Dversify — Privacy Notice

Dversify AI LLC is a technology company and is not an investment adviser, broker-dealer, bank, tax-preparation firm, or law firm. Dversify Advisors LLC is the registered investment adviser that provides the subscription advisory service. The two companies are under common ownership and share the platform under a written intercompany agreement; Dversify AI processes advisory-client information as Dversify Advisors’ service provider under confidentiality obligations. This Notice covers dversify.ai, your account, the advisory service, free tools, Ask Warren, and our communications with you.

• Account and contact information — name, email, phone, state of residence, login credentials (from you or your sign-in provider), preferences, and support messages.
• Financial, tax, and planning information — the information you enter and the documents you upload to generate reports: income, assets, liabilities, accounts and holdings, tax returns and tax forms, insurance, estate details, goals, and information about household members you choose to include.
• Generated outputs and conversations — the reports and analyses generated for you, the versions of the models and templates that produced them, and your Ask Warren conversations.
• Subscription and payment information — package, billing status, and transaction records. Card and bank details are collected and stored by our payment processor (Stripe); we do not store full payment-card numbers.
• Identity-verification information, where required, collected through vendors we use.
• Technical and usage information — IP address, device and browser type, pages viewed, actions taken, timestamps, cookies and similar identifiers, and diagnostic logs.
• Records of disclosures and consents — when you were delivered the Form ADV brochure and when you accepted the Investment Advisory Agreement and the automatic-renewal consent, including the document versions.

• to create and manage your account and authenticate you;
• to generate the reports, analyses, and assistant responses you request, and to correct reported errors;
• to deliver required disclosure documents, invoices, and account notices;
• to process subscription payments and manage renewals and cancellations;
• to operate, secure, monitor, test, and improve the platform, including quality control on outputs;
• to respond to support requests and communicate about your account and our services;
• to keep the books and records that securities regulations require of Dversify Advisors;
• to measure the effectiveness of our advertising (see Section 7); and
• to comply with law, respond to lawful requests, protect rights and safety, and enforce our terms.

We do not use your financial information, documents, reports, or conversations to train machine-learning models, and we do not use them for marketing unrelated products.

• Between Dversify AI and Dversify Advisors, as needed to deliver the advisory service and operate the platform, under the intercompany agreement and its confidentiality terms.
• Service providers acting on our behalf under contractual confidentiality and use restrictions — cloud hosting and storage, payment processing (Stripe), email delivery and records archiving, identity verification, customer support, analytics, and the model providers that power automated features. They may use your information only to provide services to us.
• Advertising measurement partners receive limited technical information through cookies and pixels as described in Section 7. We never send them your financial information, documents, or reports.
• At your direction — for example, when you download a report to share with your own professionals.
• Legal and safety — to comply with law, regulation, subpoena, or regulatory examination or request (including by the Texas State Securities Board or the SEC), and to protect our rights, our users, or the public.
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this Notice and, for advisory clients, the assignment terms of the Investment Advisory Agreement.

We do not sell personal information for money. Where a state privacy law treats advertising-measurement cookies as a “sale” or “sharing,” you can opt out as described in Sections 7 and 10.

This Section is Dversify Advisors LLC’s privacy notice under Regulation S-P and its Texas analog, delivered when you become a client and annually thereafter.

Information we collect about you as a client includes the information you provide in the platform’s data-collection process and documents you upload; information about your transactions with us (subscription and payment history); and information generated in providing the service (reports, model and template versions, communications).

Information we disclose. We do not disclose non-public personal information about current or former clients to anyone except as permitted or required by law — to our affiliate Dversify AI LLC and to service providers who perform services on our behalf under confidentiality obligations; at your direction; and to regulators, auditors, and others as required by law. We do not share your non-public personal information with non-affiliated third parties for their own marketing, so no opt-out is needed.

How we protect it. We maintain physical, electronic, and procedural safeguards that comply with applicable regulations, including the measures in Section 8, and we restrict access to personnel and service providers who need it to provide services to you.

Former clients. These practices continue to apply after your relationship with us ends.

Reports are generated by software models; Ask Warren uses large language models. Your information is processed by those systems, and by the model providers that power them, solely to generate your outputs. It is never used to train machine-learning models — ours or anyone else’s — and our contracts with model providers prohibit training on your data.

We and our vendors use cookies and similar technologies for session management, security, and usage analytics. We also use advertising pixels (currently the Meta Pixel) to measure whether our advertising leads to sign-ups and subscriptions; these pixels may receive your IP address, device information, the pages you visit on dversify.ai, and events such as starting a checkout, together with a package name and price — never your financial information, documents, or reports. You can limit cookies through your browser, opt out of Meta’s use of your data through your Meta account settings, and use the opt-out methods in Section 10. We honor Global Privacy Control signals where required by law.

Your data is processed on ISO/IEC 27001-compliant cloud infrastructure, encrypted in transit and at rest, protected by role-based access controls and multi-factor authentication for administrative access, monitored, and covered by written cybersecurity and business-continuity policies that are reviewed at least annually. Advisory-client records are maintained under Dversify Advisors’ control. No method of transmission or storage is completely secure; if a security incident affects your personal information we will notify you and any regulator as required by law.

We keep your information for as long as your account is active and as needed to provide services and meet legal, regulatory, tax, and accounting obligations. Securities regulations require Dversify Advisors to retain client agreements, the information supplied for advice, the advice generated, and related communications for at least five years after the relationship ends; those records are kept for the required period even if you close your account or request deletion, and are deleted or anonymized afterward. To request deletion of other information, see our Data Deletion page.

You can review and update account information in your dashboard. Depending on your state, you may have the right to access, correct, delete, or obtain a portable copy of your personal information, to opt out of targeted advertising or “sharing,” and to appeal a decision on your request. To exercise rights, email support@dversify.ai from your account email; we will verify your request and respond within the time the law allows. We do not discriminate against you for exercising your rights. You can unsubscribe from marketing email using the link in any message; service and regulatory notices continue while you have an account.

The platform is for adults. Advisory services are available only to individuals 18 or older, and the platform is not directed to children under 13; we do not knowingly collect personal information from children under 13 and will delete it if we learn we have.

We may update this Notice. We will post the updated Notice with a new effective date and, for material changes, notify you by email or in the platform. Advisory clients receive this Notice initially and annually.

Dversify AI LLC · Dversify Advisors LLC
501 S Austin Ave, Suite 1220, Georgetown, TX 78626 · 888-415-6112
Privacy and support: support@dversify.ai · Compliance (Dversify Advisors): compliance@dversify.ai