Mezzi Privacy Policy

StockTalk, Inc., doing business as Mezzi (“Mezzi,” “we,” “us,” or “our”), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and retain information when you access or use Mezzi’s websites, mobile applications, and related services (collectively, the “Services”).

This Privacy Policy should be read together with Mezzi’s Terms of Use and Advisory Disclosures. Capitalized terms not defined here have the meanings given in those documents.

1. Scope and Advisory Relationship

Mezzi is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). Certain features of the Services constitute investment advisory services provided by Mezzi in its capacity as an SEC-registered investment adviser.

When you access advisory features of the Services (including during any free trial that includes advisory functionality), Mezzi collects, uses, and retains information as necessary to:

• Provide investment advisory services,
• Fulfill fiduciary obligations,
• Comply with applicable laws and regulations, including SEC recordkeeping requirements.

2. Information We Collect

A. Information You Provide Directly

We may collect information you provide, including:

• Identification information (such as name and email address)
• Account and profile information
• Financial goals and preferences
• Information you manually enter regarding assets, liabilities, or other financial matters
• Documents you upload (such as brokerage statements), and data extracted from those documents
• Communications with Mezzi, including customer support inquiries and chat interactions

B. Financial Account Information

With your authorization, we collect read-only financial account data through third-party financial data aggregators (such as Plaid, Yodlee, Snaptrade, or similar providers). Mezzi does not receive or store your brokerage login credentials. Credentials are handled directly by the third-party provider.

C. Chat and Interaction Data

We collect and store:

• Advisory chat transcripts
• Informational chat transcripts
• Related interaction metadata

These records may be subject to regulatory retention obligations.

D. Automatically Collected Information

We collect technical and usage information, including:

• IP address
• Device identifiers
• Browser and operating system information
• Log data, timestamps, and usage patterns
• Analytics data used to improve performance, reliability, and security

E. Inferred and Modeled Information

We may generate inferred, estimated, benchmarked, or modeled information based on the data you provide or authorize us to access, where complete information is unavailable.

3. Use of Artificial Intelligence and Automated Processing

Mezzi uses automated systems and artificial intelligence as part of the Services.

A. Advisory and Informational Systems

• Some advisory features operate on the data you provide using deterministic procedures developed by financial professionals. This data is processed within Mezzi services running within the infrastructure of our cloud services provider (Google).
• Informational features may use third-party “frontier” AI models that generate probabilistic outputs. In order to calculate the most accurate and relevant answers available for your circumstances, these models may be sent some of the data you provide us, including information relating to your portfolio and the questions you submit. Such data is disclosed to these providers for that purpose only.

B. AI Improvement

Mezzi may use user data, including interactions with the Services, to:

• Improve internal prompts, procedures, and system performance
• Enhance the quality, consistency, and reliability of Mezzi’s advisory and informational features

C. No Third-Party AI Training

Mezzi does not permit third-party AI model providers to use Mezzi user data to train or improve their own models.

4. How We Use Information

We use information to:

• Provide and operate the Services
• Deliver investment advisory services
• Generate analytics, insights, and user-requested outputs
• Maintain and improve system performance and security
• Communicate with you regarding your account, the Services, and required notices
• Comply with legal, regulatory, and contractual obligations

Mezzi does not sell personal information and does not use personal information for advertising purposes. Mezzi does not sell or share your information with any third parties for marketing or promotional purposes.

5. Sharing of Information

We may share information:

• With service providers that perform services on our behalf (such as hosting, analytics, AI models, customer support, payment processing, and financial data aggregation)
• With collaborators you explicitly authorize (such as a spouse or financial professional)
• As required by law, regulation, legal process, or regulatory examination
• In connection with a merger, acquisition, or similar transaction

Collaborators you authorize may have access to all connected accounts and may be able to view, copy, or download information through the Services.

6. Communications

We may communicate with you via:

• Email
• In-app notifications
• Push notifications
• SMS/text messages (transactional only, such as security alerts or account notices)

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

7. Data Retention and Deletion

You may review, edit, or request deletion of your information through the Services.

However, Mezzi retains certain information as required to:

• Provide the Services
• Meet legal and regulatory obligations, including SEC recordkeeping requirements applicable to registered investment advisers

Some information, including advisory records and chat transcripts, cannot be deleted immediately upon request. Mezzi will delete such information once applicable retention obligations expire.

8. Cookies and Analytics

We use cookies and similar technologies to:

• Operate and secure the Services
• Understand usage and improve functionality
• Diagnose bugs and system issues

We do not use cookies for advertising.

9. Security

We employ administrative, technical, and organizational safeguards designed to protect your information. No system can be guaranteed to be 100% secure.

10. International Users

The Services are intended for U.S. users. Information may be processed and stored in the United States. By using the Services, you consent to such processing. Users in jurisdictions which forbid processing of data within the U.S. should not use Mezzi.

11. California Privacy Rights

California residents have rights under the California Consumer Privacy Act and California Privacy Rights Act, including rights to access, delete, and limit certain uses of personal information, subject to applicable legal exceptions.

Mezzi does not sell or share personal information for cross-site behavioral advertising.

Requests about your data may be submitted through the Services or by contacting us as described below.

12. Updates to This Policy

We may update this Privacy Policy from time to time. Changes will be reflected by an updated “Last Updated” date.

13. Contact Us

If you have questions about this Privacy Policy or your information, contact:

Email: [email protected]