Privacy Policy

1. Who we are

Raijin (the “Service” or the “Platform”) is operated by Raijin AI, Inc. (“Raijin AI,” “we,” “our,” or “us”), an investment adviser registered with the U.S. Securities and Exchange Commission (CRD #342079; SEC File No. 801-136263). This Privacy Policy explains how we collect, use, share, and protect the nonpublic personal information of the individuals who use the Service. It is provided pursuant to Regulation S-P under the Gramm-Leach-Bliley Act and is made available to you at account opening and at all times on this page.

2. Information we collect

Depending on how you use the Service, we collect the following categories of information:

• Identifying information: your name, username, email address, phone number, and a profile photo if you choose to add one.
• Brokerage connection data: when you link an external brokerage account, we receive and store secure authorization tokens (OAuth tokens) for that account. We do not collect or store your brokerage username or password.
• Account and financial data: your linked account identifiers, account balances, current positions and holdings, and your trade history, which we read in order to manage and report on your account.
• Investment profile information: your investment objectives, risk tolerance, investment horizon, investment experience, and information about your financial situation that you provide to us.
• Activity on the Platform: the agents and strategies you create, deploy, modify, or subscribe to, and related activity logs.
• AI chat content: the messages you send when you chat with an agent, together with the portfolio context that chat draws on (such as your relevant holdings, trades, and performance). See Section 4 for how this is shared with our AI provider.
• Payment information: your billing history and the payment details you provide for subscription fees. Card details are collected and stored by our third-party payment processor, Stripe, not by Raijin AI directly.
• Device and usage data: IP address, device identifiers, browser information, pages and screens visited, timestamps, and cookies and similar technologies used for authentication, security, and basic functionality.
• Communications: support messages, survey responses, and other communications you have with us.

3. How we use information

• To open, maintain, and service your account and provide our advisory services, including placing trades in your connected brokerage account where you have authorized discretionary management.
• To authenticate you and protect the Platform against unauthorized access.
• To generate and tailor algorithmic strategy recommendations based on your investment profile.
• To monitor agent performance and enforce risk guardrails.
• To power the AI chat feature and respond to your questions about your agents and holdings.
• To process payments and manage billing.
• To communicate with you about your account, including notifications, disclosures, and product updates.
• To detect, investigate, and prevent fraud, abuse, and security incidents.
• To respond to regulatory inquiries, subpoenas, and legal process, and to comply with our legal and regulatory obligations, including anti-money-laundering and recordkeeping requirements.
• To operate, maintain, and improve the Service and our compliance program.

4. How we share information

We do not sell your personal information, and we do not share it with any third party for that party’s own marketing purposes. We share information only as necessary to provide the Service or to comply with applicable law, with the following categories of recipients:

• SnapTrade Inc., our brokerage connectivity provider, solely to enable us to connect to your brokerage account and execute trades there.
• Your broker-dealer (for example, the brokerage you connect, such as Robinhood, Alpaca, or another supported broker), as necessary to execute trades and obtain account data.
• Stripe, our third-party payment processor, solely to process subscription and advisory fee payments.
• Anthropic, the provider of the AI models behind the chat feature. When you chat with an agent, your messages and the relevant portfolio context that chat relies on (such as holdings, trades, and performance) are sent to Anthropic to generate a response.
• Service providers for hosting, infrastructure, data storage, email and message delivery, analytics, and customer support, under contracts that restrict their use of your information to the services they provide to us and require them to keep it confidential and secure.
• Regulators, self-regulatory organizations, and law enforcement, in response to subpoenas, examinations, or other lawful requests.
• Our professional advisers (such as outside counsel and accountants), as necessary for them to provide their services to us.

We may also disclose information if required by law or to protect the rights, property, or safety of Raijin AI, our users, or the public.

5. Data retention

As an SEC-registered investment adviser, we are required to keep certain books and records, including records relating to your account, transactions, and advisory relationship, for the periods mandated by the Investment Advisers Act of 1940 and the rules thereunder (generally at least five years, and in some cases longer). Because of these obligations, financial and account records cannot always be deleted on request and may be retained for as long as the law requires, even after you close your account. We retain other information for as long as necessary to provide the Service and for legitimate business or legal purposes.

6. Closing your account and deleting your data

You can close your account at any time in the app under Profile → Account → Delete account. When you do, we cancel any active subscription, stop your agents, disconnect your brokerage connections and scrub the stored authorization tokens, remove your login so it can no longer be used, and anonymize the personal information in your profile. Records we are required to keep for regulatory books-and-records purposes are retained in anonymized form, as described in Section 5. You can also request closure or deletion, or ask questions about your data, by emailing support@raijinai.com.

7. Your choices

You can unsubscribe from marketing emails using the link in those emails or by contacting us. Subject to the recordkeeping limitations described above, you may also request access to, correction of, or deletion of personal information we hold about you.

8. US state privacy rights

Residents of California, Colorado, Connecticut, Utah, Virginia, and certain other US states may have additional rights under applicable state privacy laws, including the right to access, correct, or delete personal information we hold about them, the right to opt out of the “sale” or “sharing” of personal information (we do not sell or share personal information as those terms are defined by applicable law), and the right to be free from discrimination for exercising these rights. Certain financial information held by financial institutions is exempt from these state laws. To exercise any of these rights, email support@raijinai.com.

9. Security

We maintain administrative, technical, and physical safeguards designed to protect your information, including role-based access controls and multi-factor authentication, encryption of information in transit and at rest using industry-standard protocols, network security controls and logging, vendor due diligence, employee confidentiality obligations, and an incident response plan. No system is perfectly secure, and we cannot guarantee absolute security.

10. Children

The Service is not directed to children under 18, and we do not knowingly collect personal information from children.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or by email. Your continued use of the Service after an update constitutes acceptance of the revised Policy.

12. Contact

Questions about this Privacy Policy or your data? Email support@raijinai.com.