Privacy Policy

Effective October 28, 2026 · Early-access version — we may update this policy as the product develops.

Shepherd is in early access. This Privacy Policy covers this website and its waitlist. It explains what information Shepherd Finance collects when you visit or join, why we use it, and the choices available to you.

Who we are & scope

Shepherd Finance ("Shepherd," "we," or "us") is building a software interface for portfolio analysis and trading. This policy applies to shepherdfinance.com and its waitlist. The Shepherd application, when it launches, is covered by its own privacy policy.

Information we collect

When you visit or join the waitlist, we collect:

• the email address you submit to join, if you join with one;
• the ID of the account you signed in with (our sign-in provider, Privy, issues it), and, if you sign in with X or a wallet, an optional email address you give us so we can alert you;
• how you joined (email, or signing in with Google, Apple, X or a wallet), and whether a sign-in or an email code confirmed your email address;
• the referral code you arrived with, if any, your own referral code, and a custom code if you choose one;
• the leaderboard name we generate for you and your best score if you play the game on the waitlist page;
• your answers to the optional questions after you join, such as how you heard about us and which assets you are most interested in, and which optional X tasks you mark as done; and
• analytics events, such as page views, referral information, and interactions with the site (see Cookies & analytics below).

What we never collect

How we use information

We use information to:

• manage the waitlist and your place in it, including referrals;
• send waitlist updates and news about when Shepherd is available;
• measure how the site is used, fix problems, and improve it;
• protect the site and prevent fraud, abuse, and security threats — for example, we use your IP address to limit how many requests can be made, and we do not store it with your waitlist entry; and
• 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. These providers include:

• Vercel for website hosting, and our database and infrastructure providers to store and protect waitlist data;
• Resend for waitlist email delivery;
• Privy for sign-in when you join with Google, Apple, X or a wallet, and to email you a code when you confirm your email address;
• Cloudflare Turnstile to check that sign-ups come from people rather than automated scripts (it receives your IP address and basic browser signals from the sign-up page);
• PostHog for product analytics and understanding how the site is used; and
• Google Analytics for understanding how visitors find and use our website.

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 to function, such as keeping you signed in on this browser, so the page can show your place when you come back, and protecting requests. Your browser may let you block or delete cookies, but disabling essential cookies can prevent parts of the site from working.

We also use PostHog and Google Analytics to understand how the site is used. If you are in the European Economic Area, the United Kingdom or Switzerland, or your location is unknown to us, neither is loaded until you choose Accept on the cookie notice, and if you choose Decline neither is loaded. Everywhere else they are on by default and you can turn them off with Cookie settings at the bottom of this page; if your browser sends a Global Privacy Control signal, we treat it as that choice and leave them off. You can change your choice at any time with Cookie settings. When they are on, they count the pages you visit and the buttons you click. We may record anonymous sessions to improve this site; we never record what you type. We do not identify you to either by your email address, and we strip it from every event we send them.

Data retention

We keep your waitlist information while your 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 email addresses 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 privacy@shepherdfinance.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 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 waitlist communications electronically, including waitlist updates and news about when Shepherd is available. You may unsubscribe from marketing messages using the link in those messages.

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 privacy@shepherdfinance.com.