Privacy Policy

Effective July 29, 2026 · Early-access version — we may update this policy as the product develops.

Shepherd is in early access. This Privacy Policy covers the website and waitlist available today, as well as the Shepherd application and its features as they launch. It explains what information Shepherd Finance collects, why we use it, and the choices available to you.

Who we are & scope

Shepherd Finance ("Shepherd," "we," or "us") provides a software interface for portfolio analysis and trade execution through venue accounts that users own and choose to connect. This policy applies to shepherdfinance.com and the Shepherd application. It does not govern third-party wallets, trading venues, or other services you connect, which have their own privacy practices.

Information we collect

Today, on this website. We collect the email address you submit to join the waitlist. If you provide them, we also collect an optional display alias and a referral code. We collect standard analytics events, such as page views, referral information, and interactions with the site, to understand how the website is used.

When you use the Shepherd application. Depending on the features you choose, we collect:

• your account email and an optional Telegram chat ID if you link Telegram;
• wallet addresses you choose to add, including connected or watched wallets, which are public addresses only;
• venue-connection identifiers, such as an API-wallet public key or account ID, needed to connect the accounts you select;
• subscription and payment records, while payment-card details go directly to Stripe and we never see or store full card numbers; and
• usage and security logs, including IP address and user agent, used to operate, protect, and troubleshoot the service.

What we never collect

How we use information

We use information to:

• provide, maintain, and operate Shepherd and its features;
• manage the waitlist and send product or availability communications;
• send transaction, account, and receipt emails;
• measure usage, troubleshoot issues, and improve the product;
• protect the service and prevent fraud, abuse, and security threats;
• meet applicable legal and regulatory obligations.

We do not sell personal information. We do not share personal information for targeted advertising.

Who we share it with (service providers)

We share only the information reasonably needed for providers to perform services for us or to complete an action you request. These providers and recipients include:

• Vercel for website and application hosting;
• Resend for waitlist, account, and transactional email delivery;
• PostHog for product analytics and understanding how our services are used;
• Stripe for subscription and payment processing;
• Privy for authentication and wallet infrastructure;
• AI model providers to process the prompts and relevant portfolio or market context needed to provide the analysis you request; and
• trading venues and data providers you choose to connect, to retrieve requested information or carry out the actions you direct.

These third parties may process information under their own terms and privacy policies where you have a direct relationship with them. We may also disclose information when required by law or when reasonably necessary to protect the rights, safety, and integrity of Shepherd, our users, or others.

Cookies & analytics

We use essential cookies and similar technologies needed for the site and application to function, such as maintaining sessions and protecting requests. We also use analytics to understand traffic, feature use, and product performance. Your browser may let you block or delete cookies, but disabling essential cookies can prevent parts of the service from working.

Data retention

We keep personal information while your account or waitlist entry is active, or for as long as reasonably needed for the purposes described above, including security, dispute resolution, and legal or recordkeeping obligations. You may ask us to delete your information. We will honor a valid request unless we need to retain certain records for legal, security, fraud-prevention, or other permitted purposes.

Security

We use safeguards appropriate to the information we handle, including encryption of direct identifiers at rest, access controls, and data minimization. No transmission or storage method is 100% secure, so we cannot promise absolute security.

Your rights

Depending on where you live and subject to applicable exceptions, you may have rights to access, correct, delete, or receive a portable copy of your personal information. You can exercise these rights by emailing us at shepherdfinancebusiness@gmail.com. We may need to verify your identity before completing a request.

These rights apply as provided by relevant US state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act, and by the GDPR or UK GDPR for visitors in the EEA or United Kingdom. EEA and UK visitors may also have rights to restrict or object to certain processing and to complain to their local data protection supervisory authority.

Children

Shepherd is intended only for adults who are at least 18 years old. We do not knowingly collect personal information from children. If we learn that a child has provided personal information, we will take reasonable steps to delete it.

International transfers

Shepherd operates from the United States. If you access the website or application from another country, your information is processed in the United States, where privacy laws may differ from those where you live.

Electronic communications

By providing your email address, you consent to receive service communications electronically, including waitlist updates, account notices, receipts, and other information related to the services you request. You may unsubscribe from marketing messages using the link in those messages, but we may still send non-marketing communications needed to operate your account or provide requested services.

Changes to this policy

We may revise this policy as Shepherd develops or as our practices and legal obligations change. We will post the updated policy on this page and identify its new effective date.

Contact

For questions about this policy or Shepherd's privacy practices, or to submit a privacy request, email shepherdfinancebusiness@gmail.com.