Privacy Policy

About this policy

Easy Street Labs LLC ("Easy Street Labs," "we," "us," or "our") respects your privacy. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, how long we keep it, and the rights you have over it.

This policy applies to:

• Our website at easystreetlabs.com,
• Coach Liv (our AI trading-coach service, including the Coach Liv Telegram bot and Coach Liv Telegram Mini App), and
• Any other Easy Street Labs product or service that links to this policy.

Coach Liv is designed for, marketed to, and intended for use by individuals located in the United States. Easy Street Labs LLC is a United States company with no establishment in the European Economic Area, the United Kingdom, or Switzerland, and does not direct its marketing, pricing, language localization, or service offering to those regions. This policy is governed by California law. The provisions of Section 12.2 describe rights we honor as a matter of good practice for any user who is nonetheless located in the European Economic Area, the United Kingdom, or Switzerland and who has accessed Coach Liv.

If you do not agree with this policy, do not use our services.

Who we are and how to contact us

The data controller (and the "business" under California law) is:

Easy Street Labs LLC
Email: legal@easystreetlabs.com

We have not appointed a Data Protection Officer because we are not required to do so under any law applicable to us. We have not appointed an EU Article 27 representative because, as described in Section 1, we do not target our service to the European Economic Area, the United Kingdom, or Switzerland. If our service posture changes in this respect, we will update this policy and appoint a representative as required.

For all privacy questions, requests, or complaints, contact legal@easystreetlabs.com.

Quick summary

Plain-English version of what's below:

• We collect what we need to deliver Coach Liv and run our business — nothing more.
• We do not sell or share your personal information for advertising, cross-context behavioral advertising, or any monetary or other consideration.
• We do not collect your actual trade entries, exits, sizes, profit and loss, screenshots, or the specific tickers you trade. Our internal Data Inventory expressly prohibits collection of these items.
• Coach Liv uses a Bring-Your-Own-Key ("BYOK") architecture: you maintain your own account and API key with the AI model provider (currently Google, for Gemini). Your conversations with Coach Liv are processed under your relationship with that provider.
• Our staff may, under controlled conditions, read content inside your provisioned container in order to provide support and improve the service. We have internal rules that prohibit extracting personally identifying information or trading profit-and-loss information from those reviews.
• You have meaningful rights over your information, including the rights set out in the California Consumer Privacy Act (as amended by the California Privacy Rights Act, "CCPA/CPRA"). For users located in the European Economic Area, the United Kingdom, or Switzerland, we additionally honor the rights described in Section 12.2 as a matter of good practice.
• The full text below controls.

The personal information we collect

We collect the categories of personal information described in this section. The categories below use the labels from the CCPA/CPRA. The sources, purposes, legal bases, and retention details are in Sections 5–8.

4.1 Identifiers and contact information

When you sign up for Coach Liv, we collect:

• Email address
• Legal name
• Date of birth (used solely to confirm you are 18 or older and to record your age at signup for compliance purposes)
• Your unique subject identifier from your OAuth provider (Google or Apple, depending on which you choose)
• Your Telegram user ID, Telegram username (if you have one), and Telegram locale
• The signed Telegram initData payload that the Telegram Mini App provides to verify your identity

We store the email address, legal name, date of birth, OAuth subject identifier, signup IP address, and Telegram initData in encrypted form (Fernet encryption at rest).

4.2 Commercial information

• Subscription status, plan, billing cycle, and trial state
• Subscription cancellation events and reasons
• The fact that you have a payment method on file with our payment processor (we do not receive, store, or process your full payment card details — Stripe handles payment information directly under its own privacy policy)

4.3 Internet or other electronic network activity information

• Your IP address at signup
• The User-Agent string of the browser you used at signup
• Your time zone (as reported by your device or selected by you)
• High-level container telemetry: resource usage, error logs, and counts of API calls your provisioned Coach Liv instance makes to the AI model provider (we collect counts, not the content of those calls)
• Bug reports you submit to us via Discord or direct channels
• Standard analytics data about visits to easystreetlabs.com (see Section 14 on Google Analytics)

4.4 Service-account credentials

• The API key you provide for your account with the AI model provider (currently Google, for Gemini). We store this credential encrypted at rest and use it solely to operate Coach Liv on your behalf. We do not use it for any other purpose, do not share it with any third party other than the AI provider you have an account with, and revoke our copy upon account deletion.

4.5 Trading-profile and in-container information

Coach Liv learns about your trading style to be useful to you. This information lives in your own isolated, per-user container. It includes:

• Your primary trading instrument (e.g., "ES futures")
• Your trading style (e.g., scalping, swing, structural)
• Your stated edge or area of focus
• Your stated risk tolerance or daily-loss limit
• Background, personality preferences, and other context you choose to share with Coach Liv
• The conversation history between you and Coach Liv inside your container

We do not collect or store your actual trade entries, exits, sizes, profit and loss, chart screenshots, or the specific tickers you are actively trading. Our internal Data Inventory expressly prohibits collection of these items.

How our staff may access this content. Our staff may, on a limited basis, read content inside your container — including USER.md and conversation history — for two purposes only:

1. To respond to a support request, bug report, or operational incident affecting your account, and
2. To improve Coach Liv's design, features, and quality, on a sampled basis.

When our staff access in-container content, we follow internal rules that prohibit recording, screenshotting, exporting, or otherwise extracting personally identifying information (names, contact details, identifiers tying content to a specific user) or trading profit-and-loss information from those reviews. We do not use in-container content for advertising, profiling, training third-party AI models, or any purpose other than the two listed above.

4.6 Compliance and legal records

• Records that you accepted our Disclaimers and our Non-Disclosure Agreement, including timestamp and version
• Your age at signup (the record that you confirmed you were 18 or older)
• Records of any rights requests you submit (see Section 12)
• Records of subscription, cancellation, and deletion events, including a deletion audit log
• Operational notes from our staff regarding your account (used solely for support; not used for analytics, marketing, or profiling)

4.7 Trade-secret-protection audit records

To protect Coach Liv's underlying proprietary materials (the "Protected Materials") and to satisfy the "reasonable measures" requirement of the federal Defend Trade Secrets Act, 18 U.S.C. § 1836 et seq., and analogous state trade-secrets statutes, we maintain a technical control that detects when a generated response would disclose Protected Materials and blocks delivery of that response. When the control fires, we write an Audit Record that describes the detected match: an event identifier, a timestamp, the configured detection threshold, the length of the blocked response, the file or files in which the match was found, and the position and length of the match.

The Audit Record does not contain the content of your message, the content of the blocked response, or any information from your conversation history. It is tied to your internal Coach Liv account identifier, which is correlatable to your Telegram user ID.

We retain Audit Records for seven (7) years from the timestamp of each event, including after you cancel your subscription. The Audit Records are stored append-only and used only for trade-secret-protection purposes, including for the documentation of our protective measures and any future trade-secret enforcement.

4.8 Inferences

We currently draw no automated inferences about you beyond the operational state your Coach Liv container needs to do its job. We do not score, segment, profile, or rank users for marketing or any other purpose.

4.9 Sensitive personal information (as defined by California law)

The CCPA/CPRA defines a category called "Sensitive Personal Information." We collect the following items that may fall within that category:

• Account log-in credentials for the AI model provider you use with Coach Liv (your API key). Encrypted at rest. Used only to operate the service you have purchased.
• Contents of your communications with Coach Liv, to the extent processed by the AI model provider and to the extent our staff access them under the limited circumstances described in Section 4.5.

Our use of Sensitive Personal Information is limited to the purposes permitted by California Civil Code § 1798.121 — namely performing the services you requested, ensuring the security and integrity of our services, providing support to you, and short-term, transient use as necessary to operate the service. We do not use Sensitive Personal Information for advertising, profiling, or any purpose outside those permitted purposes, and we therefore are not required to provide a "Limit the Use of My Sensitive Personal Information" link. If you would still like to instruct us to further limit our use, you may contact us at legal@easystreetlabs.com.

4.10 What we do not collect

We do not collect:

• Your Social Security number, driver's license number, state ID, or passport number
• Your precise geolocation (we infer rough region from time zone only)
• Information about your race or ethnic origin, religious or philosophical beliefs, union membership, sexual orientation, sex life, or genetic or biometric data
• Health information
• Personal information about anyone under the age of 18 (see Section 10)

Where we get personal information

We collect personal information from:

Why we collect personal information

We use personal information for the following purposes:

• To provide Coach Liv. Provision your isolated container, operate the service, deliver coaching responses, and maintain your account.
• To bill you and manage your subscription. Activate trials, charge subscription fees, process cancellations, and issue refunds where appropriate.
• To support you. Respond to your support requests, bug reports, and account-related inquiries, including by reviewing content inside your container under the limited conditions described in Section 4.5.
• To improve our services. Understand which features are used, where users encounter friction, and how to make Coach Liv better — including (a) aggregated, population-level analytics with an aggregation floor that suppresses small-cohort results, and (b) sampled review of in-container content under the limited conditions described in Section 4.5.
• To meet legal and compliance obligations. Verify that you are 18 or older; record acceptance of our Disclaimers and Non-Disclosure Agreement; respond to lawful requests from authorities; maintain records required by tax, accounting, anti-fraud, and consumer-protection laws.
• To protect our trade secrets and the integrity of the service. Operate the technical controls described in Section 4.7 and maintain the resulting Audit Records.
• To keep our services secure and reliable. Detect, prevent, and respond to fraud, abuse, security incidents, technical errors, and misuse.
• To communicate with you. Send transactional messages relating to your subscription, security, and the operation of Coach Liv, and — where you have the option to receive them and have not opted out — informational or marketing communications about Coach Liv and Easy Street Labs. Where required by applicable law, we will obtain your consent before sending marketing communications and you may opt out at any time.

Who we share personal information with

We share personal information with the categories of third parties described below, and only for the purposes described. As of the effective date of this policy, the four categories of recipient listed in the first four rows are the only third parties to whom we routinely transmit personal information; the remaining rows describe categories of recipient that may apply in defined and limited circumstances.

7.1 We do not sell or share personal information

We do not "sell" personal information in exchange for monetary or other valuable consideration, and we do not "share" personal information for cross-context behavioral advertising, as those terms are defined under CCPA/CPRA. We have not done so in the preceding 12 months, and we have no plans to do so. We do not knowingly sell or share personal information of California residents under 16 years of age.

7.2 Disclosures for business purposes (last 12 months)

In the preceding 12 months, we have disclosed the categories of personal information described in Sections 4.1–4.7 for the business purposes described in Sections 6 and 7, including sensitive personal information consisting of contents of communications (within the limits described in Section 4.5) and your AI-provider API key (to the AI provider under your BYOK relationship).

How long we keep personal information

We retain personal information only as long as we need it for the purpose for which we collected it, or longer if we are required to keep it by law.

Where retention is described as "at least 4 years," the period reflects the longest of: the applicable statute of limitations for contract and consumer claims (which may reach four years under California law), tax and accounting recordkeeping rules, and the period needed to demonstrate that we operated the service lawfully. Beyond that period, we delete or de-identify the information.

How we protect personal information

We take security seriously. Our measures include:

• Encryption at rest of identity records (email, legal name, date of birth, OAuth subject ID, signup IP address, Telegram initData) and of your AI-provider API key, using authenticated encryption (Fernet).
• Encryption in transit for all connections to our services (TLS).
• Per-user container isolation so that one user's data and conversations are isolated from another's by design.
• Principle of least privilege in our staff access controls.
• Aggregation floor in any internal analytics: queries that would touch fewer than a documented threshold of users return "insufficient cohort size" rather than identifying information.
• Internal-access rules governing what our staff may do when reviewing in-container content for support or improvement purposes (see Section 4.5).
• Retention discipline: explicit retention periods, automated deletion where feasible, no "just in case" indefinite retention.

No security measure is perfect. We cannot guarantee that personal information will never be compromised. If you believe your account has been compromised, contact us immediately at legal@easystreetlabs.com.

Children's privacy

Coach Liv is intended only for adults. You must be 18 years of age or older to use Coach Liv. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will delete that information promptly. Parents or guardians who believe their child has provided us with personal information may contact us at legal@easystreetlabs.com.

Where personal information is processed

Easy Street Labs is established in the United States. Our hosting provider and our other service providers process personal information primarily in the United States. Each of our service providers — DigitalOcean, Stripe, and Google — is self-certified under the EU-U.S. Data Privacy Framework as administered by the U.S. Department of Commerce, and each has entered into a Data Processing Agreement with us (incorporated by reference into our respective terms of service with each provider) that includes the European Commission's Standard Contractual Clauses where applicable.

As stated in Section 1, Coach Liv is not directed to users in the European Economic Area, the United Kingdom, or Switzerland. If you are nonetheless located in one of those regions and have chosen to use Coach Liv, your personal information will be transferred to and processed in the United States, and you are consenting to that transfer by signing up. You can request a description of the applicable safeguards by emailing legal@easystreetlabs.com.

Your rights

12.1 Rights under California law (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know. Request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties to whom we disclosed it.
• Delete. Request that we delete personal information we have collected from you, subject to certain exceptions (such as records we are required to keep by law).
• Correct. Request that we correct inaccurate personal information we maintain about you.
• Opt out of sale or sharing. As explained in Section 7.1, we do not sell or share personal information, so there is nothing to opt out of, but the right exists.
• Limit use of Sensitive Personal Information. As explained in Section 4.9, we use Sensitive Personal Information only for purposes permitted by California Civil Code § 1798.121, so a separate "Limit the Use" link is not required. If you wish to instruct us to further limit our use, contact us.
• Non-discrimination. We will not discriminate against you for exercising any of these rights.

We will not require you to create an account to submit a request. Where applicable, we will respond within 45 days, with one 45-day extension if reasonably necessary, and will tell you if we need the extension. We may need to verify your identity before responding; verification is proportionate to the sensitivity of the request and the risk of harm. You may also use an authorized agent to submit a request on your behalf if you provide the agent with signed permission and we are able to verify both your identity and the agent's authority.

To exercise these rights, email legal@easystreetlabs.com with the subject line "California Privacy Request." Include the right(s) you want to exercise and information sufficient for us to identify your account.

California "Shine the Light"

California Civil Code § 1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for those third parties' direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

12.2 Rights honored as a matter of good practice for users located in the EEA, UK, or Switzerland

As stated in Section 1, we do not target our service to users in the European Economic Area, the United Kingdom, or Switzerland, and we therefore do not treat the General Data Protection Regulation as binding on our processing. If you are nonetheless located in one of those regions and have used Coach Liv, we will honor the following rights as a matter of good practice, subject to verification of your identity and to the limits described in Section 12.3:

• Access: confirm whether we process your personal information and obtain a copy of it.
• Rectification: correct inaccurate or incomplete personal information.
• Erasure: have your personal information erased in defined circumstances.
• Restriction of processing: require us to suspend processing in defined circumstances.
• Data portability: receive your personal information in a structured, commonly used, machine-readable format.
• Objection: object to processing where we have relied on a balancing-of-interests test in this policy.
• Withdrawal of consent: where we relied on your consent, withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

To exercise these rights, email legal@easystreetlabs.com.

12.3 How we respond to requests

We will acknowledge your request, verify your identity using information we already hold, and respond within 45 days of receipt, with one 45-day extension if reasonably necessary. Where we cannot fulfill a request — for example, because we are required to retain certain information by law or because the request implicates our Trade-Secret-Protection Audit Records, which are retained for the period described in Section 8 — we will tell you the reason.

AI-powered services and automated decisions

Coach Liv is an artificial-intelligence service. When you interact with Coach Liv inside Telegram, you are interacting with an AI system. We disclose this in our onboarding flow and again here. Coach Liv produces educational and coaching content; it is not a registered investment adviser and does not place trades for you. You always make your own trading decisions.

Coach Liv does not make decisions about you that produce legal or similarly significant effects. The model used to generate Coach Liv's responses is the proprietary system of the AI model provider (currently Google, for Gemini). You can request meaningful information about how Coach Liv uses your information by contacting us at legal@easystreetlabs.com.

Cookies and similar technologies; web analytics

The Coach Liv service inside Telegram does not use browser cookies.

Our website at easystreetlabs.com uses Google Analytics, a web-analytics service provided by Google LLC and its affiliates ("Google"). Google Analytics uses first-party cookies and similar technologies to collect information about how visitors arrive at and use our website. The information collected typically includes pages visited, time on page, approximate region (from IP address, which Google Analytics 4 anonymizes by default), device type, and referral source. Google processes this information on our behalf as a service provider and provides us with aggregated analytics reports. We do not use Google Analytics for cross-context behavioral advertising, and we do not link Google Analytics data to your Coach Liv account.

If you would prefer not to have your data used by Google Analytics, Google offers a browser opt-out at https://tools.google.com/dlpage/gaoptout. You can also use any "Global Privacy Control" or similar browser signal; we honor those signals where required by applicable law.

If you are in a jurisdiction where applicable law requires us to obtain your consent to non-essential cookies before they are set, we will present you with a cookie banner asking for that consent.

Other than as described in this section, we do not use third-party advertising cookies, cross-site tracking pixels, or behavioral-advertising technology. If this changes, we will update this policy.

Third-party services and links

Our website and the Coach Liv service may link to or interoperate with third-party services that are not operated by Easy Street Labs. Those services are governed by their own privacy policies. We encourage you to read them. In particular:

• Your use of Telegram is governed by Telegram's Privacy Policy (https://telegram.org/privacy).
• Your relationship with the AI model provider you use with Coach Liv is governed by that provider's privacy policy (currently Google's policies for Google AI Studio / Gemini API, available at https://policies.google.com/privacy and https://ai.google.dev/terms).
• Payment processing is governed by Stripe's privacy policy (https://stripe.com/privacy).
• Our web analytics provider's privacy policy is available at https://policies.google.com/privacy.

Changes to this policy

We may update this policy from time to time to reflect changes in our practices, our services, or applicable law. When we make a material change, we will update the "Last updated" date at the top of this policy and, where appropriate, notify you through the Coach Liv service or by email. We encourage you to review this policy periodically.

Contact us

If you have any question, request, or complaint regarding this policy or our handling of your personal information, contact us at:

Easy Street Labs LLC
Email: legal@easystreetlabs.com