Privacy Policy

Last updated: July 29, 2026

vFolio Inc. (“vFolio”, “we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal data in connection with the vFolio desktop application (the “App”), the website located at https://vfolio.ai (the “Website”) and any other services provided by us or our affiliates which are not covered by a separate privacy policy (the “Services”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal data, how you can assert those rights, and how you can contact us to get answers to your questions. This Privacy Policy applies to you whether you use the Services as an individual for your own purposes, as a sole practitioner or other one-person business, or as part of a company or other organization. For the purposes of this Privacy Policy, the terms “you,” “user,” “consumer,” “individual,” and “data subject” are used as appropriate for the relevant legal framework and all refer to the person whose personal data is processed.

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. Additionally, we may provide additional “just-in-time” notices or notices at collection that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal data.

The following paragraph applies only where your personal data reaches us because one of our customers placed it into the Services. If you use the Services for your own purposes, it does not apply to you, and vFolio is the controller of your personal data as described in the rest of this Privacy Policy. With respect to the personal data that our customers and their vendors collect from you outside of our Services and make available to us through their use of the Services (“Service Data”), where permitted by law, we process such information only as a “service provider” or “data processor” (as those terms are defined under applicable data protection laws) on behalf of our customers, who act as the “business” or “data controller” (as those terms are defined under applicable data protection laws). For example, Service Data includes personal data about you that is contained in a document that one of our customers stores, searches, sends for signature, or shares via the Link sharing feature using the App. Our customers – which include businesses and financial institutions as well as sole practitioners, professionals, and other individuals who use the App in the course of their own work – are the parties that control the use of the Service Data and determine the purposes for which we process such information. While this Privacy Policy describes the categories of Service Data we process and the safeguards we apply to it, our customers are responsible for their own practices in collecting, using, and disclosing information they collect from you. To learn more about such a customer’s use of your information and the rights that you may have over such information, please consult the privacy policy of, and contact, that customer.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable laws.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please contact us at support@vfolio.ai or at the address in the section below titled Contacting Us, and we will provide this Privacy Policy in an alternative format at no charge. We seek to conform this Privacy Policy to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.

BY USING OR ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SERVICES OR PROVIDE US WITH ANY PERSONAL DATA.

Personal Data We Collect from You

This Privacy Policy applies to the personal data that we obtain in various contexts. We use the term “personal data” – also called “personal information” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal data.

The following are the categories and types of personal data that we or our third-party partners may collect from or about you, depending on how you interact with the Services:

• Identifiers and contact information, such as your real name, email address, and account credentials;
• Email account information, including your email address, email metadata, and PDF attachments sent or received via your connected Microsoft 365 or Gmail account, together with contact records from that account used to identify senders and recipients. We request read-only permissions for these integrations and do not send, modify, or delete messages on your behalf;
• Documents and file content, including PDF files you store in the Vault via synced folders or email integration, and any text, tables, or data extracted from those files through the App’s search, indexing, and AI-powered features;
• Professional or employment-related information, such as your job title or employer, if you choose to provide it to us;
• Commercial information, such as subscription plan details, billing information, and records of services purchased or obtained. Payments are processed by our third-party payment processor acting as merchant of record; we do not receive or store your full payment card number;
• Device and system information, including your operating system, device type, hardware identifiers, and local folder paths for synced folders;
• Online identifiers and related information, including internet protocol (IP) address, data collected from cookies and similar technologies on our Website, and unique application identifiers;
• Usage data, such as which features you use, how often you use them, error and performance metrics, and session duration. This usage data is limited to counts, categories, and timing information — it does not include the text of your search queries, chat messages, or AI queries, which are separately addressed under AI Processing and Third-Party APIs below; and
• Signer and recipient information, such as the names, email addresses, and IP addresses of individuals you designate when using the electronic signature or Link sharing features;
• Any other personal data that you voluntarily provide us.

We may also collect personal data that is treated as “sensitive” under certain data protection laws (also known as “sensitive personal information” or “SPI”). Because vFolio processes user-uploaded documents, the content of those documents may incidentally contain SPI such as financial account information, health information, or other sensitive categories. We do not intentionally collect or solicit SPI, but it may be present in files you choose to store, index, or process through the App. We process such information solely for the purpose of providing the App’s document management, search, and AI features to you, and we apply the same security measures to all user content regardless of sensitivity.

How We Collect Your Personal Data

Personal Data You Provide

We collect personal data that you provide to us directly. This may include, but is not limited to:

• Information you provide when you contact us via email or through in-App support channels;
• Information you provide when you create your vFolio account, configure your profile, or connect your email account (Microsoft 365 or Gmail) during onboarding;
• Documents and files you upload, sync, or otherwise make available through the App, including PDFs stored in synced folders and PDF attachments accessed from your connected email account;
• Annotations, notes, comments, markups, and other content you create within the App;
• Queries you submit to the Vault Chat, Synthesize & Extract, and other AI-powered features;
• Payment and billing information you provide when subscribing to the App, which is provided directly to our third-party payment processor;
• Search queries you conduct through the Find File feature, including file name searches and semantic content searches;
• Names, email addresses, and related contact information of signers or recipients that you enter when using the electronic signature or Link sharing features;
• Any other information that you provide us on or through the Services.

Personal Data We Collect Automatically

When you use the App or visit our Website, we or third parties we work with may automatically collect certain information using technologies such as cookies (on our Website), application telemetry, and other tracking technologies described below.

• Cookies and Similar Technology: "Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our the Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies) to collect data related to usage of the Website. We may also use cookies to customize your visit to the Website and for other purposes to make your visit more convenient or to enable us to enhance the Website and Services.
• Analytics: We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Properties and other Services. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. You may obtain additional information about Google Analytics by visiting the section titled "How Google uses information from sites or apps that use our services,” located at www.google.com/policies/privacy/partners/.
• Application Telemetry and Local Data: When you use the App, we may collect telemetry data about your usage patterns, including features accessed, session duration, crash reports, and performance metrics. Telemetry is limited to metadata — such as feature counts, timing ranges, and error categories — and does not include your file names, file contents, search queries, chat messages, or email content. You may turn analytics and error reporting off at any time in the App’s settings. The App also stores data locally on your device in a local database, including text extracted from your PDF files, the search indexes and numerical representations (“embeddings”) derived from that text, folder sync configurations, and cached search results. This locally stored data is used to provide the App’s core functionality, including the Vault, Find File search, and document viewing features. Your PDF files themselves remain in the folders you select on your own device or in your own cloud storage; except as described immediately below and in connection with the electronic signature features, we do not upload or retain copies of your documents on our servers.
• AI Processing and Third-Party APIs: When you use the App’s AI-powered features, such as Chat and Excel Extract, portions of your document content and queries are transmitted to Anthropic PBC via the Claude API for processing. Anthropic processes this data to generate responses to your queries, and the results are returned to the App with linked references to source content within your files. Additionally, in order to make your documents searchable, text extracted from your documents is transmitted to Voyage AI (owned by MongoDB) for conversion into numerical representations (“embeddings”), and, when you run a search, the text of candidate passages is transmitted to Voyage AI for relevance ranking. This relevance-ranking step is optional and best-effort: search works fully without it using on-device ranking, and if you are offline or the ranking service is temporarily unavailable for any other reason, the App automatically falls back to its on-device search order rather than failing. Where a document is a scan or an image and contains no machine-readable text, images of the affected pages are transmitted to Anthropic PBC via the Claude API so that the text can be recognized and made searchable. The embeddings and recognized text that result from this processing are stored locally on your device. We do not use your documents, queries, or the outputs generated from them to train artificial intelligence models, and our artificial intelligence providers are contractually prohibited from using data submitted through their application programming interfaces to train their models.
• Electronic Signature Features: If you use the App’s electronic signature features, the document you send for signature, the names and email addresses of the signing parties you designate, and a signing audit trail (which may include IP addresses, timestamps, and the signature or initials image applied) are transmitted to and stored on our cloud infrastructure so that the document can be delivered to, signed by, and returned from those recipients. We process this information to provide the signature service, to produce the completed document and its audit trail, and to detect and prevent fraud.
• Link Sharing: If you use the App’s Link sharing feature, the document you choose to share, together with on-device page images generated from it, are uploaded to and stored on our cloud infrastructure so that we can generate a web link that lets the recipient view the document in a browser without installing the App or creating an account. If the recipient already has the App installed and is signed in to a vFolio account, opening the link instead opens the original document directly within the App rather than the browser-based view. Shared documents and page images are automatically deleted from our servers ninety (90) days after upload, regardless of whether the link has been viewed.
• Service Data: We may obtain Service Data from our customers and their vendors, which we process on behalf of our customers in accordance with our contracts with them.

How We Use Your Personal Data

We collect and use personal data for the following purposes:

• To communicate with you, which may include:
• Contacting you about and providing you with our Services;
• Responding to your direct inquiries, requests, issues or feedback, and providing customer service;
• Adding you to our mailing lists and sending you emails from time to time;
• To provide our products and services, which may include:
• Operating the Services, and providing you with the document management, search, AI-powered intelligence, and PDF editing features;
• Creating, maintaining, and otherwise managing your account, profile, or subscription;
• Indexing and embedding your documents to enable search functionality and AI-powered features within the App;
• Processing your subscription payments and providing you receipts and account updates;
• Transmitting your queries and document content to third-party AI providers — including Anthropic’s Claude API and Voyage AI’s embedding and reranking APIs — to generate AI-powered responses and search results within the Chat and Excel Extract features;
• Processing documents you send for electronic signature, and the documents and page images you make available through the Link sharing feature;
• For analytics and personalization, which may include:
• Identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners;
• Conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners;
• Understanding how you interact with our Services, and to improve Services;
• Personalizing your experience to save you time when you use the Services;
• Better understanding our customers’ needs;
• Providing personalized recommendations about our products and services;
• For security and fraud prevention, which may include:
• Helping maintain the safety, security, and integrity of our Services, databases and other technology assets, and business;
• Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
• Investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Services;
• To comply with legal obligations, which may include:
• Establishing or exercising our rights and defending against legal claims;
• Responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation;
• Acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of vFolio or the division responsible for the services with which your information is associated;
• For any additional purposes that you specifically consent to.

With respect to Service Data, we use that information to provide the Services to our customers,including facilitating document management, search indexing, electronic signature, Link sharing, and AI-powered features within both individual and shared workspaces. We reserve the right to supplement your personal data with information we gather from other sources which may include online and offline sources. We may collect information that is not personal data (“non-personal data”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal data does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal data with personal data. If we combine any non-personal data with personal data, the combined information will be treated by us as personal data to the extent that it is capable of personally identifying you. We reserve the right to develop and derive aggregate data (meaning information that relates to a group or category of individuals, from which individual identities have been removed) from personal data in order to enhance and maintain the Services, and such aggregate data will be treated as non-personal data.

How We Disclose or Share Your Personal Data

In addition to using your personal data ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal data to other affiliates and entities in the following instances:

• Service Providers: We may share your personal data with third-party service providers who may use your information to provide us with services including, but not limited to: cloud infrastructure and hosting services, AI and machine learning services (including Anthropic PBC for the Claude API and Voyage AI for search embeddings and relevance ranking), email integration services, payment processing, data analytics, customer service, auditing, and anti-fraud monitoring. These service providers may have access to personal data that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
• Legal Compliance and to Defend Our Rights: We may disclose personal data and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our End User License Agreement; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• Business Transfers: We may share your personal data and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Services.
• Non-Personal Data: We may share non-personal data with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Services, and for our own market research activities.

Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

With regard to Service Data, our customers provide us with instructions on what to do with such information. For example, a customer may choose which folders and email accounts to synchronize, configure individual or shared workspaces, manage access to documents, or determine which documents are indexed or processed using the AI-powered features. These choices and instructions may result in the access, use, disclosure, modification, or deletion of Service Data. Customers and their affiliates determine their own policies for the sharing and disclosure of Service Data. For example, if a customer’s use of the Services requires that Service Data be sent to one of the service providers described in the section below — such as transmitting a query to Anthropic PBC to generate an AI response, or to Voyage AI to make a document searchable — we do so because the customer’s own use of the Services calls for it, and not for any independent purpose of our own.

How We Protect Your Personal Data

Personal data is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Privacy Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. These safeguards include encryption of data in transit using industry-standard transport layer security, encryption at rest for data stored on our cloud infrastructure, role-based access controls that limit access to personal data to personnel who need it to perform their duties, multi-factor authentication for administrative access, and logging and monitoring of our production systems. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by using the information in the section below titled Contacting Us.

Data Retention

We will retain your personal data for as long as your inquiry is active or as needed to provide you with the Services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal data. While deletion is pending, we may securely store your personal data in backup archives in accordance with our routine data backup procedures, and if we do so, your data will be securely stored and isolated from any further processing until deletion is possible. In addition, we apply the following retention periods. If you cancel your subscription, your account and the personal data associated with it — including your profile, usage and telemetry data, and any documents, signer information, or page images stored on our servers in connection with the electronic signature or Link sharing features — are automatically and permanently deleted ninety (90) days after cancellation takes effect. Documents and page images stored on our servers in connection with the electronic signature or Link sharing features are also deleted ninety (90) days after the relevant signature request or shared link is completed, declined, or expires, whichever is sooner, even if your account remains open. You may also request deletion of your account and associated personal data at any time by contacting us using the information in the section below titled Contacting Us; we will complete such requests within thirty (30) days after we verify your identity. Records that we are required to retain for tax, accounting, audit, or other legal purposes are retained for the period required by applicable law regardless of account deletion. Backup copies of our systems are retained for up to seven (7) days as part of our routine backup procedures. Content that the App stores locally on your own device is under your control at all times and can be removed by deleting it from your device or by uninstalling the App.

Your Choices

Consistent with applicable law, you may exercise the choices described in this section regarding your personal data and communications from us. You may also have certain additional rights available depending on the laws of your country of residence, as described further below in the Privacy Policy.

• Opting Out of Messages or Services: We may send you marketing messages via email. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at privacy@vfolio.ai. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you.
• Cookies and Tracking Technologies: If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Services or some of their functionality may be affected. Note that cookie-based opt-outs must be performed on each device and browser on which you wish to opt out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Be advised that cookie-based opt-outs are not effective on some mobile services.

European Privacy Rights

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

References to the “GDPR” throughout this section include, as applicable: the EU General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and the GDPR as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; and the Swiss revised Federal Act on Data Protection, SR 235.1, effective September 1, 2023.

Legal Basis

We will only use your personal data, as that term is defined under the GDPR, when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have consented to a certain use of your personal data.
• Where we need to comply with a legal or regulatory obligation.

Data Controller

vFolio Inc. is the data controller of all personal data collected through our Services, with the exception of Service Data, for which vFolio acts as a data processor on behalf of its customers. Where required by applicable data protection law, vFolio will enter into a data processing agreement with a business customer upon request. To contact us, please see the section of the Privacy Policy titled Contacting Us. With regard to Service Data, you may consult the privacy policy and contact information of the applicable customer that acts as the data controller of your Service Data for additional information about their data processing practices.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at privacy@vfolio.ai.

Data Transfer

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at privacy@vfolio.ai.

Use of your personal data for marketing purposes

We may use your personal data for marketing purposes, including to form a view on what we think may be of interest to you, and to decide which products, services, and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, if you have consented to our use of your personal data for marketing purposes.

Automatic Decision-Making and Profiling

We do not currently make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects concerning you.

Data Subject Rights

If you are situated in the EEA, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully; or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Lodge a complaint with a supervisory authority. If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance.

To exercise your rights under the GDPR or to submit a complaint regarding our privacy practices, please contact us at privacy@vfolio.ai. Please note that in order for you to assert your data subject rights, we may need to verify your identity. This is a security measure to ensure that your personal data is not wrongfully modified or deleted, or disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

Cross-Border Data Transfers

If you submit personal data to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal data to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers.

Children's Privacy

Our Services are intended for users ages 18 and over, and we do not knowingly collect personal data from children under the age of 18. The App is designed for use by adults, including finance professionals, business users, and individuals managing their own documents, and is not directed at children. When we become aware that personal data (or other information that is protected under applicable law) from a child under 18 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal data from or about a child under 18, please contact us by using the information in the section below titled Contacting Us.

Changes to This Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Website for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will provide notice through the App or by email to the address associated with your account before those changes take effect. Your continued use of the Services following the posting of any changes to this Privacy Policy means you accept such changes.

Contacting Us

If you have any questions about our privacy or security practices, you can contact us at privacy@vfolio.ai.