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Wealth Recon
LEGAL

Privacy Policy

Effective date: June 4, 2026. Last updated: June 4, 2026. Version: 2.0.

1. Scope

This Privacy Policy describes how Wealth Recon collects, uses, shares, and protects personal information. It applies to two distinct populations:

  • Advisor users: licensed financial advisors who hold a Wealth Recon account and use the application to generate prospect-research dossiers.
  • Dossier subjects: the individual humans whose names, household compositions, professional histories, and wealth signals are surfaced in Wealth Recon dossiers. Subjects do not hold a Wealth Recon account; they may interact with Wealth Recon only through the privacy-request channels described below.

Wealth Recon honors the strictest United States state privacy obligations regardless of subject or advisor user location, anchored by California's Consumer Privacy Act, Colorado's Privacy Act, Virginia's Consumer Data Protection Act, and Connecticut's Data Privacy Act. The privacy-law watchlist at docs/operations/privacy-law-watchlist.md (internal) is reviewed quarterly to keep this floor current as the United States state-privacy landscape moves.

2. Information we collect about advisor users

When you sign up for a Wealth Recon account, we collect: full name, firm, account email address, work email address, optional Central Registration Depository number, optional LinkedIn Uniform Resource Locator. We collect verification results from FINRA BrokerCheck and the Securities and Exchange Commission Investment Adviser Public Disclosure database, plus a work-email-domain match outcome.

When you use Wealth Recon, we collect: your dossier requests, your inline edits to dossier content, your advisor-profile fields that drive Connection Pathways (alma maters, military service, professional memberships, geographic markets), your billing information through Stripe, your access patterns (login timestamps, page visits within the gated app), and any messages you send to support, privacy, or admin email addresses.

We do not collect or store your password directly; Supabase Auth handles authentication and stores hashed credentials.

3. Information we collect about dossier subjects

The dossier subject's name, location, employer, professional history, public wealth signals, household composition, philanthropic activity, board service, public political contributions, public real estate holdings, public-company equity, and other categories documented in master spec Section 8 are collected exclusively from publicly available sources. Sources include Securities and Exchange Commission filings, court records, real estate records, regulatory disclosures, news, professional history sources, and similar public-web surfaces. The information we collect about dossier subjects is publicly available information, meaning information that is lawfully made available from government records or that the subject or another party has made widely available to the general public. Most United States state privacy laws exclude publicly available information from the definition of personal information they regulate. We extend subject rights below to this information regardless of that exclusion, as a matter of policy rather than legal obligation.

Every claim that appears in a Wealth Recon dossier is paired with a verifiable source Uniform Resource Locator. The product does not publish a factual statement about a subject without a source URL that an advisor can open and read. This rule applies to every dossier the engine produces and is enforced in the dossier pipeline itself, not as a manual review step.

We do not buy data from breach markets. We do not pay third parties operating outside the law. We do not access medical or health records (with the narrow exception of voluntary public disclosure by the subject themselves), beneficial-ownership reports filed with the Financial Crimes Enforcement Network, social media of minor children, or any source restricted by federal statute.

When an advisor in your firm-tenant corrects a fact in a dossier, the corrected fact is stored against the subject's canonical Master Person Index record with provenance: the advisor identifier, the timestamp, and the corrected-flag indicator. The corrected fact may inform future dossiers on the same subject across other firm-tenants in aggregated, de-identified form. Reused material is limited to the corrected factual value and its public source; it never includes the identity of the advisor or firm that made the correction, that advisor's notes, or any advisor-specific content. This reuse keeps public-record accuracy current across the product and is also described in our Terms of Service. A subject who exercises the deletion or do-not-process right in Section 6 stops all future reuse keyed to that subject.

3a. Categories of personal information

For the populations described above, we handle the following statutory categories of personal information, using the category names common to United States state privacy laws: identifiers, such as name, email address, and online identifiers; professional or employment information; financial-account or wealth-signal information drawn from public sources; commercial information, such as subscription and billing records for advisor users; internet or network activity, such as login timestamps and in-app page visits for advisor users; geolocation derived only from the public record or general region, not precise device location; and inferences drawn from the above to build a research artifact. We do not knowingly handle the special or sensitive categories that state laws single out for heightened protection, such as government identification numbers beyond a publicly filed Central Registration Depository number, precise geolocation, biometric identifiers, health information, or information about racial or ethnic origin, except where a subject has voluntarily made such information public.

4. How we use the information

For advisor users, we use your information to authenticate your account, deliver the dossier generation pipeline, surface your Connection Pathways across the prospects in your tenant, render the in-app reader and the downloadable Portable Document Format and Comma-Separated Values exports, bill your subscription through Stripe, deliver transactional emails, deliver the onboarding drip-email sequence and product-update emails (you may opt out of marketing emails through your account preferences), and run aggregated product-analytics through Plausible Analytics on the marketing site (the gated app uses Sentry for error tracking only; Plausible Analytics excludes the gated app and the privacy-request page).

For dossier subjects, we use your information to surface a research artifact that licensed advisors use in prospect-evaluation workflows. We do not sell your data, do not use it for marketing, and do not use it to contact you outside the privacy-request channel you have initiated.

Wealth Recon does not assemble, provide, or authorize the use of any dossier or other Service output for any purpose covered by the Fair Credit Reporting Act, fifteen United States Code section sixteen eighty-one and following. Dossiers are not consumer reports. Advisor users may use dossiers only for legitimate, internal financial-advisory purposes, which are the lawful business uses associated with evaluating, contacting, or serving prospective and existing clients. Use of any dossier output to make a credit, insurance, employment, housing, tenancy, or government-benefit eligibility decision is prohibited. The Fair Credit Reporting Act prohibition is also set out in our Terms of Service and our Advisor Use Agreement.

4a. Dossier cache and refresh tiers

Each dossier request consumes a credit from the requesting advisor's account. To keep research current without re-running the agent pipeline for stale repeat requests, Wealth Recon applies a tiered cache rule to every dossier:

  • If a dossier on the same subject was generated within the past twenty-four hours, the cached dossier is returned silently to the requesting advisor and no agents run.
  • If a dossier on the same subject was generated within the past twenty-four hours to thirty days, the cached dossier is returned and a refresh agent runs in the background to update any stale fields.
  • If a dossier on the same subject is more than thirty days old or has never been generated, a full agent pipeline runs and the dossier is rebuilt from sources.

The requesting advisor sees only the date of their own dossier request. The user interface does not surface a cache-state indicator or indicate that any other advisor has previously researched the subject. The cache tiers apply across firm-tenants. See Section 5 above for the cross-advisor invisibility rule that governs how cached components are surfaced.

4b. Relationship to the Gramm-Leach-Bliley Act

Wealth Recon is not a financial institution, and a dossier is not a financial product or service offered to a consumer. The nonpublic personal information that the Gramm-Leach-Bliley Act protects is information a consumer gives a financial institution to obtain a financial product or service. Wealth Recon does not collect that information from dossier subjects; it assembles dossiers from public sources. To the extent an advisor user is itself a financial institution subject to the Gramm-Leach-Bliley Act, that advisor remains responsible for its own compliance, and the Advisor Use Agreement prohibits any use of the Service that would violate that Act. This section describes the boundary of the Act as it applies to Wealth Recon and is not a representation that Wealth Recon is a covered financial institution.

5. How we share the information

Within Wealth Recon, advisor users at the same firm-tenant share access to dossiers generated within that tenant per the master spec's tenant-wide visibility rule. Advisors at different firms do not see each other's dossiers, requests, or edit history, except through the anonymized Master Person Index aggregation described in Section 3 above.

No advisor is ever notified that another advisor pulled a dossier on the same prospect. The product does not surface a "this prospect was researched by another user" signal under any circumstance, including within the same firm-tenant. The cross-advisor invisibility rule is absolute and is enforced in the dossier pipeline itself. The reuse of corrected facts and cached dossier components across firm-tenants is described in Section 3 above and is also addressed in our Terms of Service.

Wealth Recon shares advisor-user information with third-party service providers to operate the application:

  • Stripe for payment processing.
  • Supabase for database, authentication, and object storage.
  • Vercel for hosting and content delivery.
  • Inngest for background job orchestration.
  • Anthropic, Google, Perplexity, xAI for the large-language-model agent pipeline. Pipeline calls are made through application-programming-interface keys held in our environment-variable store, and we use these providers on their enterprise or business terms, which prohibit using the call payloads to train their foundation models. Each provider's published privacy and data-retention policy governs how long it holds the call payloads for its own abuse-monitoring and operational purposes; that period is set by the provider and not by Wealth Recon.
  • Sentry for error monitoring in the gated app. Error reports may incidentally include limited request context. We configure Sentry to limit the data captured in error events and do not intend for dossier content to be sent to Sentry; we do not use Sentry to store dossiers or inline edits.
  • Cloudflare for content-delivery, CAPTCHA, and email-routing services.
  • Plausible Analytics for marketing-site analytics (cookie-free, no personal information).
  • FINRA BrokerCheck and the Securities and Exchange Commission Investment Adviser Public Disclosure database for signup verification (one-way query; we do not transmit any information to these databases beyond the Central Registration Depository number you submit).

This list names our principal current subprocessors. We maintain a current subprocessor list and will provide it on request through the privacy channel below. We may add or change subprocessors as the Service evolves.

Wealth Recon shares dossier-subject information only with advisor users at the requesting firm-tenant and within the anonymized Master Person Index aggregation. Wealth Recon does not sell dossier-subject data to any third party.

5a. Sale and sharing of personal information

Wealth Recon does not sell personal information, and does not share personal information for cross-context behavioral advertising, as the terms sell and share are defined under California law. This is true for both advisor users and dossier subjects. Because we do not sell or share in this sense, we do not offer a separate "Do Not Sell or Share My Personal Information" control; the subject rights in Section 6 and the advisor rights in Section 7 reach all of your information. The reuse of corrected facts across firm-tenants described in Section 5 is a product-operation use, not a sale, and no money or other valuable consideration changes hands for it.

6. Subject rights

If you are the subject of a Wealth Recon dossier, you have the following rights regardless of where you reside in the United States:

Because dossiers are built from public sources, we do not notify a subject when a dossier is generated. You may use the access right below at any time to learn whether we hold any record about you and to obtain a copy of it. You may use an authorized agent to submit a request on your behalf. We may require the agent to provide proof of your written authorization, and we may still ask you to verify your own identity directly before we act.

We confirm receipt of every request within 10 business days and respond substantively within 45 calendar days of a verified request. Where a request is complex or numerous, we may extend once by an additional 45 days and will tell you why within the first 45-day period. The day counts shown below are our internal operational goals, which are faster than the legal deadline; the 45-day statutory period governs if our goal is not met.

  • Access: request a human-readable export of every record Wealth Recon holds on you, plus the access log of every advisor query that touched your record. Operational target: 21 calendar days from a verified intake.
  • Deletion: request that Wealth Recon delete every record keyed to your identity and apply a permanent do-not-process flag designed to prevent future dossier generation on you. Operational target: 14 calendar days.
  • Correction: request that Wealth Recon correct a wrong fact in our records. Operational target: 21 calendar days.
  • Do-not-process: request that Wealth Recon never generate a future dossier on you. Operational target: 7 calendar days.

The primary channel for any of these requests is the form at https://wealthrecon.com/privacy. Identity verification runs in two stages: a confirmation email loop for all requests, plus, on access, deletion, correction, and do-not-process requests, a documentary-identification check whenever the public record does not unambiguously identify you. We apply the documentary check to access requests because a dossier may contain sensitive financial detail, and we will not release it to an unverified requester. Identity documents are reviewed, used to confirm identity, and then deleted from Wealth Recon's systems within seven calendar days. Identity documents are never used to enrich the contact intelligence layer.

The secondary channel is privacy@wealthrecon.com. The tertiary channel is the physical mailing address listed below.

If we decline your request, we will tell you why and how to appeal. To appeal, reply to our decision through the same channel within a reasonable time. We will review the appeal and respond within 45 days, explaining our reasoning. If we deny the appeal, we will give you a way to contact your state attorney general to submit a complaint, where your state law provides that route.

We do not charge a fee for processing any of these requests. We do not retaliate against any subject for exercising these rights. Subjects whose deletion or do-not-process requests are honored may rescind those requests at any time through the same form.

7. Advisor-user rights

Advisor users have all subject rights above (treating themselves as subjects), plus the following account-level rights:

  • Update your account information through the Account page in the gated app.
  • Export your tenant's data (your account record, your dossier list, your inline edits, your advisor profile) through the Account page; an automated export delivers within one business day.
  • Cancel your subscription through the Stripe Customer Portal at any time.
  • Opt out of non-transactional emails (the onboarding drip sequence, the product-update sequence) through the unsubscribe link in any such email or through the Account page.

8. Data retention

We retain advisor-user account information for the duration of your active subscription plus a 12-month archive window after cancellation, after which the records are deleted. Dossier artifacts (the styled Portable Document Format, the dossier JavaScript Object Notation, the Comma-Separated Values export) are retained indefinitely while you remain an active customer; they archive for 12 months after cancellation, then delete. Notwithstanding the 12-month window, we retain billing, payment, and tax records for the period required by applicable tax and financial-recordkeeping law, after which they are deleted. These records are held by our payment processor, Stripe, and by us only as needed to meet those obligations.

Subject identity records and household records are retained for as long as the subject remains a candidate for advisor research, measured as 24 months from the most recent dossier that referenced the subject. If no dossier references the subject for 24 consecutive months, the records auto-purge. We do not retain subject records indefinitely. Master Person Index entries follow the same 24-month-from-last-reference rule and are not exempt from it. A subject who exercises the deletion right in Section 6 is removed ahead of this schedule, subject only to the minimized suppression record described below.

After we honor a subject deletion, we keep a minimized suppression record consisting of a one-way reference derived from the subject's identifying details, the date of deletion, and the do-not-process flag. We keep this record for the sole purpose of recognizing the same subject in the future and preventing the regeneration of a dossier. This record cannot be used to reconstruct the deleted dossier or its sources. We retain audit-log entries for the period required to meet our legal and regulatory-defense obligations, and no longer.

9. Security

Wealth Recon encrypts data at rest using AES-256 with keys held in Supabase's key management service, with key rotation on a 90-day schedule. Connections between the application and storage use Transport Layer Security version 1.3. Connections to third-party source providers use Transport Layer Security version 1.3 or the strongest version the provider supports.

Access controls are scoped tightly. Bryce Randall, as solo founder and operator, has full administrative access to the operational store. No other human has standing access at V2 launch. Future engineers and operators will receive role-scoped access under least-privilege controls.

The Wealth Recon team aims to assess any suspected data incident within 72 hours of discovery. Notification to affected advisor users and dossier subjects, where required by law, will follow the relevant state-specific notification rules and timelines.

10. Children's privacy

Wealth Recon is not directed at and does not knowingly collect personal information from individuals under 18. The signup gate restricts access to licensed financial advisors. Dossier subjects who are minors are excluded from the engine; the methodology rules suppress dossier generation on subjects under 18.

11. International users

Wealth Recon is operated from the United States and is intended for use by United States-based licensed financial advisors. We do not market Wealth Recon outside the United States. If you access Wealth Recon from outside the United States, your information will be transferred to and processed in the United States, where data-protection laws may differ from those in your home jurisdiction.

12. Changes to this Privacy Policy

Wealth Recon may amend this Privacy Policy from time to time. Material amendments will be notified through the email address on your account, and a banner will surface on the in-app reader for thirty days following the change. Non-material amendments will be reflected in the version date at the top of this document.

13. Contact

For privacy questions or requests, contact privacy@wealthrecon.com or use the form at https://wealthrecon.com/privacy.

For other support questions, contact support@wealthrecon.com.

Physical mailing address: Wealth Recon LLC, c/o Polsky Exchange North, 1452 E. 53rd St., 2nd Floor, Chicago, IL 60615.