This Privacy Policy ("Policy") describes how Novion Social Inc. ("NovionSocial," "Company," "we," "us," or "our") collects, uses, processes, stores, transfers, and protects personal information in connection with your access to and use of the NovionSocial platform (the "Platform").
By accessing or using the Platform, creating an account, or otherwise providing information, you acknowledge that you have read and understood this Policy. Where required by applicable law, we will obtain your consent for the collection, use, or disclosure of personal information.
1. Scope, Application, and Interpretation
1.1 Scope of Application
This Policy applies to all personal information collected, processed, or stored by NovionSocial through the Platform, including websites, mobile applications, APIs, integrations, and any related services. It applies to both registered users and, where applicable, visitors interacting with the Platform.
1.2 Territorial Scope
This Policy applies to users located in Canada and is designed to comply with Canadian privacy legislation, including PIPEDA and Quebec's Act respecting the protection of personal information in the private sector. Where users access the Platform from other jurisdictions, additional legal requirements may apply.
1.3 Definitions
"Personal Information" means any information about an identifiable individual, whether directly or indirectly identifiable, including identifiers, behavioral data, financial information, and technical data.
"Processing" includes collection, use, storage, disclosure, transfer, and deletion of personal information.
1.4 Role of NovionSocial
NovionSocial acts as the primary organization responsible for determining the purposes and means of processing personal information. Third-party providers engaged by NovionSocial act as service providers or processors where applicable.
1.5 Consent
By using the Platform, you consent to the collection, use, and disclosure of your personal information as described in this Policy, where consent is an appropriate legal basis and subject to your rights under applicable law. Where separate or express consent is required, we will request it.
2. Categories of Personal Information Collected
2.1 Information Provided Directly by Users
We collect personal information you voluntarily provide, including your name, email address, login credentials, profile details, and any information entered into forms or submitted through the Platform.
Where you choose to register or sign in using Google Sign-In, we receive your first name, last name, email address, and profile picture directly from Google, subject to the permissions granted.
Where you choose to register or sign in using Sign in with Apple, we may receive your name, email address or Apple-provided private relay email address, and authentication identifiers, depending on the information you authorize Apple to share.
This information is required to create accounts, authenticate users, and deliver services.
2.2 Financial and Portfolio Data
We collect financial information you input, including portfolio holdings, securities positions, cost basis, transaction activity, watchlists, and derived analytics. This information is used solely to provide portfolio tracking, analytics, and insights and is not used for resale or external profiling.
2.3 AI Interaction Data
We collect data associated with your use of AI features, including prompts, queries, instructions, outputs, and metadata such as timestamps, usage frequency, and system logs. This information is necessary to provide AI functionality and monitor system performance.
We may also process user-submitted posts, comments, images, and profile content through automated moderation systems, including OpenAI's Moderation API, to identify potentially harmful, prohibited, or policy-violating content.
2.4 Social and Communication Data
We collect information related to user interactions, including messages, posts, comments, reactions, and engagement metrics. This data enables social features and community participation.
2.5 Technical and Device Information
We automatically collect technical information such as IP address, device identifiers, browser type, operating system, session logs, access times, and usage behavior. This data is used for analytics, system optimization, and security monitoring.
2.6 Cookies and Tracking Technologies
We use cookies and similar technologies to maintain session integrity, authenticate users, store preferences, and analyze usage patterns. These technologies may be deployed directly or through analytics providers such as PostHog.
2.7 Data from Third-Party Sources
We may receive data from third-party providers integrated into the Platform, including market data from Twelve Data, news content from Stock News API, and financial market intelligence from Unusual Whales.
Unusual Whales may provide information concerning unusual options activity, political trading disclosures, ETF flows, economic events, and other market developments. NovionSocial receives this information for use in its market intelligence features and does not transmit user personal information to Unusual Whales.
We may also receive publicly available financial news, market information, and statements from third-party sources for use in the Platform's market monitoring, news classification, and informational features, including the Trump Tracker.
Where you authenticate using Google Sign-In or Sign in with Apple, we receive the applicable account information described in Section 2.1.
2.8 Analytics and Diagnostics
We use PostHog to understand how people use the mobile app and diagnose technical problems. We collect screen visits and interactions with features such as search, posts, portfolios, and TradeMind.
This information may include securities symbols, account and content identifiers, timestamps, interaction counts, and search or message lengths. We also collect crash and error diagnostics, including error messages, stack traces, and app and device information.
These records may be linked to your signed-in account through an internal user identifier. We use this information to improve usability and reliability and to troubleshoot problems.
3. Purposes of Processing
3.1 Core Platform Functionality
We process personal information to operate, maintain, and improve the Platform, including account management, portfolio tracking, AI tools, and user interaction features.
3.2 Personalization and Recommendations
We use data to tailor content, features, and recommendations based on user activity, preferences, and behavior.
The Platform may also use automated systems to categorize, prioritize, and display financial news, public statements, market developments, and other information according to their potential relevance to financial markets.
3.3 AI Processing and Output Generation
We process user inputs through third-party AI systems provided by OpenAI to generate outputs and insights.
AI systems may also be used to classify financial news, assess the potential market relevance of public statements, generate informational markers, and support automated market intelligence features, including the Trump Tracker.
3.4 Security and Fraud Prevention
We process data to detect, prevent, and respond to unauthorized access, fraud, abuse, and other security risks.
We may use automated content moderation systems, including OpenAI's Moderation API, to evaluate posts, comments, images, and profile content for potential violations of Platform policies or applicable laws.
3.5 Legal and Regulatory Compliance
We process personal information to comply with applicable laws, legal processes, and regulatory obligations.
3.6 Communications
We process contact information to send service-related communications and, where permitted, promotional communications in compliance with applicable laws.
4. AI Processing and External Systems
4.1 Third-Party AI Services
The Platform integrates artificial intelligence services provided by OpenAI, including AI-powered analysis, content generation, financial information processing, and automated content moderation.
4.2 Data Transmission
When using AI features, your inputs and relevant contextual information may be transmitted to OpenAI for processing. Such information may include financial or portfolio information you submit for AI-assisted analysis.
Where content moderation is performed, posts, comments, images, and profile content may be transmitted to OpenAI's Moderation API for automated evaluation.
These services may process data in accordance with applicable contractual terms, data processing arrangements, and provider policies.
4.3 No Proprietary Training
NovionSocial does not use your personal or financial data to train internal AI models or develop independent machine learning systems.
4.4 Output Limitations
AI outputs are generated probabilistically and may contain errors, omissions, or outdated information. They are not a substitute for professional advice.
5. Data Sharing and Disclosure
5.1 Service Providers and External Data Sources
We share personal information with service providers where necessary to operate the Platform, subject to the functions they perform:
- Supabase (database, authentication, infrastructure)
- PostHog (product analytics, crash reporting, and error diagnostics)
- Sentry (error tracking)
- Google (authentication via Google Sign-In)
- Apple (authentication via Sign in with Apple)
- OpenAI (AI processing, AI-generated analysis, and automated content moderation)
The Platform also obtains financial and market information from third-party data sources, including:
- Twelve Data (market data)
- Stock News API (news content)
- Unusual Whales (financial market intelligence, unusual options activity, political trading disclosures, ETF flows, and other market information)
Unusual Whales supplies data to NovionSocial. NovionSocial does not transmit user personal information to Unusual Whales.
5.2 Infrastructure Providers
We may use cloud infrastructure providers to host and process data securely.
5.3 Legal Requirements
We may disclose information where required by law, court order, or regulatory authority.
5.4 Business Transactions
In the event of a merger, acquisition, or sale, personal information may be transferred as part of the transaction.
5.5 No Sale of Personal Information
We do not sell personal information to advertisers or third parties.
6. Data Retention and Deletion
6.1 Retention Principles
We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy.
These principles also apply to analytics and diagnostic records held by PostHog.
6.2 Retention Periods
Account data: retained during active use and up to 24 months after deletion
Financial data: retained only as necessary for Platform functionality, generally not exceeding 24–36 months
AI interaction data: retained up to 12 months
Analytics data: retained for 12–24 months
Support communications: retained up to 24 months
6.3 Deletion and Erasure
Users may request deletion of their personal information. We will take reasonable steps to delete or anonymize such data, subject to legal and operational constraints.
Deleting a Platform account does not automatically erase analytics and diagnostic records held by PostHog. You may request deletion or anonymization of account-linked records using the contact details in Section 14, subject to applicable legal and operational constraints.
7. User Rights and Controls
Under PIPEDA and the Act respecting the protection of personal information in the private sector, as applicable, you have the right to:
- Access your personal information
- Request corrections
- Request deletion
- Withdraw consent
- Request information about processing
- File complaints with regulators
Requests will be processed within a reasonable timeframe as required by law.
8. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Maintain authentication sessions
- Store user preferences
- Analyze performance and usage
- Improve Platform functionality
Analytics providers such as PostHog may use tracking identifiers. In the mobile app, identifiers stored within the app can associate usage events and diagnostic reports with a session or account.
You can manage website cookies through your browser settings. Browser cookie settings do not control identifiers stored in the mobile app. To request information about analytics collection or exercise your applicable privacy rights, contact us using the details in Section 14.
9. Electronic Communications (CASL Compliance)
We comply with Canada's Anti-Spam Legislation (CASL), including:
- Obtaining consent before sending promotional communications
- Clearly identifying the sender
- Providing unsubscribe mechanisms
- Honoring opt-out requests promptly
Transactional communications may still be sent where permitted by law.
10. Security Safeguards
10.1 Technical Measures
We implement encryption, access controls, monitoring systems, and secure infrastructure practices.
10.2 Organizational Measures
Access to personal information is restricted to authorized personnel with a legitimate business need.
10.3 Residual Risk
No system is completely secure, and we cannot guarantee absolute protection against breaches.
11. International Data Transfers
Personal information may be processed outside Canada by third-party providers, including providers of AI processing, authentication, analytics, and infrastructure services.
We take reasonable steps to ensure appropriate safeguards are in place.
Where personal information is transmitted to OpenAI or other external service providers, such processing may occur in jurisdictions outside Canada, subject to applicable contractual, technical, and organizational safeguards.
12. Data Breach Notification
In the event of a breach posing a real risk of significant harm, we will:
- Notify affected individuals without undue delay
- Notify regulators as required
- Take steps to mitigate harm
13. Changes to This Policy
We may update this Policy periodically. Material changes affecting personal data will be communicated directly, including via email where required.
14. Contact Information
Email: Legal@novionsocial.com