Data Processing Terms

1. Scope and Purpose

These Data Processing Terms ("Terms") govern the collection, processing, storage, and deletion of financial data synced from your brokerage account(s) through our integration with SnapTrade. These Terms supplement—and do not replace—the WealthEngine Pro Privacy Policy and Terms of Service. In the event of a conflict between these Terms and the Privacy Policy regarding brokerage data, these Terms control.

These Terms apply only to data obtained through the SnapTrade brokerage integration. Data you enter manually into the Portfolio Tracker (such as manually added accounts, positions, or transactions) is governed by our Privacy Policy and Terms of Service.

2. Data We Collect via SnapTrade

When you authorize a brokerage connection, we collect and store the following categories of data from your brokerage through SnapTrade:

We do not collect: Your brokerage login credentials (username, password, MFA codes), Social Security number, bank account or routing numbers, tax documents, beneficiary information, or any data not explicitly listed above.

3. How We Process Brokerage Data

3.1 Permitted Uses

Your brokerage data is processed exclusively for the following purposes:

• Portfolio Display: Presenting your holdings, positions, and account balances in the WealthEngine Pro Portfolio Tracker interface.
• Performance Calculations: Computing portfolio returns (daily, weekly, monthly, cumulative), comparing performance against benchmarks (SPY, QQQ), and tracking premium income from options positions.
• Snapshot History: Storing daily portfolio snapshots to generate performance charts and historical tracking over time.
• Account Aggregation: Combining data across your linked brokerage accounts to present a consolidated portfolio view, if you link multiple accounts.
• Sync Status Tracking: Monitoring the health and freshness of your brokerage connection (last sync time, connection status, error states) to ensure data accuracy.

3.2 Prohibited Uses

We do not and will not use your brokerage data to:

• Generate personalized trade ideas, trade suggestions, or investment recommendations based on your individual portfolio holdings
• Provide portfolio-specific analysis that differs from the universal research published to all subscribers
• Share, sell, rent, or disclose your brokerage data to any third party (except as required by law)
• Use your holdings data for advertising, marketing, or profiling purposes
• Execute trades, place orders, or take any action in your brokerage account
• Aggregate your data with other users' data for any purpose beyond anonymized platform improvement metrics
• Train machine learning models on your individual portfolio data

4. SnapTrade's Role

SnapTrade is the third-party service that facilitates the secure connection between your brokerage and WealthEngine Pro.

4.1 Authentication

When you connect a brokerage account, you are redirected to SnapTrade's secure Connection Portal to authenticate directly with your brokerage. WealthEngine Pro never sees, receives, transmits, or stores your brokerage login credentials at any point in this process.

4.2 Data Retrieval

After authorization, SnapTrade retrieves your financial data from your brokerage on our behalf and transmits it to WealthEngine Pro via encrypted API connections. SnapTrade acts as a data intermediary—it facilitates data retrieval but does not store your financial data long-term.

4.3 SnapTrade's Privacy and Security

SnapTrade maintains its own security and compliance program. Their handling of your data is governed by their own privacy policy, available at snaptrade.com/privacy. We encourage you to review SnapTrade's privacy practices. WealthEngine Pro's obligations under these Data Processing Terms begin when your brokerage data is received by our systems.

4.4 SnapTrade Registration

To use the brokerage integration, a SnapTrade user account is created on your behalf. This account is linked to your WealthEngine Pro user ID. We store an encrypted authorization token ("userSecret") to facilitate ongoing data synchronization. This token does not grant trading access—it enables read-only data retrieval.

5. Data Storage and Security

5.1 Storage Infrastructure

Your brokerage data is stored in an encrypted PostgreSQL database hosted on DigitalOcean's managed database infrastructure in the United States. DigitalOcean's managed databases provide SOC 2 Type II compliant infrastructure with automated encryption at rest.

5.2 Encryption

• In Transit: All data transmitted between SnapTrade and WealthEngine Pro, and between your browser and our servers, is encrypted using TLS (Transport Layer Security).
• At Rest: All brokerage data stored in our database is encrypted at rest using the encryption provided by DigitalOcean's managed database service.
• SnapTrade Tokens: The encrypted authorization token (userSecret) used for SnapTrade API authentication is additionally encrypted at the application level before database storage using a dedicated encryption key.

5.3 Access Controls

• Access to brokerage data tables is restricted via database-level role-based access controls (RBAC)
• Application queries use least-privilege database roles that limit access to only the data necessary for each function
• Administrative access to the database is restricted to authorized personnel with a documented business need
• Brokerage data is not accessible through any public API endpoint without authenticated session validation

5.4 Audit Logging

We log brokerage-related events for security and troubleshooting purposes, including: connection events (connect, disconnect), data sync events (initiated, completed, failed), and error states. These logs do not contain the substantive content of your financial data (i.e., we log that a sync occurred, not the specific holdings or balances retrieved).

6. Data Synchronization

6.1 Sync Frequency

Brokerage data is synchronized:

• Automatically: On a periodic schedule to keep your portfolio data current within the Platform.
• Manually: You may trigger a manual data refresh through the Portfolio Tracker interface. Manual syncs are limited to 3 per day to manage API rate limits.

6.2 Sync Limitations

Data synchronization depends on the availability and responsiveness of both SnapTrade's API and your brokerage's data feeds. Sync delays, partial data, or temporary unavailability may occur due to:

• Brokerage system maintenance or outages
• SnapTrade API rate limits or service interruptions
• Data processing delays at the brokerage level
• Network connectivity issues

We do not guarantee real-time data accuracy. There may be a delay between activity in your brokerage account and its reflection in the Platform.

7. Data Retention and Deletion

7.1 Active Connection

While your brokerage connection is active, we retain and periodically refresh your brokerage data to provide portfolio tracking services. Daily portfolio snapshots are stored to enable performance history and charting.

7.2 Disconnection

If you disconnect your brokerage account through account settings:

• The SnapTrade connection is revoked immediately—no further data is retrieved from your brokerage
• Previously synced brokerage data (holdings, positions, balances) is retained for 30 days to allow reconnection without data loss
• After 30 days, all synced brokerage data is permanently deleted from our systems
• Historical portfolio snapshots taken during the connection period are deleted on the same schedule

7.3 Account Deletion

If you delete your WealthEngine Pro account:

• All brokerage connections are revoked immediately
• All brokerage data, portfolio snapshots, and SnapTrade registration records are permanently deleted within 30 days
• The encrypted SnapTrade authorization token is destroyed

7.4 Immediate Deletion Request

You may request immediate deletion of all brokerage data at any time (without deleting your WealthEngine Pro account) by contacting support@wealthenginepro.com with the subject line "Brokerage Data Deletion Request." We will process the request within 7 business days and confirm deletion by email.

7.5 Backup Handling

Database backups that contain deleted brokerage data are overwritten in accordance with our standard backup rotation schedule. We do not maintain indefinite backup archives of deleted data.

8. Your Controls and Rights

You have the following controls over your brokerage data at all times:

California residents have additional rights under the CCPA/CPRA as described in our Privacy Policy, including the right to know what data has been collected, the right to deletion, and the right to correction.

9. Explicit Restrictions on Data Use

To be clear and unambiguous, WealthEngine Pro makes the following commitments regarding your brokerage data:

10. Data Accuracy and Limitations

The accuracy, completeness, and timeliness of your brokerage data depends on multiple factors outside of WealthEngine Pro's control:

• Brokerage Data Quality: We display data as received from your brokerage via SnapTrade. We do not independently verify, audit, or correct this data. If your brokerage provides incomplete or inaccurate data, that will be reflected in the Platform.
• Cost Basis: Not all brokerages provide cost basis data through SnapTrade. Where cost basis is unavailable, certain performance calculations may be limited or estimated.
• Options Data: Options position data availability varies by brokerage. Some brokerages may not provide full options chain details (premiums, greeks) through SnapTrade.
• Performance Calculations: Portfolio performance metrics computed by WealthEngine Pro are for informational purposes only. They may differ from your brokerage's official calculations due to differences in methodology, timing of data retrieval, corporate action handling, or dividend reinvestment treatment.
• Delayed Data: Synced data may not reflect real-time brokerage account activity. There is an inherent lag between actions taken in your brokerage and their appearance in the Platform.

You should always consult your brokerage's official statements as the authoritative record of your account activity, holdings, and performance.

11. Changes to These Terms

We may update these Data Processing Terms from time to time to reflect changes in our data practices, features, or legal requirements. When we make material changes, we will:

• Update the "Effective Date" and version number at the top of these Terms
• Notify you by email at the address associated with your account
• Post the updated Terms on the Platform

Material changes to how we process brokerage data will not take effect until at least 14 days after notice is provided, giving you the opportunity to disconnect your brokerage and request data deletion before the changes take effect.

12. Contact Information

For questions about these Data Processing Terms or how we handle your brokerage data:

WealthEngine Pro

Email: support@wealthenginepro.com

Subject Line: Brokerage Data Inquiry

For data deletion or export requests, please use the specific subject lines noted in Section 8 so we can route your request promptly.