Privacy Policy

Effective Date: October 25, 2025
Last Updated: October 25, 2025

Aculis Inc. (“Aculis,” “we,” “us,” or “our”) builds AI-powered workflow and automation software for financial services organizations and professionals. We respect your privacy and are committed to protecting it.

This Privacy Policy explains how we collect, use, and protect your personal information when you use our websites, applications, and related services (together, the “Services”).

By using our Services, you agree to the terms of this Privacy Policy.

1. Who We Are

Aculis Inc.
16192 Coastal Hwy, Lewes, DE 19958
Email: privacy@aculisai.com

If you have questions or concerns about this policy or your data, please contact us at the email above.

2. What We Collect

The information we collect depends on how you interact with our Services. It may include:

Account and Profile Information
Name, business email, company, role, password or SSO identifiers, preferences, and communication settings.

Customer Content and Model Inputs
Text, documents, emails, calendar entries, CRM data, and other content you upload or connect to our Services. We also process prompts and AI-generated outputs.

Usage and Device Data
Log files, device type, browser, operating system, IP address, timestamps, and performance metrics to ensure reliability and security.

Integration Data
Metadata and content from third-party systems you connect (like email, calendar, CRM, or portfolio systems) within authorized scopes.

Support and Communication Data
Messages, tickets, or other communications with our support team.

Payment and Billing Information
Billing contact info and payment method tokens. Payment details are processed securely through our payment provider (Stripe); we do not store full card numbers.

Cookies and Analytics
We use cookies and similar technologies for security, functionality, and analytics. You can adjust cookie preferences in your browser settings.

3. How We Collect Information

We collect information:

• Directly from you when you create an account or use our Services

• Automatically through device and usage logs

• From integrated third-party services (only within scopes you approve)

• Through customer support interactions

4. How We Use Information

We use your information to:

• Provide, maintain, and improve our Services

• Operate our self-hosted AI models and integrations

• Communicate with you and provide support

• Detect, prevent, and respond to security issues or fraud

• Comply with legal and regulatory requirements

• Improve system reliability and performance

We do not sell or share personal information for advertising or marketing purposes.

5. Our AI Model Practices

• Self-Hosted Models: All Aculis models and inference systems are hosted and operated by us on Microsoft Azure.

• No Third-Party AI Providers: We do not send your data or prompts to third-party model vendors.

• Training: Customer content is not used to train our foundation models unless explicitly agreed to in writing.

• Evaluation: We may use anonymized or aggregated data for system quality and reliability testing.

• Human Access: Human review is strictly limited to debugging, support, or security events, with all access logged and restricted.

6. Data Retention

We retain data in accordance with applicable financial services regulatory requirements and customer agreements.
When retention periods expire or accounts are closed, data is securely deleted or anonymized unless longer retention is required by law.

7. How We Share Information

We may share limited data with:

• Service Providers: Including Microsoft Azure (hosting), SendGrid (email delivery), Stripe (billing), and other standard SaaS infrastructure providers under strict data-processing agreements.

• Your Organization: If you access Aculis through an employer or firm, your administrators may have access to your account data.

• Legal or Regulatory Requests: Only when required by law or regulation.

• Business Transfers: In case of merger, acquisition, or asset sale, subject to continued protection under this policy.

We do not sell or share personal information for behavioral advertising.

8. Data Storage and Security

All data is stored in Microsoft Azure data centers located in the United States.
Regions are selected based on availability, dependability, and scaling capacity.

We apply strict security controls including:

• Encryption in transit and at rest

• Azure Key Vault key management

• Role-based access, SSO, and MFA for administrators

• Continuous monitoring, logging, and intrusion detection

• Regular penetration testing and vulnerability management

• Disaster recovery and business continuity systems

If a security incident occurs, we will notify affected parties as required by law.

9. Your Rights and Choices

Depending on where you live (e.g., California or Canada), you may have the right to:

• Access or request a copy of your personal data

• Correct or delete your data

• Restrict or object to processing

• Opt out of marketing communications

• Request information about how your data is used or shared

To exercise your rights, email us at privacy@aculisai.com.
We will respond as required by applicable law.

10. California Residents (CCPA / CPRA)

If you are a California resident, you have the following rights under the CCPA/CPRA:

• The right to know what personal information we collect, use, or disclose

• The right to request deletion of your personal information

• The right to correct inaccurate data

• The right to opt out of the sale or sharing of your personal information (we do not sell or share it)

• The right to limit the use of sensitive information

You can submit requests by contacting privacy@aculisai.com.

11. Canadian Residents (PIPEDA)

For users in Canada, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA).
You have the right to access, correct, or withdraw consent for the use of your personal information.
Requests can be made at privacy@aculisai.com.

12. Children’s Privacy

Our Services are designed for professional users.
We do not knowingly collect data from children under the age of 13.
If you believe a child has provided us with personal information, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time.
The updated version will always be available at www.aculisai.com/privacy with a new “Last Updated” date.
We encourage you to review it periodically.

14. Regulatory Disclosure

Aculis Inc. is not a registered investment adviser, broker-dealer, or fiduciary under the Investment Advisers Act of 1940, FINRA, or any other federal or state securities laws.

Our Services and any outputs produced by our AI models are for informational purposes only and should not be interpreted as investment, legal, tax, or financial advice.
All decisions made based on the use of Aculis or its outputs are the sole responsibility of the user.

If you are a registered financial professional or organization, you remain solely responsible for ensuring that your use of the Services and any data, insights, or communications generated by Aculis comply with all applicable laws, regulations, and internal policies.

Aculis operates strictly as a technology and data processing provider, not as a party to any advisory or fiduciary relationship.

15. Contact Us

Aculis Inc.
16192 Coastal Hwy, Lewes, DE 19958
Email: privacy@aculisai.com
Support: help@aculisai.com
Website: www.aculisai.com