Privacy Policy

SharePulse is an investor relations intelligence platform operated by Onfolio Holdings, Inc. ("SharePulse", "we", "us"). This policy explains what data we collect, how we use it, and the choices you have. It applies to sharepulse.ai, dashboard.sharepulse.ai, and related services.

1. Who we serve

SharePulse is sold to small-cap public companies ("Issuers") and to investor relations firms ("IR Firms") that serve them. References to "Customer" mean the Issuer or IR Firm that has subscribed. References to "End User" mean an individual who logs into a Customer account. References to "Site Visitor" mean anyone who visits our marketing site without an account.

2. Data we collect

From Site Visitors

• Form submissions (name, email, company website) when you request access.
• Basic request metadata (IP, user-agent, referrer) for security and abuse prevention.
• Essential cookies needed to operate the site. We do not run third-party advertising cookies.

From End Users (Customer accounts)

• Account profile: name, work email, role.
• Authentication tokens from Google OAuth, ActiveCampaign, and other integrations you choose to connect.
• Usage telemetry: pages viewed, features used, error logs.

Customer Data uploaded into the platform

• NOBO and Transfer Agent shareholder lists.
• Investor CRM contacts (e.g. ActiveCampaign sync).
• Email engagement, survey responses, and meeting notes.
• Documents you upload (decks, fact sheets, filings).
• Public market data we ingest on the Customer's behalf (filings, price/volume, peer activity, mentions).

Customer Data belongs to the Customer. We process it on the Customer's behalf to operate the platform.

3. How we use data

• Provide, secure, and improve the platform.
• Generate the AI-assisted insights, drafts, and reports the Customer requests. All AI output is reviewed by a human at the Customer before anything external happens — SharePulse does not auto-send communications on a Customer's behalf.
• Respond to support requests.
• Send service emails (billing, security, product updates). Marketing emails are opt-in and you can unsubscribe at any time.
• Detect abuse, debug errors, and meet legal obligations.

We do not sell personal information. We do not use Customer Data to train third-party AI models.

4. Sub-processors

We use the following infrastructure and service providers to run SharePulse. Each handles the data minimum needed for its function:

• Cloudflare — marketing site hosting and DDoS protection.
• Railway — dashboard application hosting and database.
• Anthropic — Claude API for AI drafting and analysis. Anthropic does not train on Customer Data sent via the API.
• OpenAI — used in LLM perception audits to measure how AI assistants describe Customers.
• Polygon (Massive) — market data.
• Google (OAuth, Gmail API, Analytics, Search Console) — when the Customer connects these.
• ActiveCampaign — email and contact sync when connected.
• Stripe — billing and payment processing.
• ScrapingBee — proxy fetching for public mention monitoring.

An up-to-date sub-processor list is available on request.

5. Data retention

We keep Customer Data for the life of the subscription. On termination, Customer Data is exported on request and deleted from production within 30 days, and from backups within 90 days. Billing and compliance records are kept as long as legally required.

6. Security

We use industry-standard practices: TLS in transit, encryption at rest, scoped credentials per Customer, audit logging, and role-based access. No system is perfectly secure, and we cannot guarantee absolute security — but we'll notify affected Customers without undue delay if we identify a breach involving their data.

7. International transfers

SharePulse is operated from the United States. If you access the platform from outside the US, you understand that your data will be processed in the US and other jurisdictions where our sub-processors operate.

8. Your rights

Depending on where you live, you may have the right to access, correct, delete, or export your personal data, and to object to certain processing. To exercise these rights:

• If you are an End User of a Customer, contact your Customer admin first — they control the account.
• For everything else, email contact [at] onfolio [dot] com.

We respond within 30 days. We do not discriminate against you for exercising a privacy right.

9. Children

SharePulse is a B2B product not intended for anyone under 18. We do not knowingly collect data from children.

10. Changes

We may update this policy as the product evolves. Material changes will be flagged on this page and, where appropriate, by email. The "Effective" date at the top reflects the current version.

11. Contact

Questions, requests, or concerns: contact [at] onfolio [dot] com
Onfolio Holdings, Inc., a Delaware corporation.