Privacy Policy

This Privacy Policy describes how Tengu, Inc. (“Tengu”, “we”, “our”) collects, uses, shares, and protects information when you visit tengu.co, create an account, or use the Tengu platform (the “Service”).

Tengu is a software platform. We are not a broker-dealer, investment adviser, or custodian. Your funds and securities remain with whichever brokerage you connect to Tengu. We are, however, responsible for the data you give us about yourself and your accounts, and that is what this policy explains.

We collect information you give us, information we receive from your brokerage and other providers when you connect them, and information about how you use the Service.

Information you give us directly.

• Account information: name, email address, and an authentication credential (passwords are stored hashed, never in plain text).
• Profile and preferences you choose to share.
• Support, sales, and waitlist communications you send to us.
• Payment information you provide when purchasing a paid plan or a marketplace strategy. Card and bank details are processed by our payment processor and are not stored on Tengu’s servers in their raw form. Crypto payment addresses, when applicable, are stored in association with the corresponding purchase.

Information from your connected brokerage. When you connect a brokerage account through our integration partners (SnapTrade, Plaid, Interactive Brokers, Kraken, or any other connector we support), we receive read-only data such as account holdings, balances, recent orders, and identifiers needed to route trades. When you place a trade through Tengu, we receive the corresponding order and execution records.

Information from AI providers. When you use AI-assisted features, your prompts (and any portfolio context you choose to include) are sent to the model provider routing layer described in Section 5. Responses are returned to Tengu and to you.

Information collected automatically.

• Log data: IP address, browser/device type, OS, referring URL, pages viewed, timestamps.
• Approximate location derived from IP.
• Cookies and similar technologies described in our Cookie Policy.
• Product usage events (feature use, errors, performance metrics).

We use the information we collect to:

• Operate, maintain, and improve the Service, including authentication, account management, and trade routing.
• Display your portfolio, performance, and analytics to you.
• Provide AI-assisted features, including generating responses to your prompts and grounding those responses in data you have authorized Tengu to access.
• Process payments for paid plans and marketplace strategies and pay out revenue share to strategy authors where applicable.
• Communicate with you about the Service, including service notices, product updates, and security alerts.
• Detect, investigate, and prevent fraud, abuse, market manipulation, and security incidents.
• Comply with our legal obligations and enforce our Terms of Service.
• With your separate consent, send marketing communications you can opt out of at any time.

If you are in the European Economic Area or the United Kingdom, we rely on one or more of the following legal bases to process your personal data:

• Performance of a contract, to operate the Service you have signed up for.
• Legitimate interests, to keep the Service safe, prevent fraud, secure our infrastructure, and improve the product, where those interests are not overridden by your fundamental rights.
• Consent, for non-essential cookies, marketing emails, and any other use that requires it under applicable law.
• Legal obligation, to comply with applicable laws and respond to lawful requests.

Tengu only shares information with the third parties we need to run the Service. We do not sell personal information.

• Brokerage connectors. SnapTrade, Plaid, Interactive Brokers, Kraken, and any other connector you choose. We share the identifiers and order instructions needed to read your positions and place trades you authorize. The brokerage holds your funds; Tengu does not.
• AI model providers. When you use AI-assisted features, prompts and selected context are routed to model providers including OpenAI, Anthropic, Google, xAI, and Perplexity. Each provider operates under its own terms and privacy policy. We do not allow these providers to use your prompts to train their public models where opt-out is available.
• Cloud infrastructure. We host the Service on Amazon Web Services in the United States. Backups, logs, and operational metadata may be stored in AWS-managed services.
• Payment processors. Card, bank, and crypto payments are processed by third-party processors that handle the sensitive elements of the transaction on our behalf.
• Operational vendors. Email delivery, customer support tooling, analytics, error tracking, and security monitoring providers, each under contractual confidentiality.
• Legal and safety. Law enforcement, regulators, courts, or other parties where we believe disclosure is required by law or necessary to protect the rights, property, or safety of Tengu, our users, or others.
• Corporate transactions. A buyer, successor, or affiliated entity in connection with a merger, acquisition, financing, or sale of assets, subject to a continuation of protections substantially equivalent to those in this policy.

Depending on where you live, you may have one or more of the following rights regarding the personal information Tengu holds about you:

• Access, ask for a copy of the personal information we hold about you.
• Correction, ask us to fix information that is inaccurate or incomplete.
• Deletion, ask us to delete your account and the personal information associated with it, subject to legal and operational retention requirements.
• Portability, ask for a copy of the personal information you provided to us in a structured, machine-readable format.
• Objection / restriction, object to or ask us to restrict certain processing.
• Withdraw consent, where processing is based on your consent.
• No discrimination: if you live in California, we will not deny service or charge a different price because you exercised your rights.

To exercise any of these rights, email support@tengu.co. We may need to verify your identity before responding.

We retain personal information for as long as we have an ongoing relationship with you and afterward only for as long as is necessary to:

• Comply with our legal, accounting, and reporting obligations (which may require us to retain trade-related records for several years).
• Resolve disputes and enforce our agreements.
• Preserve security and integrity of the Service and protect against fraud or abuse.

When we no longer need the information for one of these purposes, we delete or anonymize it.

Tengu encrypts data at rest using AES-256 and data in transit using TLS 1.3. Brokerage credentials are stored using envelope encryption with AWS KMS-managed keys. Production access is restricted, audited, and routed through OIDC-only continuous deployment.

No system is perfectly secure, and we cannot guarantee absolute security. See our Security page for additional detail on the controls we use.

The Service is not directed to anyone under 18. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, contact us at support@tengu.co and we will take appropriate steps to delete it.

Tengu is based in the United States and processes information there. If you access the Service from outside the U.S., your information will be transferred to, stored in, and processed in the U.S. and other countries where our service providers operate. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses) for cross-border transfers.

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last updated” date at the top. For material changes we will provide additional notice (for example, by email or an in-product notification) before the changes take effect.

If you have questions about this Privacy Policy or how Tengu handles your information, contact us at:

• Email: support@tengu.co
• Postal: Tengu, Inc. (address available on request)