Privacy Policy

Last updated: August 15, 2026

This Privacy Policy describes how Wealth Luum Inc., operating as Luum Wealth ("Luum", "we", "us", or "our"), collects, uses, discloses, and protects personal information in connection with the Luum Wealth portfolio analytics platform (the "Platform").

We are committed to compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Canadian provincial privacy legislation, including Quebec's Act respecting the protection of personal information in the private sector as amended by Law 25.

Not investment advice. Luum is a portfolio analytics and educational tool. Nothing on the Platform is personalized investment advice, a suitability assessment, or a recommendation to buy or sell any security. See our Investment Disclosures for the full statement.

1. Who we are

Wealth Luum Inc. is a Canadian company incorporated in Ontario, offering portfolio analytics software to retail investors under the name Luum Wealth. The Platform lets you record, import, connect, and analyze your investment holdings.

Privacy Officer contact: privacy@luumwealth.com

2. Scope

This Policy applies to personal information we collect through the Platform, our website at luumwealth.com, our marketing site, and related services. It does not apply to third-party services you reach from links on the Platform, or to your brokerage's own handling of your data.

3. Information we collect

3.1 Account information

Name and email address.
Authentication credentials, managed on our behalf by Clerk. We never see or store your password.
A mobile phone number, if you choose to complete phone verification. This is held by Clerk, not in our database. See Clerk's Privacy Policy: https://clerk.com/legal/privacy.
Subscription and billing information, processed by Stripe. We never receive or store your full card number.

3.2 Financial data you provide or connect

Portfolio holdings and positions, entered manually, imported by CSV, or synchronized from a brokerage account you connect.
Transaction history — purchases, sales, dividends, contributions, and withdrawals.
Cash flow records used to calculate your returns.
Account types and registration status (for example TFSA, RRSP, FHSA, RESP, LIRA, or, for US users, 401(k), IRA, Roth IRA, HSA).
Manually tracked assets and liabilities you add to your net worth — for example a property value, a vehicle, a mortgage, or a loan balance.
Portfolio goals, target allocations, named savings goals, contribution room figures, and scheduled contributions you configure.
Watchlists and price alerts you create.

You control what we hold. You choose what to enter, upload, or connect. We do not acquire your financial data from any brokerage, credit bureau, or data broker without an action by you.

3.3 Investor profile

During onboarding and in Settings, we ask for:

Your tax country and base currency.
Your primary investment goal and risk tolerance.
Optionally, your age range, net worth range, and self-described investing skill level.

We use these to set sensible defaults, tailor the analytics we show you, and choose which educational content is relevant. We do not use them to assess your suitability for any investment, and they are not shared with any third party for marketing.

3.4 Technical and usage data

Your IP address, stored only as a salted one-way hash. We do not retain raw IP addresses in our audit records.
Browser type, operating system, and user agent string.
API request logs — method, path, response code, and latency.
Security audit events — sign-ins, data exports, portfolio creation and deletion.

3.5 Device identification for fraud prevention

We generate a device identifier when you use the Platform, and store it together with your browser's user agent string. We use this solely to detect abuse — for example, many trial accounts created from one device.

This identifier is not used for advertising, is not shared with advertisers or data brokers, and is not used to track you across other websites. It is retained for the life of your account and deleted when your account is deleted.

3.6 Product analytics, only if you opt in

If, and only if, you give consent, we collect product analytics: page views and named feature-usage events (for example, that a portfolio was created or a CSV was uploaded), together with your account identifier and email address.

Consent is off by default. The analytics library is not loaded at all until you opt in, so no analytics cookie or browser storage is written and no event is sent before consent.
You are asked during onboarding, and you can change your choice at any time in Settings → Investor Profile → Analytics.
Withdrawing consent stops collection and resets the analytics identity on your device.
We do not collect autocaptured clicks, keystrokes, session recordings, or the contents of your portfolio through analytics.

3.7 AI assistant conversations

When you use the AI assistant, your questions are processed by Anthropic (the Claude API) in the United States, and relevant figures from your portfolio are supplied to the model so it can answer about your actual holdings.

We do not store your conversations. The exchange is held only in your browser for that session; closing or reloading the page starts a fresh conversation and we keep no copy. We do record that a call happened — the feature used, the token count and the cost — so we can meter usage and bill correctly. That record contains no conversation text and no portfolio figures.

We do not use your conversations to train AI models, and our agreement with Anthropic does not permit them to train models on data submitted through their commercial API.

3.8 Support requests

If you contact support, we retain your message and our reply. Support cannot see your financial data — see Section 5.

4. How we use your information

We use personal information to:

Provide, operate, secure, and improve the Platform.
Calculate portfolio analytics, allocation, drift, returns, income, fees, and tax summaries.
Generate AI insights grounded in your own portfolio data.
Process billing, manage your subscription and trial, and meter AI credits.
Send you the transactional and service messages described in Section 8.
Respond to support, access, and privacy requests.
Detect and prevent fraud, abuse, and unauthorized access.
Meet legal, tax, and regulatory obligations.

We do not sell your personal information. We do not use your financial data for advertising, and we do not disclose it to advertisers or data brokers.

5. Our own staff cannot see your financial data

This is a deliberate design constraint, not only a policy commitment:

Luum support staff and engineering staff cannot view, access, adjust, or modify your holdings, positions, transactions, cash flows, goals, watchlists, or manually tracked assets and liabilities. Administrative tools have no path to these records.
Your brokerage connection credentials are encrypted. Decryption capability is not available to support or engineering staff.
The only account-data action our staff can take is deletion of an entire account, which removes the associated financial data as a consequence.
Because of this, we cannot answer questions about the contents of your portfolio, correct a figure on your behalf, or recover data you have deleted. Requests of that kind are outside what support is able to do.

We collect and process personal information on the basis of:

Your consent, given when you create an account, when you connect a brokerage, and separately for optional product analytics and non-essential email.
Performance of our contract with you — providing the service you signed up for.
Our legitimate interests in operating a secure, reliable, non-fraudulent platform.
Legal obligation, for example the retention of billing records under Canadian tax law.

You may withdraw consent at any time. Withdrawing consent for essential processing means closing your account — see Section 10.

7. Where your data is stored, and who processes it

Your personal and financial data is stored on Amazon Web Services infrastructure in Canada. All data is encrypted at rest and in transit.

Some categories of data are processed outside Canada by the service providers below. Each is bound by a data processing agreement or equivalent contractual data protection commitment, and may use your data only as we direct.

Provider	Purpose	Data shared	Processing location
AWS	Hosting, database, storage, email delivery	All Platform data	Canada
Clerk	Authentication and session management	Email, name, phone number if provided, session tokens	United States
Stripe	Subscription billing and payments	Email, billing address, subscription tier, payment method	United States (Stripe Canada entity)
Snaptrade	Brokerage account connection	Brokerage OAuth credentials, and holdings data in transit	Canada & United States
Anthropic	AI assistant (Claude API)	Your AI questions and the portfolio figures needed to answer	United States
Voyage AI	Help centre search (embeddings)	The text of your help centre search query	United States
PostHog	Product analytics — only if you opt in	Page views, feature-usage events, account identifier, email	United States
EODHD	Market data	No personal information — symbol queries only	European Union / United States
Bank of Canada	Foreign exchange rates	No personal information — currency-pair queries only	Canada

We do not use Google Analytics, Meta Pixel, or any advertising or ad-tech network.

We will disclose personal information where required by law or valid legal process — a court order, search warrant, or regulatory demand — and will notify you where we are legally permitted to do so.

8. Email and other messages (CASL)

Canada's Anti-Spam Legislation governs the commercial electronic messages we send you.

Messages we always send while your account exists, because each one is a record of a transaction or a warning that you are about to lose access, money, or data:

Billing events — receipts and payment failures.
Notice that your account has expired.
Notice that your account has become inaccessible.
Notice before your data is permanently deleted.

Messages you can switch off individually in Settings → Notifications, including brokerage sync failures, stale-data warnings, trial expiry reminders, allocation drift, goal tracking, price moves, watchlist and IPO alerts, and AI credit warnings.

Every notification-category email includes an unsubscribe link — including the always-sent ones above, since some (the notice before deletion, for instance) can carry a call to action to subscribe or reactivate — and supports one-click unsubscribe from your mail client. The only emails with no unsubscribe link are ones with nothing to unsubscribe from: account creation, email verification, a requested data export becoming ready, and AI credit top-up receipts. You can also switch off all non-essential email at once from Settings. An unsubscribe takes effect on confirmation and does not affect the always-sent messages above — clicking it stops future optional email, not the transaction records and account-status notices you can't opt out of.

9. How long we keep your data

Data	Retention
Holdings, transactions, cash flows, goals, watchlists, manual assets	For the life of your account, then 60 days after you request deletion
AI assistant conversations	Not stored on our servers. Your conversation is held only in your browser for that session; closing or reloading the page starts a fresh conversation. We do not retain a copy.
Brokerage credentials	Until you remove the connection, then deleted and the key disabled
Your account record	60 days after a deletion request, then permanently deleted
Billing and payment records	7 years, as required by Canadian tax law (Income Tax Act s. 230)
Security audit log, including hashed IP addresses	2 years. Contains access events, not financial data
API and application logs	90 days
Uploaded CSV files as submitted	1 year from upload
Data export files you request	7 days, then automatically deleted
Device identifiers (Section 3.5)	Life of the account

9.1 If you delete your account

Deletion begins a 60-day grace period. Your financial data becomes inaccessible immediately, and you can reverse the deletion during those 60 days by contacting us. After 60 days everything is permanently deleted except the billing records and audit entries above.

A lapsed trial follows a fixed schedule. This path ends in the deletion of your data, so please read it.

Period	What happens
Days 1–30	Free trial, full access.
Days 31–37	Grace period. Your account remains fully functional.
Days 38–97	Read-only. You can view and export everything, but not add or change data.
Days 98–157	Sign-in leads to a reactivation screen. Subscribe to restore access.
Day 157 onward	Your account and all financial data are permanently deleted.

We email you before each of these transitions, and the notice before deletion cannot be switched off. Export your data during the read-only period if you do not intend to subscribe — Settings → Your Data → Export.

10. Your rights under PIPEDA

Access. You may ask what personal information we hold about you. You can download much of it yourself at any time from Settings → Your Data → Export, which produces a machine-readable file containing your portfolios, positions, transactions, cash flows, goals, upload history, and security audit events.
Correction. You may ask us to correct inaccurate or incomplete personal information. You can edit your profile and financial records directly in the Platform.
Withdrawal of consent and deletion. You may withdraw consent and delete your account and associated data at any time from Settings, subject to the grace period and the billing retention requirement in Section 9.
Explanation. You may ask us how your information is used and who it has been disclosed to.
Complaint. You may complain to us, and if you are not satisfied, to the Office of the Privacy Commissioner of Canada at priv.gc.ca.

To exercise any of these rights, email privacy@luumwealth.com. We will respond within 30 days.

10.1 If you are in Quebec

Quebec law gives you additional rights, including the right to data portability, the right to be informed when personal information is used to render a decision based exclusively on automated processing, and the right to request that such processing be reviewed by a person.

The Platform's analytics, projections, and AI observations are informational and are not used to make decisions about you — we do not use automated processing to accept or refuse you as a customer, set your price, or assess your creditworthiness or suitability.

You may complain to the Commission d'accès à l'information du Québec.

11. Cookies and browser storage

What	Type	Purpose	Consent
Clerk session cookies	Cookie (`httpOnly`, `Secure`, `SameSite=Lax`)	Keeps you signed in	Strictly necessary — none required
Onboarding state	Cookie (`httpOnly`)	Remembers that you finished onboarding	Strictly necessary — none required
Theme preference	Local storage	Remembers light or dark mode	Strictly necessary — none required
Cookie notice dismissal	Local storage	Stops us showing the notice again	Strictly necessary — none required
Analytics storage	Cookie / local storage	Product analytics (Section 3.6)	Only written after you opt in

We use no advertising or cross-site tracking cookies.

12. Security

We employ encryption at rest and in transit, network isolation, least-privilege access controls, envelope encryption of brokerage credentials, secret scanning and continuous vulnerability scanning, rate limiting, audit logging, and periodic security review.

No method of transmission or storage is completely secure. If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals and report to the Office of the Privacy Commissioner of Canada as PIPEDA requires, and to the Commission d'accès à l'information where Quebec residents are affected.

13. Children

The Platform is not directed at anyone under 18, and we do not knowingly collect personal information from minors. If you believe a minor has given us personal information, email privacy@luumwealth.com and we will delete it.

14. Changes to this Policy

We may update this Policy. Material changes will be communicated by email and by posting the updated Policy with a revised effective date, before the change takes effect. Where a change requires your consent, we will ask for it rather than rely on your continued use.

15. Contact and complaints

Luum — Privacy Officer Email: privacy@luumwealth.com