AI Policy

Last updated: March 1, 2026

Sherlock Technologies Inc., doing business as Ape AI ("Ape AI," "we," "us," or "our"), is committed to transparency about how we use artificial intelligence in our Services. This AI Policy explains what personal data we share with third-party AI service providers, who those providers are, how we use data to improve our Services, and how we obtain your permission before sharing your data.

This policy should be read alongside our Privacy Policy, which provides additional detail about how we collect, store, and protect your personal data.

Use of Artificial Intelligence

Ape AI uses third-party AI services to power features such as personalized financial analysis, chat-based assistance, and market insights. These AI-powered features help us deliver tailored recommendations based on your financial data.

Third-Party AI Providers and Your Data

All third-party AI service providers we work with operate under data processing agreements with us. These providers are contractually prohibited from using your personal data for their own purposes, including training their AI models on your data. Your data is sent to these providers exclusively to generate responses and analysis within our Services.

Use of Your Data for Model Training

Ape AI uses data from your interactions with our AI features to develop, train, and improve our own proprietary models and Services. This helps us provide more accurate financial analysis, better recommendations, and an improved user experience over time.

This feature is enabled by default when you accept this AI Policy. You can disable it at any time through your account settings without affecting your ability to use any features of our Services.

When data is used for model training, we apply the following safeguards:

Pseudonymization: Direct identifiers (your name, email, account credentials, and account ID) are stripped before data enters any training pipeline. However, we recognize that chat conversations and portfolio data may contain information that is unique to you even after direct identifiers are removed. We treat this data as pseudonymized and apply appropriate protections under applicable data protection laws.
No re-identification: We do not attempt to re-identify pseudonymized training data or link it back to individual accounts.
Access controls: Training datasets are accessible only to authorized personnel involved in model development.
No third-party sharing: Training data is never sold, licensed, or shared with third parties. Our use of pseudonymized data for internal model training does not constitute a sale or sharing of personal information under the California Consumer Privacy Act (CCPA).

If you disable model training, we will no longer use your data for training purposes. Your data will continue to be processed as needed to provide AI-powered features, but it will not be included in any training datasets. Data that has already been incorporated into a trained model's parameters cannot be individually extracted or deleted, as this is a technical limitation of how machine learning models work. However, any training data that has not yet been incorporated into a model will be deleted within 30 days of your opt-out.

What Data Is Sent to AI Providers

When you use our AI-powered features, the following data is sent to third-party AI service providers to generate personalized responses:

Chat messages and conversation history: The text you enter in chat conversations, along with prior messages in the same conversation, to provide contextual responses.
Portfolio and holdings data: If you have linked a brokerage account, your holdings, positions, account balances, and realized profit/loss may be shared to generate personalized financial analysis.
Watchlist data: Symbols and instruments on your watchlists, along with current quotes, to provide relevant market insights.
User preferences: Your experience level and selected avatar/persona, to tailor the tone and depth of AI responses.
Market and financial data: Publicly available stock prices, technical indicators, fundamental data, news articles, and sentiment data relevant to your queries.

We do not send the following to AI providers: your email address, password, payment information, real name, or other account credentials.

Who Receives This Data

We use the following third-party AI service providers to process your data:

| Provider | Service | Purpose | | --- | --- | --- | | Google LLC | Vertex AI / Gemini | Chat response generation and financial analysis | | OpenAI, L.L.C. | GPT | Chat response generation and financial analysis | | Groq, Inc. | Groq Cloud | Low-latency chat response generation | | Cerebras Systems, Inc. | Cerebras Inference | Low-latency chat response generation | | OpenRouter | Model routing | Routing requests to additional AI models |

For each provider's data practices, refer to their privacy policies: Google | OpenAI | Groq | Cerebras | OpenRouter

Data Retention

Chat data sent to third-party providers is processed in real time and is not stored by these providers beyond their standard abuse-monitoring retention periods, which range from 7 to 55 days depending on the provider. Refer to each provider's privacy policy for specific retention periods.
Your chat history is stored on our servers for as long as your account is active, so that you can access past conversations. You can delete individual conversations or your entire chat history at any time through your account settings. Note that some data may be retained as required for security, legal compliance, or platform integrity, and that any data already used for model training is subject to the training data retention terms below. See our Privacy Policy for full retention details.
Training data (unless you have opted out) is retained in pseudonymized form for up to 3 years from the date of collection to support ongoing model improvement. If you opt out, unprocessed training data is deleted within 30 days.
Account deletion: When you delete your account, all associated chat history and personal data is deleted in accordance with our Privacy Policy. Pseudonymized data that has already been incorporated into model parameters cannot be individually extracted.

Your Controls and Choices

You have the following controls over how your data is used with AI features:

Model training (opt-out): Model training is enabled by default. You can disable the use of your data for improving Ape AI's models at any time through your account settings.
Chat history deletion: You can delete individual conversations or your full chat history from your account settings. Deletion removes the data from your account view; some data may be retained as described in our Privacy Policy.
Account deletion: You may delete your account at any time, which will remove your personal data in accordance with our Privacy Policy.

Your Permission and Consent

Our Services are AI-native — artificial intelligence is integrated across all features of our platform. By creating an account and using Ape AI, you agree to this AI Policy, including the sharing of data with third-party AI providers as described above. This consent is required to use our Services, as AI processing is essential to their functionality.

Model training is enabled by default when you accept this AI Policy. You are not required to keep model training enabled to use our Services — you can disable it at any time in your account settings. The consent screen will clearly indicate that model training is enabled by default and provide information on how to disable it.

If you do not agree to this AI Policy, please do not use our Services. You may delete your account at any time to withdraw your consent and have your personal data removed.

Legal Basis for Processing (EEA/UK Users)

For users in the European Economic Area or United Kingdom, our legal basis for processing your data for AI-powered features is contract performance (the data sharing with third-party providers is necessary to deliver the AI features you use). Our legal basis for model training is legitimate interests (Article 6(1)(f) GDPR) — specifically, our interest in improving the quality and accuracy of our Services. We have assessed that this interest does not override your rights, particularly because: (a) direct identifiers are stripped before training, (b) you can opt out at any time without losing access to features, and (c) training data is never shared with third parties. You have the right to object to this processing under Article 21 GDPR by disabling model training in your account settings.

International Data Transfers

Our AI service providers process data in the United States and other regions. For users in the European Economic Area (EEA) or United Kingdom, we ensure appropriate safeguards for international data transfers, including Standard Contractual Clauses where applicable. For more information, see the International Data Transfers section of our Privacy Policy.

Children's Privacy

Our Services are not directed to individuals under 18. We do not knowingly collect data from children through our AI features. If you believe a child has provided data through our Services, please contact us to request deletion.

Changes to This Policy

We may update this AI Policy from time to time. For material changes — such as changes to how we use your data for model training or changes to which third-party providers receive your data — we will notify you via email or an in-app notification at least 30 days before the changes take effect. We encourage you to review this policy periodically.

Limitations and Disclaimers

AI-generated content provided through our Services is for informational purposes only and does not constitute financial advice, investment recommendations, or any form of fiduciary guidance. AI responses may contain inaccuracies or errors. You should independently verify any information before making financial decisions. We are not responsible for any actions taken based on AI-generated content.

Our AI models are not designed to provide personalized investment advice as defined by the SEC or FINRA. The use of AI-powered features does not create a fiduciary, advisory, or broker-dealer relationship between you and Ape AI.

Contact Us

If you have any questions about this AI Policy, please contact us at [email protected].