Privacy Policy

Last updated: October 3, 2026

This Privacy Policy describes how Dependable Income Investing LLC, a Wyoming company ("Company," "Us," or "We"), handles personal data in connection with our websites, newsletters, social media groups, mobile applications, and products and services (collectively, the "Service").

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you. The types of data we collect are listed below.

Personal Data

Access to Our Service granted after registering an account, for that purpose you provide us an email address and name of account. Once you register and sign in to our Service, you are not anonymous to us. If you want to buy a subscription, we may need your first name, last name and phone number. To provide you analytics and other information about your investing results you provide us your Portfolio Data (can include transactions). We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

We use Transport Layer Security (TLS) encryption technology in order to protect certain information that you submit to us. This technology protects you from having your information intercepted by anyone while it is being transmitted to Dependable Income Investing LLC or payment processor.

Usage Data

To make our Service better we may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may including information, but not limited to, such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Usage Data includes the following:

• Internet Protocol (IP) address of computers accessing the site
• Web page requests
• Referring web pages
• Browser used to access site
• Time and date of access

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and to store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. More info at "Cookie and local storage usage policy" paragraph below.

Free fund comparison tool and abuse prevention (unsigned use)

When you use our free fund comparison tool without signing in, we use a security challenge (Cloudflare Turnstile) and a browser-based identifier from FingerprintJS (loaded with our site) to limit automated abuse. These technologies may process technical data such as IP address, browser characteristics, and device signals. That processing occurs on your device and, where applicable, through service providers we use (including Cloudflare, FingerprintJS / Fingerprint, and Supabase, which hosts our application data).

We store only short-lived records needed to count requests (for example, a key that can include IP address and the browser identifier). Those records are automatically deleted within about 24 hours. We do not use this information for advertising, do not sell it, and do not build a marketing profile from it.

Referral program (ref parameter)

When you arrive on our app with a referral link that includes a ref parameter (for example ?ref=example-slug), we may save that referral identifier in a first-party browser cookie and in localStorage on our app’s domain so we can attribute your signup to the correct partner if you later create an account. We use a first-touch rule: the first non-empty ref value we store in that browser wins until it expires. These entries are kept for up to 90 days (then they expire or are overwritten per our implementation). They are used only to operate our referral program (for example, recording which affiliate referred a new user when permitted by our rules), not for third-party advertising. We do not sell this identifier by itself as a product.

Abuse prevention when you are signed in

If you sign in, we may apply similar abuse-prevention limits using your account ID instead of or in addition to browser/IP signals.

Website hosting (Netlify)

Our website files are served from Netlify; Netlify may process standard server/access logs (such as IP and request metadata) under its own privacy policy.

Data we receive from third parties

When you sign in to your account using your social internet service credentials (Facebook, Twitter, Google, Yahoo!, LinkedIn), such service sends us your username and the email address associated with the credentials you've used. We neither control nor take any responsibility for the way third parties provide information about you and/or process your personal data.

Brokerage connections (SnapTrade)

If you choose to connect a brokerage account to the Service, we use a third-party service provider, Passiv Inc. (doing business as SnapTrade) ("SnapTrade"), to facilitate a read-only connection between your brokerage and our Service.

What we receive. When you connect, SnapTrade may provide us (and we may store a local copy of) brokerage / connected-account data such as:

• brokerage / institution name and connection status;
• account identifiers and account types;
• holdings and positions (for example symbol, quantity, and cost basis where the broker provides it);
• cash balances and related account balances where provided;
• orders, activities, and transactions (including dividends and corporate actions where provided);
• technical identifiers we need to operate the connection (for example SnapTrade user or connection identifiers we store).

What we do not receive. We never receive your brokerage login password or brokerage multi-factor authentication codes. You enter brokerage credentials only in SnapTrade's Connection Portal. SnapTrade holds connection credentials or tokens under its own security controls, including Amazon Web Services Key Management Service (AWS KMS) where applicable. AWS KMS is the Amazon service that creates and controls encryption keys. We do not see or store those brokerage credentials.

Who must accept SnapTrade's terms. Only users who use brokerage sync need to accept SnapTrade's End User Terms. Those terms are presented and accepted in SnapTrade's Connection Portal (not as a separate SnapTrade checkbox screen built by us).

Our disclosure. Before you open the Portal, we tell you that a third party (SnapTrade / Passiv Inc.) is used to connect brokerages. We may name SnapTrade in that disclosure.

Controller / processor. For brokerage data we obtain through SnapTrade and keep in our Service, Dependable Income Investing LLC is the organization responsible for how that data is used in our Service (our Privacy Policy is the user-facing policy for that use). SnapTrade acts as a processor / service provider for End User personal information on our behalf in connection with the connection and sync services, under SnapTrade's Developer Terms and Privacy Policy.

Links:

• SnapTrade End User Terms: https://snaptrade.com/terms-and-conditions
• SnapTrade Privacy Policy: https://snaptrade.com/privacy-policy

Use of Your Personal Data

We may use Personal Data for the following purposes:

• To provide and maintain our Service.
• To manage Your Account: to manage your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about services we offer, unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to us.
• Testimonials and customer feedback collection: If you share a testimonial or review about your experience using our Service, it can be shared or otherwise used on the website.
• Brokerage sync (only if you connect): to display your connected portfolio in the Service (including Manage); to drive your Income Calendar using dividend and related activity data from the connection; to power tools you choose to use, such as Rebalance and Targets, which may calculate a suggestion from a holding you already have, its current price or yield, and a target you entered; and to operate, secure, troubleshoot, reconnect, and bill the brokerage-sync feature (including logs and connection health).

When you connect a brokerage, we use connected brokerage data only for the purposes above for your account. A calculated suggestion in Rebalance or Targets is a tool result from your own holdings and the targets you set. It is not investment advice, not a suitability determination, and not a recommendation that you buy or sell any security. We do not automatically push buy, sell, or hold signals from your connected accounts.

We do not use connected brokerage portfolios to:

• advertise to you based on your holdings;
• share your holdings with other users; or
• train artificial intelligence or machine-learning models on your connected portfolio.

We may share your personal information in the following situations:

• With Service Providers: We may share personal information with service providers who help us operate the Service — for example payment processors, hosting and infrastructure providers, analytics and error monitoring, customer support tools, email delivery, and Passiv Inc. (SnapTrade) when you choose to connect a brokerage. Those providers process information on our instructions or as described in their own policies where they act as independent controllers for their services.
• For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Where your personal data is stored and processed

We and our service providers may process and store personal data in the United States, Canada, and other countries.

If you connect a brokerage through SnapTrade, SnapTrade has indicated that its primary production cloud region is in Canada, but SnapTrade's Privacy Policy allows processing in other countries, including the United States. We do not promise that SnapTrade processing is limited to Canada.

When information is processed outside your province, state, or country, it may be subject to the laws of those other places, including lawful access by courts, regulators, or law enforcement.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Brokerage data — retention, disconnect, and deletion

While connected. We keep a local copy of brokerage data we import and refresh it according to your plan and our sync schedule (our default sync cadence is not real-time).

Disconnect (turn sync off). If you disconnect a brokerage connection in the Service, we instruct SnapTrade to delete that connection on SnapTrade's side. Disconnecting does not automatically erase the portfolio data already imported into your Manage portfolios. Those holdings may remain in your account as an ordinary portfolio until you edit or delete them, or until you request erasure of your account / personal data as described below.

Premium or access lapse. If brokerage sync requires a paid subscription (or similar access) and that access ends, we may delete the SnapTrade connection after a short grace period (currently three (3) calendar days after the relevant end date, unless we state otherwise in-product). Deleting the connection stops further sync; imported portfolio data may still remain in Manage unless you delete it or request erasure.

Account deletion / privacy erasure request. If you delete your Dependable Income Investing account, or you ask us to erase personal data in a way that covers brokerage data, we will delete SnapTrade users/connections associated with your account (as applicable) and delete SnapTrade-sourced brokerage data we hold, except where we must retain information for legal, security, dispute, or accounting reasons. (Any SnapTrade internal exception for holdings/positions/transactions on deletions requested by SnapTrade does not apply to your End User deletion / erasure request to us.)

Your choices. You can view connections, reconnect, disconnect, and request access, correction, or erasure by contacting us (see Contact Us). Canadian users may also have rights under applicable Canadian privacy law (including PIPEDA).

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.

YOUR RIGHTS

You have the following rights in relation to your personal data under the GDPR:

• to obtain information on how we handle your personal data and access documents which contain your personal data;
• to request us to correct or update your personal data if it is inaccurate or out of date;
• to object to the processing of your personal data for the purposes of our legitimate interests, as discussed above;
• to erase personal data about you that is held by us: which is no longer necessary in relation to the purposes for which iswas collected, to the processing of which you object, or which may have been unlawfully processed by us;
• to restrict processing by us, i.e. to restrict processing to storage only: here you oppose to deletion of your personal data and prefer restriction of processing instead, or where you object to the processing by us on the basis of its legitimate interests;
• to transmit personal data that you submitted to us back to you or to another organisation in certain circumstances; and if we rely on your consent (for example, when setting cookies on your device or for direct marketing), you may withdraw your consent at any time.

If you at any time decide to exercise any of these rights, please contact us.

Children and sensitive personal data

Our Service is not directed towards children who are under the age of 18. We do not knowingly contact or collect personal information from children below the age of 18 years, or sensitive personal data ("racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural person's sex life or sexual orientation, etc"). Please consult Art. 9 GDPR for more information. If you believe we have inadvertently collected such information, please contact us immediately so that we can either obtain special consent or delete the information.

Brokerage connection features are available only to users who are 18 years of age or older. By connecting a brokerage, you represent that you are at least 18.

Cookie and local storage usage policy

In the interest of transparency, this policy contains detailed information on Dependable Income Investing LLC's use of cookies and other similar technologies, and explains how the User can control the use of cookies and other similar technologies. By accessing Service, the User accepts the terms and conditions of this policy, applicable during each connection and from any terminal.

Contact Us

Questions about this Privacy Policy or personal data requests:

• Website: https://dependableincomeinvesting.com
• Email: support@dependableincomeinvesting.com