Privacy Policy

Last updated: January 16, 2026

Soft Shirt LLC ("Company," "we," "us," or "our") operates the RT:CMD portfolio analytics platform (the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Service.

1. Information We Collect

1.1 Account Information

When you create an account, we collect:

• Email address (via Google OAuth)
• Name (as provided by Google)
• Profile picture URL (optional, from Google)

1.2 Brokerage Data

When you connect a brokerage account through our integration partner (SnapTrade), we receive:

• Account holdings and positions
• Transaction history
• Account balances
• Account identifiers

We do NOT have access to your brokerage login credentials. Authentication is handled securely by SnapTrade using industry-standard OAuth protocols.

1.3 Usage Data

We automatically collect certain information when you use the Service:

• Log data (IP address, browser type, pages visited)
• Device information
• Feature usage patterns

2. How We Use Your Information

We use the collected information to:

• Provide, maintain, and improve the Service
• Sync and display your portfolio data
• Generate personalized recommendations and alerts
• Communicate with you about the Service
• Detect and prevent fraud or abuse
• Comply with legal obligations

3. Data Sharing and Disclosure

3.1 We Do NOT Sell Your Data

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

3.2 Service Providers

We share data with trusted third parties who assist in operating our Service:

• SnapTrade: Brokerage data aggregation (see their Privacy Policy)
• Google: Authentication services
• DigitalOcean: Cloud hosting infrastructure

3.3 Legal Requirements

We may disclose your information if required by law, court order, or governmental authority.

4. Data Security

We implement appropriate technical and organizational measures to protect your data:

• All data transmitted over HTTPS/TLS encryption
• Brokerage tokens encrypted at rest using industry-standard encryption (Fernet/AES)
• Regular security audits and updates
• Limited employee access to user data

5. Data Retention

We retain your data for as long as your account is active or as needed to provide the Service. When you delete your account:

• Account information is deleted within 30 days
• Brokerage connections are immediately revoked
• Portfolio data is permanently deleted
• Anonymized, aggregated data may be retained for analytics

6. Your Rights

You have the right to:

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data
• Portability: Request your data in a portable format
• Disconnect: Revoke brokerage connections at any time

To exercise these rights, contact us at privacy@softshirtllc.com.

7. Third-Party Links

The Service may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

8. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will delete it promptly.

9. International Data Transfers

Your data may be transferred to and processed in the United States. By using the Service, you consent to this transfer. We ensure appropriate safeguards are in place for international transfers.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting the updated policy on this page
• Updating the "Last updated" date
• Sending an email notification for material changes

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

• Email: privacy@softshirtllc.com
• Company: Soft Shirt LLC