Privacy Policy

This Privacy Policy (the "Policy") describes how Vale Finance LLC ("Vale", "we", "us" or "our") collects, uses, stores and discloses information in connection with the vale.money platform and the related websites, applications, portfolio connectivity features, research tools and paid subscription services.

This Policy applies to information we collect directly from you, automatically through your use of the service, from connected portfolio providers, from authentication providers, and from third parties that assist us in operating Vale.

This Policy does not apply to third-party services that may integrate with Vale or be linked from Vale, except to the extent that we receive information from them or use them as service providers.

The processing of personal data is governed by Argentine Personal Data Protection Law No. 25,326 ("LPDP") and the regulations in force issued by the Agencia de Acceso a la Información Pública ("AAIP"). To the extent that users from other Latin American countries use the service, local data protection rules in those jurisdictions may also apply.

Depending on how you use Vale, we may collect the following categories of data:

• Account and identity data, such as name, email address, sign-in method and account identifiers.
• Profile and preference data, such as watchlists, saved configurations, alert criteria, notification preferences, onboarding responses, feature choices and device or push notification tokens, where applicable.
• Portfolio and connectivity data, such as holdings, positions, balances, transactions, account metadata and connection status returned through broker integrations.
• Messages, file uploads, feedback and other content that you submit through chat or other platform flows.
• Subscription and billing data, such as plan type, billing status, renewal dates, invoices and limited payment metadata provided by the applicable payment processors.
• Usage, device and technical data, such as IP address, device identifiers, browser type, operating system, application events, error logs, referral URLs and interaction data.
• Cookies, local storage and similar data used for authentication, security, preferences, analytics and service performance.

We use the information we collect for the following purposes:

• To provide, maintain, secure and improve the service.
• To create and manage your account and authenticate access.
• To power portfolio-aware research features, analytics, summaries, screeners, watchlists, alerts, notifications and related automations.
• To generate, classify, summarize and deliver AI-assisted responses based on your data and available information.
• To process subscriptions, payments, renewals, refunds and account support requests.
• To detect fraud, abuse, security incidents and violations of our Terms and Conditions.
• To measure product usage, improve reliability and develop new features.
• To comply with legal obligations and enforce our rights.

We may combine information collected from different sources in order to operate the service more effectively, personalize product functionality, detect abuse and improve reliability.

When you choose to connect a broker account, connectivity is established directly through official, publicly available APIs published by those brokers for such purposes. We use connected portfolio data to support research features, analytics, summaries, alerts, portfolio-aware chat and other features you request.

Portfolio connectivity is designed to be read-only on Vale's side. We do not use connected portfolio data to place trades on your behalf through the current service.

Broker data may be delayed, incomplete or inconsistent with your broker's official records. You should consult your broker and custodian for official account information.

If you create alerts or enable push, email, SMS or in-app notifications, we may use your alert settings, watchlists, portfolio context, device tokens, communication preferences and other relevant product data to generate and deliver those messages.

Notification delivery may depend on external messaging, mobile platform, email or infrastructure providers. Messages may be delayed, suppressed, undelivered or affected by your device, carrier, browser, operating system, permissions or network conditions.

We may share information in the following circumstances:

• With service providers that assist us in operating Vale, such as hosting, infrastructure, analytics, customer support, authentication, payments, communications, AI providers for current features, and portfolio connectivity providers.
• With market data, public data and content providers, as necessary to power product features.
• When you instruct us to connect an account, export information or use a third-party integration.
• Where required by law, subpoena, court order, regulation or legal process, or where we believe disclosure is necessary to protect rights, safety or the integrity of the service.
• In connection with a merger, financing, acquisition, reorganization, bankruptcy or sale of all or part of our business.

We may also disclose anonymized or aggregated information that does not reasonably identify you, subject to applicable law.

We do not sell your connected portfolio holdings or transaction history at an individually identifiable level.

We may create and use aggregated or anonymized analytics, trends, benchmarks and product insights that do not reasonably identify you, subject to applicable law.

If applicable privacy law treats certain data sharing for analytics or advertising as a "sale" or "transfer", your rights may depend on your jurisdiction and on the specific data involved. You may contact us for more information about how those rules apply.

Vale features that process your messages, portfolio context and other user-specific data rely on artificial intelligence model providers acting as service providers or processors under their applicable terms.

Because AI features are part of the service, your messages and related context may be processed to generate responses, improve reliability, monitor for abuse and support feature quality. Do not submit information that you do not want processed for those purposes.

Vale may reference, display, compare or analyze outputs from different model providers on public, editorial, benchmarking or experimental surfaces. Such references do not by themselves imply that your private messages or connected portfolio data are sent to those providers.

We use cookies, local storage, SDKs and similar technologies for authentication, session management, security, remembering preferences, measuring product usage and understanding performance.

You can control certain cookie settings through your browser or device settings, although disabling them may affect the functionality of the service.

Our websites and applications may not respond to all browser-based "Do Not Track" signals or other similar preference signals, except where required by applicable law.

We apply administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse or alteration. Such measures may include encryption in transit, access controls, environment segregation, audit logs and vendor management.

No security program is perfect, and we cannot guarantee absolute security or that unauthorized access will not occur.

We retain information for as long as reasonably necessary to provide the service, maintain security, comply with legal obligations, resolve disputes, enforce agreements and support legitimate business operations.

Retention periods vary depending on the type of data, user settings, subscription status, backup cycles and legal requirements. Some information may persist in backups or archives for a limited period after deletion.

We may also retain information necessary to detect fraud, prevent abuse, enforce our agreements, resolve disputes or comply with tax, accounting, recordkeeping and legal obligations.

Under Argentine Law No. 25,326 and AAIP regulations, you have the right to:

• Access your personal data held in our records.
• Rectify inaccurate, incomplete or outdated data.
• Request the deletion of your personal data where no legal obligation to retain it exists.
• Disconnect linked broker accounts or request the deletion of the associated portfolio data.
• Object to or restrict certain processing where permitted by law.
• Manage subscription renewals through the applicable billing provider.

To exercise these rights, contact us at legales@vale.money. We may need to verify your identity before acting on certain requests.

Some rights are subject to exceptions under applicable law. For example, we may need to retain certain records for billing, security, fraud prevention, legal compliance or internal business purposes permitted by law.

If you believe that the processing of your personal data violates applicable regulations, you have the right to file a complaint with the Agencia de Acceso a la Información Pública (AAIP), the data protection supervisory authority in Argentina.

Vale and its service providers may process and store information in Argentina and in other countries, including the United States, where privacy protections may differ from those in your home jurisdiction.

Under Argentine Law No. 25,326, international transfers of personal data to countries or international organizations that do not provide adequate levels of protection require compliance with the conditions established by the AAIP. By using the service, you understand that your information may be transferred to and processed in those jurisdictions, subject to applicable law.

If you close your account or request deletion, we will take reasonable steps to delete or de-identify eligible information within a commercially reasonable period, subject to backups, technical limitations, legal obligations, dispute resolution needs and fraud prevention requirements.

Disconnecting a broker account will stop future syncing, but may not automatically delete historical data already stored in Vale unless you also request its deletion where applicable.

Vale is not directed to individuals under 18 years of age, and we do not knowingly collect personal information from anyone under 18. If we become aware that we have collected data from a minor without appropriate parental consent, we will take steps to delete that information.

If we offer services in the future that require separate legal notices, financial privacy notices, broker-dealer disclosures, investment adviser notices or other regulated agreements, those services may be governed by additional or different privacy disclosures, in accordance with CNV rules and other applicable regulation.

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and update the effective date shown at the beginning of the document. In the event of material changes, we will seek to notify users through the communication channels available on the platform.

Privacy inquiries may be sent to legales@vale.money. For general or support inquiries, you may write to soporte@vale.money.

Vale Finance LLC · 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, United States.