or end a session for violations of the Terms of Service, including suspected market manipulation or unlicensed investment advice conducted live.
We do not sell your personal information to third parties. We share data with the service providers below, each of which is contractually required to protect your data and use it only for the specified purpose. Each is a "service provider" or "contractor" under California law and may not use your information for its own purposes.
| Provider | Purpose | Data Shared |
|---|---|---|
| SnapTrade (Passiv Inc.) | Optional brokerage account connectivity for Mentors, used to verify that posted trade alerts match real executed trades | Mentor-only: SnapTrade user ID/secret, brokerage authorization references, trade execution records (symbol, side, price, quantity, timestamp, order ID, account ID). Login credentials are never shared with HiLo. |
| Stripe, Inc. | Subscription billing and payment processing for Web Payment subscriptions | Name, email, billing address, payment method (tokenized) |
| Apple Inc. | In-App Purchase billing for subscriptions purchased on iOS | Transaction/receipt identifier and subscription status; Apple, not HiLo, holds your payment method |
| Google LLC | Google Play Billing for subscriptions purchased on Android | Transaction/receipt identifier and subscription status; Google, not HiLo, holds your payment method |
| Twilio Inc. | Phone number verification via SMS one-time password | Phone number |
| Mixpanel, Inc. | Product usage analytics | Device ID, in-app events (anonymized) |
| Sentry (Functional Software, Inc.) | Error monitoring and crash/performance diagnostics | Device/OS info, stack traces, anonymized technical logs |
| MongoDB Atlas (MongoDB, Inc.) | Primary application database (managed cloud service), including chat messages, trade alerts, and account data | All categories of information described in Section 1 |
| Amazon Web Services, Inc. | Cloud hosting and caching (ElastiCache) for market data | Market data cache; application infrastructure logs |
| Cloudflare, Inc. (R2 storage) | Storage of user-uploaded media (profile pictures, photos, and videos you upload or share in chats), and podcast audio/artwork once Podcasts is enabled (see Section 4) | Uploaded photos, videos, and profile pictures; podcast audio files, artwork, and metadata |
| xAI, Inc. | AI features (movement reasons, earnings recaps, financial summaries, market briefing text, public chat sentiment and symbol tags, HiLo AI Agent) | Public chat message text, market data, and questions you ask the AI Agent. Zero data retention: not stored or used for training by xAI |
| ElevenLabs, Inc. | Synthetic voice audio for the twice-daily market briefing | Briefing text only; no personal information |
6.1 Legal requirements. We may disclose your information if required by law, regulation, or legal process, including subpoenas, court orders, government requests, and SEC, FINRA, CFTC, or state securities regulator inquiries.
6.2 Business transfers. If HiLo is involved in a merger, acquisition, or asset sale, your information may be transferred to the acquiring entity, and you will be notified via email or in-app notice.
6.3 Other users and Mentors. Your username, profile information, and the content you post are visible to other users as described in Section 3. A Mentor you subscribe to can see your username and the messages you send in that Mentor's channel or in Direct Messages with the Mentor. Mentors are independent and may use that information only to provide their content on the Platform; they are not permitted to export it or contact you off-Platform. If you are a Mentor and opt in, your connected brokerage holdings, portfolio value, and returns are displayed on your profile to users who view it, and your Transparency Score (based on verification rate, posting consistency, and activity) is displayed publicly.
No system is 100% secure. Despite our efforts, no data transmission or storage system is completely secure, and you acknowledge this inherent risk by using the Platform.
9.1 Access, right to know, and correction. You may access and update most of your profile information within the App. You may also request a copy of the personal information we hold about you, including the categories and specific pieces, the sources, the purposes, and the categories of third parties we disclosed it to, and request correction of inaccurate information, by emailing privacy@hilo.finance. We will verify your identity, usually by confirming control of the phone number or email on your account, and respond within 45 days (extendable once by 45 days with notice).
9.2 Data deletion. You may delete specific content or your entire account and associated personal data at any time via in-app account-deletion tools, or by emailing privacy@hilo.finance. We will complete deletion within 30 days, except where retention is required by law or is necessary to preserve the integrity of a Public Chat for other members (see Section 8).
9.3 Marketing opt-out. Unsubscribe via any marketing email, in-app settings, or by emailing privacy@hilo.finance.
9.4 Push notification opt-out. Disable push notifications in device settings or in the App.
9.5 Sale, sharing, and targeted advertising. We do not sell your personal information, share it for cross-context behavioral advertising, or use it for targeted advertising. If we begin displaying third-party advertising (see Section 4), we will add a "Do Not Sell or Share My Personal Information" option and honor Global Privacy Control browser signals before any such sharing starts.
9.6 Appeals. If we deny a privacy request, you may appeal by replying to our decision. We will respond within 45 days and, if we still deny the request, tell you how to contact your state attorney general.
The Platform is not intended for users under 18. We do not knowingly collect personal information from children. If you believe a child under 18 has provided us with personal information, contact privacy@hilo.finance and we will delete the account.
If you are a California resident, you have the right to: (a) know the categories and specific pieces of personal information we have collected about you; (b) delete personal information we have collected from you, subject to certain exceptions; (c) correct inaccurate personal information; and (d) non-discrimination for exercising your rights. We do not sell personal information, and do not currently share personal information for cross-context behavioral advertising as defined by the CPRA; if that changes, this Policy will be updated with an opt-out mechanism before any such sharing begins.
In the last 12 months we have collected these categories of personal information: identifiers (name, username, phone number, email, device identifiers, IP address); commercial information (subscription and payment history); internet or network activity (usage and log data); approximate geolocation derived from IP address; audio (Audiorooms recordings, once enabled); the content you post and send; professional information you choose to provide (trading experience); financial information (Mentors only: SnapTrade trade execution data); and the sensitive personal information described in Section 1.4. We collect it from you, from your device, and (for Mentors) from SnapTrade. We use it for the purposes in Section 2, disclose it for business purposes to the service providers in Section 6, and retain it for the periods in Section 8. We do not use or disclose sensitive personal information for purposes beyond those permitted by California law.
To exercise your rights to know, delete, or correct, email privacy@hilo.finance or use the in-app account-deletion tool for deletion requests. We will verify your identity and respond within the time required by law. You may designate an authorized agent to submit a request on your behalf by providing written authorization.
11.1 Other U.S. state privacy rights. If you live in Virginia, Colorado, Connecticut, Texas, Oregon, or another state with a consumer privacy law, you have similar rights to access, correct, delete, and obtain a copy of your personal information and to opt out of targeted advertising, sales, and profiling for significant decisions (none of which we currently do). Use the contact methods in Section 9. You may appeal a denial as described in Section 9.6.
The Platform is operated from the United States. If you access the Platform from outside the U.S., your information will be transferred to, stored, and processed in the U.S., which may not have data protection laws as comprehensive as your home country.
The Platform may contain links to third-party websites or services (including brokerage platforms accessed via SnapTrade, or Massive/Twelve Data/Alpha Vantage/Benzinga content). We are not responsible for the privacy practices of third parties, and encourage you to review their privacy policies.
We may update this Policy from time to time. Minor changes are effective immediately upon posting; material changes are effective 30 days after notice via email or in-app notification. Continued use of the Platform after changes take effect constitutes acceptance. We review this Policy at least once every 12 months and update the "Last updated" date above when we change it.
HiLo Platform Inc. (d/b/a HiLo Finance) — San Jose, CA 95118 — United States
Privacy inquiries: privacy@hilo.finance | General support: support@hilo.finance