• Visit our website at http://torowealth.ai
• Use Toro Wealth — an AI-powered portfolio intelligence platform for self-directed investors. Users connect their investment accounts to track holdings, monitor live prices, and receive personalized portfolio analysis from an AI analyst. The platform provides sector breakdowns, benchmark comparisons, tax liability estimates, and a prioritized action plan based on each user's risk profile and financial goals. Toro Wealth is an informational tool operated by El Toro Solutions LLC and is not a registered investment advisor.
• Engage with us in other related ways, including any marketing or events

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You may include: usernames, email addresses, and investment portfolio data including holdings, account balances, and financial goals.

Sensitive Information. We do not process sensitive information.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for the following reasons:

• To facilitate account creation and authentication and otherwise manage user accounts
• To deliver and facilitate delivery of services to the user
• To respond to user inquiries and offer support
• To send administrative information to you
• To request feedback
• To protect our Services
• To evaluate and improve our Services, products, and your experience
• To identify usage trends
• To comply with our legal obligations

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information in specific situations: Business Transfers — We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

4. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

Yes. We offer products, features, or tools powered by artificial intelligence. We provide AI Products through third-party service providers including Anthropic. Your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. We will keep your personal information for the period of time in which users have an account with us.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including row-level security ensuring only you can access your own data, JWT authentication on every API call, and encrypted storage of all financial data. However, no electronic transmission over the Internet can be guaranteed to be 100% secure.

7. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age.

8. WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change, or terminate your account at any time. To exercise your rights, contact us at [email protected].

9. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, or other states with privacy laws, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, get a copy of, or delete your personal information. Contact us at [email protected] to exercise these rights.

11. INVESTMENT DATA AND FINANCIAL INFORMATION

Toro Wealth collects and stores investment portfolio data including holdings, account balances, and transaction history provided by users or synced via third-party brokerage connections (Plaid). This financial data is used solely to provide portfolio analysis and informational insights within the Toro Wealth platform. We do not sell, share, or use your financial data for advertising purposes. All financial data is encrypted at rest and protected by row-level security ensuring only you can access your own data. Toro Wealth is operated by El Toro Solutions LLC and is not a registered investment advisor. Nothing in this platform constitutes personalized investment advice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated date at the top of this Privacy Notice.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

El Toro Solutions LLC
2475 Brickell Ave, Apt 2205
Miami, FL 33129
United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

To request to review, update, or delete your personal information, please visit: [email protected]