Privacy Policy

FastTrackr Inc. ("FastTrackr AI", "we", "us", or "our") is committed to protecting the privacy of individuals whose information is collected and processed through the FastTrackr Advisor Transition Platform (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect information in connection with the Platform.

This Privacy Policy applies specifically to the FastTrackr Transition Platform. For our general website and other services, please refer to the applicable privacy policy at fasttrackr.ai.

By using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy.

1. DEFINITIONS

"User" means any individual who accesses or uses the Platform, including financial advisors, transition consultants, firm administrators, and support staff.

"Advisor" means any licensed or registered financial professional — including financial advisors, registered representatives, investment adviser representatives, wealth managers, financial planners, and portfolio managers — who is transitioning between financial services firms, or whose book of business is being acquired by, transferred to, or consolidated with another firm. This includes individuals affiliated with or departing from any type of financial services entity, including wirehouses, broker-dealers, RIAs, hybrid RIAs, bank trust departments, insurance-affiliated advisory platforms, and independent contractors operating through an OSJ. An Advisor may be a sole practitioner or part of a transitioning team.

"Client" means any end-client or retail customer of an Advisor whose personal information is entered into or processed through the Platform by a User.

"Client Data" means all data and personal information relating to Clients uploaded, entered, or otherwise provided through the Platform, including names, addresses, contact details, account information, financial information, and Sensitive Client Data.

"Sensitive Client Data" means Client Data that is highly confidential or regulated, including Social Security Numbers (SSNs), government identification numbers, account numbers, financial account details, tax information, and nonpublic personal information ("NPI").

"User Account Data" means personal information of Users collected during registration and use of the Platform, such as name, email address, firm affiliation, and usage data.

"Project Data" means all information associated with a transition Project, including Household records, document uploads, advisor configurations, and progress tracking data.

2. SCOPE OF THIS POLICY AND OUR ROLE

2.1 Dual Role

FastTrackr AI operates in two distinct capacities under this Privacy Policy:

• As a data controller with respect to User Account Data and Platform usage information that we collect directly from Users for our own purposes (e.g., account management, billing, platform improvement); and

• As a data processor acting on behalf of Users with respect to all Client Data that Users upload, enter, or process through the Platform. In this capacity, we process Client Data solely at the direction of Users, who are the data controllers with respect to their Clients.

IMPORTANT: FastTrackr AI does not control the collection or use of Client Data. Users — not FastTrackr AI — are solely responsible for ensuring they have the legal right to collect, upload, and process Client Data, and for obtaining all necessary Client consents required by law. All regulatory and compliance obligations in connection with Client Data rest entirely with the User.

2.2 US Platform Only

The Platform is designed exclusively to support advisor transition activity within the United States financial services regulatory framework. Users may upload information relating to clients who are foreign nationals or who have addresses outside the United States in connection with otherwise US-based transition projects.

3. INFORMATION WE COLLECT

3.1 User Account and Registration Data

When you register for or use the Platform, we collect:

• Full name and professional title

• Email address and phone number

• Firm name, role, and business address

• Registration credentials (managed through authentication systems)

• Subscription and billing information (for paid accounts)

• Advisor identifiers such as G Numbers, RR Codes, or any identification numbers as required for transition workflows

• Any other information as maybe reasonably required

3.2 Client Data Uploaded by Users

Users may upload or enter Client Data into the Platform in connection with transition Projects. This Client Data is uploaded by Users and may include:

• Client names, addresses, phone numbers, and email addresses

• Household composition and member information

• Account types and custodian details

• Account numbers

• Social Security Numbers (SSNs) and tax identification numbers

• Financial holdings, balances, and account statements

• Beneficiary and estate planning information

• Identification documents

• Any other personal or financial information included in documents or data uploads or via manual entry

NOTICE REGARDING SENSITIVE CLIENT DATA: The Platform may be used by Users to store Social Security Numbers and other highly sensitive financial information. FastTrackr AI processes this information solely as a service provider at the direction of the User. Users are solely responsible for ensuring they are legally and contractually authorized to collect and upload this data, and for obtaining all required Client consents. FastTrackr AI assumes no responsibility for the lawfulness of any Client Data uploaded by Users.

3.3 Client-Submitted Data

In certain workflows, Clients may be invited to directly access the Platform via OTP-verified login to review, verify, or add their own information. FastTrackr AI processes this data as a service provider on behalf of the User.

3.4 Document Uploads

Users and Clients may upload documents through the Platform, including account statements, tax forms, identification documents, and other financial or non-financial records. FastTrackr AI uses AI and OCR technology to extract and structure relevant data for use in the transition Project. Documents may contain Sensitive Client Data.

3.5 Audio and Transcript Data

Where enabled, Users may upload audio recordings or transcripts of client calls for the purpose of enriching Household records. These recordings are processed to extract relevant information and are retained for the period described in Section 7 below.

3.6 Usage and Technical Data

We may collect technical data about how Users interact with the Platform, including:

• IP addresses and device identifiers

• Browser type and version

• Pages and features accessed and time spent

• Login timestamps and session data

• Error logs and diagnostic data

4. HOW WE USE INFORMATION

4.1 User Account Data

We use User Account Data to:

• Create and manage User accounts and Projects

• Authenticate User access to the Platform

• Provide technical support and respond to inquiries

• Send operational communications including onboarding, account updates, and security alerts

• Process payments and manage subscriptions

• Improve the Platform and develop new features

• Comply with legal obligations

4.2 Client Data

We use Client Data solely to:

• Provide the Platform services to the User, including storing, organizing, and structuring Household records for the transition Project;

• Generate transition-related documents, forms, and outputs as directed by the User;

• Enable enrichment workflows, including AI-assisted data extraction from documents and audio;

• Facilitate Client-facing workflows where a Client is invited to verify or add their own information;

• Comply with legal obligations, including applicable breach notification requirements.

FastTrackr AI does not use Client Data to train its own AI models. All third-party AI services used by FastTrackr AI to process Client Data are engaged under terms that exclude data submitted via API from use in training their models. FastTrackr AI does not use Client Data to market to Clients, develop products for third parties, or for any purpose other than providing the Platform services to the User who uploaded the data.

4.3 No Sale of Personal Data

FastTrackr AI does not sell, rent, or trade any User Account Data or Client Data to any third party for any commercial purpose.

5. HOW WE SHARE INFORMATION

5.1 Service Providers

We work with third-party service providers who assist us in providing the Platform, including cloud hosting providers, AI and OCR processing services, and security providers. Where contractual arrangements are in place, we require these service providers to handle data confidentially and to use it only for the purpose of providing services to us. We do not control the internal practices of third-party providers beyond the scope of our arrangements with them. FastTrackr AI may update or change its third-party service providers at any time at its discretion.

5.2 AI and Automated Processing

The Platform uses artificial intelligence and OCR technology to extract and analyze data from uploaded documents and audio files. Client Data may be transmitted to third-party AI service providers as part of this process. FastTrackr AI selects AI providers that operate under terms excluding API-submitted data from model training, and prohibits these providers from using Client Data for any independent purpose. However, FastTrackr AI cannot guarantee the internal practices of third-party AI providers beyond the scope of our agreements with them.

5.3 Custodians and Destination Firms

Client Data is not shared with custodians or destination firms by FastTrackr AI directly. Such sharing is conducted by Users using data organized and prepared through the Platform. FastTrackr AI is not a party to any data sharing between Users and custodians or firms.

5.4 Legal Requirements

We may disclose information if required to do so by law, regulation, court order, or in response to a valid request from a regulatory or law enforcement authority. We will attempt to notify affected Users of any such disclosure where legally permissible.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of FastTrackr AI's assets, Client Data and User Account Data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

5.6 No Disclosure to Prior Firms

FastTrackr AI does not disclose any Client Data, User Account Data, or Project Data to any Prior Firm or to any party adverse to a User in any employment or transition-related dispute.

6. BROKER PROTOCOL, SOLICITATION LAWS, AND DATA RESPONSIBILITY

CRITICAL NOTICE TO ALL USERS: FastTrackr AI is a neutral technology platform. We do not verify, monitor, or enforce compliance with the Broker Protocol for Broker Recruiting, any non-solicitation agreement, or any solicitation law. The legal permissibility of collecting and using specific types of Client Data during an advisor transition is YOUR sole responsibility.

Users acknowledge and agree that:

• Under the Broker Protocol (where applicable), only limited Client information may be taken by a departing Advisor. Certain data is expressly prohibited from being taken under the Broker Protocol;

• For Non-Protocol Advisors, the permissibility of collecting or retaining any Client Data is governed by applicable employment agreements, non-solicitation covenants, state law, and applicable regulations, and may be significantly more restricted;

• FastTrackr AI takes no responsibility for any regulatory action, lawsuit, arbitration, or other proceeding arising from a User's collection, storage, or use of Client Data in connection with any advisor transition;

• All regulatory compliance obligations arising from use of the Platform rest solely with the User.

7. DATA RETENTION

7.1 Client Data

Client Data is retained for the duration of the active Project to which it relates. Following Project closure or receipt of a deletion request:

• Active Client Data is deleted from production systems within thirty (30) days of Project closure;

• Backup copies are purged within sixty (60) days following deletion from active systems;

• Users are solely responsible for maintaining their own records of Client Data in compliance with applicable regulatory retention requirements. FastTrackr AI is not responsible for any consequences arising from a User's failure to maintain required records.

7.2 Document Uploads

Uploaded documents are retained for the duration of the active Project and deleted within thirty (30) days of Project closure or upon receipt of a deletion request, subject to the backup schedule above.

7.3 Audio Recordings and Transcripts

Audio recordings uploaded through the Platform are retained for the duration of the active projects and for up to thirty (30) days after project closure or upon receipt of a deletion request, after which they are permanently deleted. Structured data and notes extracted from audio recordings may be retained as part of the Household record for the duration of the Project.

7.4 User Account Data

User Account Data is retained for the duration of the User's account and for up to thirty (30) days following account termination, after which it is deleted, unless longer retention is required by law.

7.5 Deletion Requests

Users may request deletion of Client Data or their account by contacting contact@fasttrackr.ai. FastTrackr AI will process deletion requests within thirty (30) days. Users acknowledge that FastTrackr AI is not responsible for any consequences arising from their failure to maintain required records prior to deletion.

7.6 Confidentiality After Deletion

Deletion of Client Data under this Section does not affect FastTrackr AI's confidentiality obligations under the Terms of Service. FastTrackr AI's obligation to not disclose or misuse Confidential Information it held during the term continues for five (5) years following termination, regardless of when the underlying data was deleted.

8. DATA SECURITY

FastTrackr AI implements commercially reasonable technical and organizational security measures to protect Client Data and User Account Data, including:

• Encryption of data in transit and at rest 

• Access controls and role-based permissions limiting who can access Client Data

• Regular security assessments and monitoring

Given the sensitivity of Sensitive Client Data processed through the Platform — including SSNs, account numbers, and financial information — we apply security controls appropriate to the nature of such data.

No data transmission or storage system can be guaranteed to be completely secure. In the event FastTrackr AI becomes aware of a security incident affecting Client Data, FastTrackr AI will notify affected Users as soon as reasonably practicable and in any event within the timeframe required by applicable law for material breaches, and within a reasonable time for non-material incidents. Notification will be sent to the primary email address associated with the User's account. FastTrackr AI's notification obligation runs solely to Users — not to end Clients. Notifying end Clients of any breach affecting their data is solely the responsibility of the User.

9. COOKIES AND TECHNICAL TRACKING

The Platform uses cookies and similar technologies for authentication, session management, and analytics. We do not use third-party advertising cookies or cross-site tracking. You can control cookie settings through your browser, though disabling cookies may affect Platform functionality.

10. YOUR RIGHTS AND CHOICES

10.1 User Account Data Rights

With respect to your own User Account Data, you have the right to:

• Access — Request a copy of your personal information we hold

• Rectification — Request correction of inaccurate or incomplete information

• Erasure — Request deletion of your account and personal data, subject to legal retention requirements

• Portability — Request a machine-readable copy of your personal data

To exercise these rights, contact us at contact@fasttrackr.ai. FastTrackr AI will make reasonable efforts to respond within thirty (30) days, subject to technical feasibility and applicable legal requirements.

10.2 Client Rights — Advisor Responsibility

FastTrackr AI does not have a direct relationship with Clients whose information is processed through the Platform. If a Client wishes to exercise rights regarding their personal information, they should contact the Advisor or firm on whose behalf their data was uploaded. FastTrackr AI will cooperate with Users to facilitate Client data access, correction, or deletion requests as technically feasible.

10.3 California Privacy Rights

California residents may have rights under the California Consumer Privacy Act (CCPA). As an early-stage company, we do not currently meet the CCPA applicability thresholds. However, we respect California residents' privacy concerns and implement reasonable data protection practices. Contact us at contact@fasttrackr.ai with any questions.

11. CHILDREN'S PRIVACY

The Platform is intended for use by adults only. Individuals under 18 years of age may not register for or use the Platform as Users.

However, Users may upload or process personal information relating to minors in connection with custodial accounts (UTMA/UGMA), 529 education savings accounts, beneficiary designations, trust accounts, and other financial records as part of a transition Project. Such information is processed by FastTrackr AI solely as a service provider acting on the User's instructions. Users are solely responsible for ensuring that any processing of information relating to minors complies with all applicable laws, including any requirement to obtain consents or authorisations from the minors' parents or legal guardians.

FastTrackr AI does not knowingly operate any feature directed at children as users of the Platform and does not knowingly collect personal information from children as Platform users.

12. DATA TRANSFERS

Data may be processed in the United States and, in limited cases involving third-party processing services or other operational needs, in other countries. Where data is transferred internationally, FastTrackr AI takes reasonable steps to require appropriate data protections through its arrangements with service providers. FastTrackr AI cannot guarantee the practices of foreign service providers beyond the scope of those arrangements.

13. RELATIONSHIP WITH TERMS OF SERVICE

This Privacy Policy is incorporated into and forms part of the FastTrackr Transition Platform Terms of Service. In the event of any conflict between this Privacy Policy and the Terms of Service, the Terms of Service shall control. Additional data handling provisions, including indemnification and limitation of liability, are set forth in the Terms of Service.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify Users of material changes by posting an updated version on the Platform with a revised 'Last Updated' date. Your continued use of the Platform after any such update constitutes your acceptance of the revised Policy.

CONTACT US

For questions, concerns, or to exercise your privacy rights, contact us at:

FastTrackr Inc. Email: contact@fasttrackr.ai