Privacy Policy

1. General Information

This Privacy Policy describes how Wealthy Pockets d/b/a Acclr8 (“Acclr8”, “we”, “our” or “the Company”) collects, uses, shares, and protects the personal information of users (“you”, “your” or “User”) of our websites www.acclr8.net, www.acclr8.com, mobile applications, and related educational services (collectively, the “Services”). By using our Services, you accept the practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

• Full name
• Email address
• Phone number
• Physical address
• Payment information (processed by secure third parties)
• Photo identification and signature information
• Basic demographic information
• Financial information relevant to educational services

2.2 Information Collected Automatically

• IP address and geographic location
• Device type and operating system
• Browser information
• Pages visited and browsing time
• Cookies and similar technologies
• Application activity logs
• Interactions with educational content

2.3 Information from Third Parties

• Social media information (if you choose to connect accounts)
• Information from payment processors
• Data from digital marketing platforms

3. How We Use Your Information

3.1 Service Delivery

• Provide access to educational content and teaching materials
• Process enrollments and payments
• Facilitate participation in seminars, videoconferences, and forums
• Provide technical support and customer service
• Personalize your educational experience

3.2 Communications

• Send updates about courses and services
• Notify changes in terms and policies
• Provide relevant educational information
• Respond to inquiries and support requests

3.3 Service Improvement

• Analyze platform usage and performance
• Develop new products and services
• Conduct market research
• Optimize user experience

3.4 Legal Compliance

• Comply with legal and regulatory obligations
• Protect user rights and security
• Prevent fraud and illicit activities
• Respond to legal processes

4. Legal Basis for Processing

We process your personal information based on:

• Consent: When you expressly authorize us
• Contract: To fulfill our educational services
• Legitimate Interest: To improve services and communications
• Legal Obligation: To comply with legal requirements

5. Sharing Information

5.1 No Sale of Data

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

5.2 Authorized Sharing

We may share information with:

• Service Providers: Payment processors, technology platforms, marketing services
• Educational Partners: Authorized instructors and mentors
• Legal Authorities: When required by law
• Rights Protection: To protect our legal rights

5.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your information may be transferred as part of the transaction.

6. Data Security

We implement appropriate technical and organizational measures:

• Encryption of data in transit and at rest
• Restricted access controls
• Continuous security monitoring
• Staff privacy training
• Regular security audits

No system is completely secure. We cannot guarantee absolute security against unauthorized access, loss, or alteration of data.

7. Data Retention

We retain your personal information:

• During the duration of your membership or subscription
• For periods required by law
• Up to 5 years after the contractual relationship ends
• As long as necessary for legitimate business purposes

Data is securely deleted at the end of the retention period.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

Access & Control

• Access: Request a copy of your personal information
• Rectification: Correct inaccurate or incomplete data
• Deletion: Request deletion of your data
• Portability: Obtain your data in a structured format
• Restriction: Limit the processing of your data

Communication Rights

• Objection: Object to certain uses of your data
• Revocation: Withdraw previously granted consent
• Opt-out: Choose not to receive marketing communications

To exercise these rights, contact us at: support@acclr8.net

9. Cookies & Similar Technologies

We use cookies for:

• Essential site functionality
• Performance analysis
• Content personalization
• Marketing and advertising

You can control cookies through your browser settings, our site preference tools, or third-party provider opt-out mechanisms.

10. Minors

Our services are intended for individuals 18 years of age and older. We do not intentionally collect information from minors. If we identify data from minors, we will promptly delete it.

11. International Transfers

Your information may be transferred and processed in countries outside your residence, including the United States. We implement appropriate safeguards to protect your data in international transfers.

12. Third-Party Providers

We work with trusted third parties for:

• Payment processing
• Cloud and hosting services
• Digital analytics and marketing
• Technical support

Each third party has its own privacy policies. We are not responsible for the privacy practices of third parties.

13. Changes to This Policy

We may update this Privacy Policy periodically. Significant changes will be notified through:

• Notice on our website
• Email to registered users
• In-app notifications

Continued use of our services after changes constitutes acceptance of the updated policy.

14. Regulatory Compliance

This policy complies with applicable regulations including:

• California Consumer Privacy Act (CCPA)
• United States federal regulations
• Florida privacy laws
• International data protection standards

15. ZION AI Platform — Data Collection & Processing

ZION AI is a general-purpose artificial intelligence assistant that also provides specialized trading, strategy-building, and financial planning features. ZION collects and processes additional categories of data across all types of interactions — including general conversation, research, education, creative tasks, and financial services. This section describes the specific data practices associated with ZION AI.

15.1 AI Conversation & Interaction Data

• All conversational inputs, prompts, questions, and instructions you provide to ZION AI across any topic or use case
• AI-generated outputs including text responses, research, creative content, code, strategies, Expert Advisors, and analysis
• Trading strategies, parameters, and criteria you define
• Files, documents, and media you upload or share with ZION AI
• Voice interaction recordings and transcriptions (via ElevenLabs)
• User feedback, ratings, and corrections provided to improve AI responses
• Session metadata including timestamps, duration, and feature usage

15.2 Brokerage & Trading Data

• Brokerage account identifiers and connection credentials (via MetaAPI)
• Trade history, open positions, and pending orders
• Account balance, equity, and margin information
• Automated strategy operation logs and performance data
• Expert Advisor deployment and operational data

15.3 Financial Account Data

• Bank account information accessed through Plaid (account numbers, routing numbers, balances, and transaction history)
• Cryptocurrency exchange account data (via Coinbase and Binance APIs)
• Payment transaction records (via Stripe)
• Cryptocurrency portfolio holdings and transaction history

15.4 Market & Analytics Data

• Market data and price feeds (via TradingView and CoinGecko)
• Backtesting results and simulated performance data
• Trading pattern analysis and behavioral metrics
• Tax planning data and financial report compilations

16. How ZION AI Uses Your Data

16.1 AI Model & Personalization

• Process your instructions to build and deploy trading strategies
• Learn your trading patterns and preferences to improve AI responses
• Generate personalized Expert Advisors and automated systems
• Provide contextual market analysis based on your portfolio and preferences
• Generate tax planning spreadsheets and financial compilations

16.2 Trade Execution

• Relay your automated strategy instructions to your connected broker account
• Monitor open positions and manage risk parameters you have defined
• Generate alerts and notifications based on your configured strategies

16.3 Third-Party Data Sharing for ZION AI

To provide ZION AI features, your data may be shared with:

• MetaAPI: Brokerage connection data and strategy relay instructions
• Plaid: Bank account authentication and financial data retrieval
• Stripe: Payment processing and subscription management
• Coinbase & Binance: Cryptocurrency account data and exchange operations
• CoinGecko: Cryptocurrency market data queries
• ElevenLabs: Voice audio data for speech processing and synthesis
• TradingView: Market data rendering and chart interactions
• AI model providers: Anonymized or pseudonymized conversation data for processing (not used to train third-party models)

Important: Each third-party provider operates under its own privacy policy and security practices. We recommend reviewing the privacy policies of MetaAPI, Plaid, Stripe, Coinbase, Binance, CoinGecko, ElevenLabs, and TradingView. Acclr8 is not responsible for the data practices of these third parties once your data has been transmitted to them.

17. ZION AI Data Security & Credentials

• Brokerage API credentials are encrypted at rest and in transit using industry-standard encryption protocols. Acclr8 does not store your broker login password directly; connections are maintained through secure API tokens.
• Bank account connections through Plaid use Plaid's tokenized authentication — Acclr8 never receives or stores your bank login credentials.
• Cryptocurrency exchange API keys are stored with restricted permissions as configured by you. We recommend using read-only or trade-only permissions without withdrawal access.
• Voice data transmitted to ElevenLabs is processed in real-time and is not permanently stored by Acclr8 unless you opt into conversation history features.
• AI conversation logs containing financial data are encrypted and access-controlled. You may request deletion of your conversation history at any time.

18. ZION AI Data Retention

In addition to the general data retention policies above, the following retention periods apply to ZION AI data:

• AI conversation history: Retained for the duration of your active subscription plus 90 days, unless you request earlier deletion
• Trading strategy configurations: Retained for the duration of your subscription; exported to you upon request before deletion
• Strategy operation logs: Retained for 7 years to comply with financial record-keeping regulations
• Brokerage API tokens: Revoked and deleted immediately upon account disconnection or subscription termination
• Bank connection tokens (Plaid): Revoked and deleted immediately upon disconnection
• Voice recordings: Deleted within 30 days unless required for dispute resolution
• Tax planning data: Retained for 7 years to comply with tax record-keeping requirements

19. Contact

For questions about this Privacy Policy or your privacy rights: