This Privacy Policy explains how Thulo Inc. ("THULO," "we," "us," or "our") collects, uses, and protects information when you interact with our website, join our waitlist, and — once generally available — use the THULO platform. We have written it to be clear and direct. If anything is unclear, contact us at [email protected].
At the current waitlist stage, the information we collect is limited and intentionally minimal:
When the THULO platform becomes available, we will collect additional information necessary to operate the service — including account credentials, strategy configurations you create, broker connection metadata (via OAuth — we never receive your broker password), and audit logs of AI-agent activity within your account. A more detailed product-stage privacy notice will be presented at account creation.
We use the information we collect for the following purposes, and no others without your consent:
We share information only with service providers who help us operate THULO (for example, email delivery, hosting, and analytics providers), and only under written agreements that require them to protect your information and use it solely on our instructions. We also disclose information when required by law, in connection with a legal proceeding, to protect our rights or the safety of users, or in the event of a corporate transaction (with notice to you wherever practicable).
We apply reasonable administrative, technical, and physical safeguards to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include encryption in transit (TLS), encryption at rest for sensitive data, least-privilege access controls, audit logging, and — on the production platform — physically isolated per-user compute environments. No system is perfectly secure, but we work continuously to harden ours, and we will notify affected users without undue delay if a breach affecting their personal data occurs, as required by applicable law.
Depending on where you live, you have rights regarding the personal information we hold about you. THULO honors these rights for all users, regardless of residency:
To exercise any of these rights, email [email protected] from the address associated with your account or waitlist entry. We will verify your identity and respond within the timeframe required by applicable law (generally 30 to 45 days).
THULO uses a small number of cookies and similar technologies. These fall into two categories:
We do not use third-party advertising trackers, retargeting pixels, or cross-site tracking.
We retain waitlist information for as long as your entry is active and for a reasonable period afterward to handle follow-up questions or re-engagement, unless you request deletion sooner. Server logs and analytics data are retained for shorter periods (typically 30 to 90 days) and then deleted or aggregated. Once the platform launches, account information will be retained for the life of your account and a limited period after closure as required by law and our audit-trail obligations.
THULO operates from North America. If you access the site from outside the United States or Canada, you understand that your information may be transferred to, stored, and processed in those jurisdictions. We use appropriate safeguards (such as standard contractual clauses, where applicable) for cross-border transfers.
If you are located in Canada, your personal information is handled in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws. We collect only the personal information necessary for the purposes described in this Policy, we obtain meaningful consent where required, and we limit use, disclosure, and retention accordingly. Canadian users may direct privacy inquiries or complaints to our Privacy Officer at [email protected], and you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada.
Residents of California, Colorado, Connecticut, Virginia, Utah, Texas, and other U.S. states with comprehensive consumer privacy laws have specific rights under those laws — including the rights described in the "Your Rights" section above. Where applicable, you may also have the right to opt out of certain processing activities (for example, profiling for decisions that produce legal effects). THULO does not engage in the "sale" or "share" of personal information as defined under the California Consumer Privacy Act (CCPA), and we do not engage in targeted advertising that would require an opt-out under similar state laws.
THULO is intended for adults aged 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have inadvertently collected information from a minor, we will delete it. If you are a parent or guardian and believe a minor has provided us with personal information, please contact [email protected].
We may update this Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top and, where appropriate, notify you by email or through the site. Continued use of THULO after an update means you accept the revised Policy.
For any privacy question, request, or complaint, write to us. We aim to respond within seven business days.