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Privacy Policy

Effective Date: 12-Jun-2026

Version: 1.0

1. Introduction

Imperia Middleware Inc. (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of your information when you use the PortCall app (“the app”). This policy aligns with our Terms of Service and our written information security program.

2. Information We Collect

  • Account Information: Email address, authentication identifiers, subscription tier and status, and other information you elect to provide.
  • Date of Birth: Collected once at onboarding solely to verify that you are at least 21 years of age. We retain the date of birth (or a derived age-verification record) to enforce the age gate, including preventing repeated attempts to bypass it.
  • Portfolio Data: The stock ticker symbols you select for your portfolios. We do not collect brokerage account credentials, account numbers, position sizes, balances, or transaction history, and the app does not connect to your brokerage.
  • Listening and Usage Data: Which briefings are delivered and played, playback events, feature usage, device type, operating system, device identifiers (IDFV), and security-related metadata such as cryptographic public keys, nonces, and timestamps used for request authentication.
  • Microphone and Voice: The app does not access your microphone and we do not collect recordings of your voice. Voice interactions via Siri or CarPlay are processed by Apple under Apple’s terms, not by us.

3. How We Use Your Information

  • Generate and deliver audio briefings, including briefings personalized to the ticker symbols you select.
  • Operate shared rendering: briefing segments for a given ticker may be generated once and delivered to all users holding that ticker; this processing uses ticker symbols only, never your identity.
  • Manage subscriptions, billing status, and account services.
  • Enforce our Terms of Service, including age verification.
  • Communicate with you regarding updates, security alerts, and, only if you opt in, promotional offers.
  • Analyze usage to improve the app.

PortCall does not display third-party advertisements and we do not use your data for third-party advertising. If that ever changes, this policy will be updated first and consent obtained where required.

4. Data Sharing and Disclosure

We do not sell your personal data. We share information only as follows:

  • Service Providers: Third parties that provide identity management and authentication, cloud hosting and infrastructure, subscription verification, analytics, and customer support — including Apple, Amazon Web Services, and Google Cloud Platform. We require service providers to protect your data and to use it only for the purposes for which we engage them.
  • AI and Speech-Synthesis Providers: Briefing scripts are generated by third-party large-language-model providers and converted to audio by third-party speech-synthesis providers. The inputs to these providers are market data, news content, and ticker symbols — not your name, email address, or other directly identifying information. Aggregate portfolio composition (which tickers are held by how many subscribers) is used to schedule rendering and is not associated with your identity when transmitted.
  • Market Data Vendors: Market data is licensed from third-party vendors. We do not transmit your identity or your individual portfolio to market data vendors.
  • Emergency and Legal Disclosure: We may disclose personal information without prior consent where we reasonably believe disclosure is necessary to prevent imminent harm to Imperia Middleware, app users, other entities, or the public, or to comply with law enforcement requests, legal process, court orders, or regulatory obligations.
  • Record Retention and Tombstoning: We retain personal data only as long as reasonably necessary for the purposes in this policy or as required by law. Upon account deletion, minimal identifying information is retained as a cryptographically hashed record (“tombstone”) solely for compliance, security, and auditing purposes, including enforcement of the age gate.

5. User Rights and Choices

Under applicable laws, including GDPR and CCPA, you have rights to access, rectify, delete, port, restrict, or object to our processing of your data, and to opt out of any sale or sharing of your data (which we do not do), exercisable by emailing support@imperiamiddleware.com or through the app settings. You may withdraw previously given consent at any time; withdrawal does not affect the lawfulness of processing before withdrawal. Because the app’s core function is AI-generated content, the app cannot operate without the third-party AI processing described in Section 4; if you do not wish your portfolio selections to be processed as described, you may delete your portfolios or your account.

6. Data Security

We maintain a written information security program and implement industry-standard technical and organizational measures to safeguard your information. No method of transmission or storage is entirely secure, and you acknowledge the inherent risks of data transmission over the internet. In the event of a suspected or actual data breach involving your personal information, we will notify you and applicable regulators as required by law, including details of the breach and mitigation steps where applicable.

7. Children’s Privacy

PortCall is a 21+ service. It is not directed to children or to anyone under 21, and we do not knowingly collect personal data from anyone under 21 (and in no event from children under 13, consistent with the Children’s Online Privacy Protection Act). Age is verified at onboarding by date of birth, and under-age attempts are blocked at that screen. If we learn that a person under 21 has created an account, we terminate the account immediately and promptly and permanently delete the associated personal data. If you believe a person under 21 is using PortCall, contact us immediately at support@imperiamiddleware.com and we will act on the report without delay.

8. Data Retention

Account information and portfolio data are retained while your account is active and deleted or de-identified after account deletion, subject to the tombstone record described in Section 4 and any retention required by law. Age-verification records are retained as needed to enforce the age gate. Rendered briefing audio is shared content not associated with your identity and is retained according to our content archival schedule. A summary of our retention schedule is available on request.

9. International Data Transfers

Your personal information may be transferred to and processed in countries outside your home jurisdiction, including the United States, where data protection laws may differ from those of your jurisdiction. By using the app, you consent to this transfer, processing, and storage. Where required by law, we rely on appropriate transfer mechanisms, which may include your explicit consent, Standard Contractual Clauses, or other recognized safeguards.

10. Third-Party Links and Services

The app may reference or link to third-party websites or services, and operates within Apple platforms (including CarPlay) governed by Apple’s terms. We are not responsible for the privacy practices of third parties; please review their policies directly.

11. Warrant Canary

As of June 2026, PortCall has not received: any National Security Letter; any order under the USA PATRIOT Act, the Foreign Intelligence Surveillance Act, or similar statutes; or any other request or mandate from a government authority that would compel us to provide customer data in a manner we are prohibited from disclosing. We publish this statement periodically. If this section is removed or no longer updated, users should understand that the circumstances described above may have changed.

12. Policy Changes

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. Material changes will be communicated via the app or email. Continued use of PortCall after such notification constitutes acceptance of the changes.

13. Contact Information

For privacy-related questions or to exercise your rights, contact us at support@imperiamiddleware.com.