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 keep the trades and rules you tell Coach Liv about, once you have confirmed them, so that Coach Liv can measure your trading against your own rules. That record is used to coach you and for nothing else. Section 4.5 explains it.
• We do keep the one setup screenshot you upload at signup. That image is the baseline Coach Liv measures your later setups against, so the service does not work without it. Section 4.5 explains why, and Section 8 says how long we keep it.
• We keep your conversation history inside your own Coach Liv so that it remembers your context from one session to the next. It is deleted when you delete your account.
• Coach Liv's responses are generated by an AI model provider (currently Google, for Gemini) under our own business account with that provider. You do not need an account or an API key with the provider, and we no longer ask for one.
• Our staff may, under controlled conditions, read your Coach Liv's content in order to provide support and improve the service. We read your conversation history only when we need it to resolve an issue affecting your account, and our internal rules prohibit extracting personally identifying information or trading profit-and-loss information from any such review.
• 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 your email address, legal name, date of birth, OAuth subject identifier, signup IP address, and Telegram initData in encrypted form.

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 AI model access

Coach Liv's responses are generated by an AI model provider (currently Google, for Gemini). We operate Coach Liv under our own business account with that provider. You do not need your own account with the provider, and we do not ask for or store an API key from you. If you provided an API key to us before September 2026, under our earlier Bring-Your-Own-Key arrangement, we have deleted it. Section 7 describes what the provider receives and on what terms.

4.5 Your trading profile, setup screenshot, trading record, and container content

Coach Liv learns about your trading style so it can be useful to you. You give us most of it in the signup questionnaire inside the Telegram Mini App. It includes:

• Your name as you want Coach Liv to use it
• Your primary trading instrument (e.g., "ES futures")
• Your playbook: your trading style, your stated edge, and the setup you are trying to take
• Your stated daily-loss limit and per-trade risk
• Your session rule (when you trade and when you stop)
• One screenshot of your A+ setup, which you upload during signup
• Background, personality preferences, and other context you choose to share with Coach Liv in conversation

Why we keep the screenshot. The A+ setup image is the reference Coach Liv compares your later setups against. Coaching you on whether a setup matches your own criteria is the core of the service, and it cannot work without the picture of what your criteria look like. So we keep it. Because it is a chart you chose, it may show an instrument, price levels, dates, or anything else that was on your screen when you captured it. We do not read that information out of the image, and we do not build a record of what you trade from it — but we do hold the image itself.

We keep your answers and your screenshot after signup. We hold onto them so that you can leave signup partway through and pick it back up, so that we can build and rebuild your Coach Liv from them, and so that you can change your strategy later without starting over. They stay with your account until you delete it. Section 8 sets out the retention periods.

How we hold them. We store your questionnaire answers and your setup screenshot in encrypted form. Encryption protects that information if our storage is ever reached by someone who should not have it. It does not mean we are unable to see it: we hold the keys, and your own Coach Liv has to be able to read this information in ordinary form in order to coach you.

Your trading record. When you tell Coach Liv about a trade — when you got in, where your stop was, when and where you got out, how many contracts or shares — Coach Liv reads it back to you and, once you confirm it, keeps it in a record inside your own Coach Liv. The same goes for the rules you set for yourself (a maximum number of trades a day, a daily loss limit, a trading window, and the like) and for any exception you decide to make to them. Coach Liv measures your results in points and in "R," your result relative to the risk you set. It shows dollar figures only if you tell it what a point is worth for your contract; it never works them out on its own.

Why we keep it. Coach Liv keeps your trading record for one reason: to coach you. It checks your trading against the rules you set, tells you where the two match and where they do not, and remembers what it found so that its coaching fits you better over time. That is the whole use. We do not use your trading record to trade, to advise anyone else, to market to you, to sell or share, or to train AI models.

It is your record. Coach Liv writes nothing to it that you have not confirmed, and every correction is kept alongside the original rather than written over it. You can ask Coach Liv to read it back or to give you a copy at any time. It stays with your account and is deleted when you delete your account, on the same terms as your conversation history (Section 8).

What Coach Liv writes about you. Coach Liv keeps a coaching notebook: its own running notes about your trading, your patterns, and the arc of your progress, drawn from your conversations and from your trading record. Those notes belong to your Coach Liv and are covered by everything this policy says about its content.

Your conversation history. Coach Liv keeps a record of your conversations so that it can remember your context from one session to the next. That record stays with your account and is deleted when you delete your account. Any chart or image you send Coach Liv during a conversation is part of that record and is handled the same way. The one image we keep separately, and on purpose, is the A+ setup screenshot described above.

How our staff may access this content. Our staff may read your Coach Liv's content in two situations, and only these:

1. To resolve a support request, bug report, or operational incident affecting your account, and
2. To review, on a sampled basis, the profile and coaching notes Coach Liv maintains, so that we can improve Coach Liv's design, features, and quality.

We read your conversation history and your trading record only under (1) — that is, only when reading them is necessary to resolve an issue affecting your account. Neither is part of our sampled review.

Whenever our staff access this 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. We do not use this 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, the coaching notes Coach Liv writes for you as described in Section 4.5, and the arithmetic Coach Liv does on your own trading record — counts, results in points and R, and checks against the rules you set — which exists only to coach you. 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 item that may fall within that category:

• 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, keep your trading record and measure it against your own rules, and maintain your account.
• To personalize your coaching. Use your profile, your conversations, and your trading record so that Coach Liv's coaching fits you, and only you.
• 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 your Coach Liv's content 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 and (b) sampled review of the profile and coaching notes 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 five categories of recipient listed in the first five 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). Before September 2026, this also included the AI-provider API key that users supplied under our earlier Bring-Your-Own-Key arrangement, disclosed only to that provider.

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 your identity and contact information, your signup questionnaire answers, and your A+ setup screenshot.
• Encryption in transit for all connections to our services (TLS).
• Encrypted off-host backups. Our off-host backups are encrypted so that they can be read only with a decryption key held separately from the systems that create the backups.
• Per-user container isolation so that your Coach Liv, and the conversations, trading record, and files inside it, are separated from every other user's by design.
• Principle of least privilege in our staff access controls.
• Internal-access rules governing what our staff may do when reading your Coach Liv's content for support or improvement purposes (see Section 4.5).
• Retention discipline: explicit retention periods, and automated deletion where we have it in place. Section 8 states plainly where we do not.

Encryption at rest protects your information against someone reaching our storage who should not have it. It is not a limit on our own access: we hold the keys, and Section 4.5 describes the only circumstances in which our staff read your content.

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.

12.4 Backups and your deletion rights

We keep encrypted backups of our systems so we can restore your account and our service if something fails. We use these backups only for that recovery purpose and for nothing else. We keep each backup for up to 15 days, after which it is deleted automatically.

When you ask us to delete your personal data, we remove it from our active systems without undue delay. A copy may remain in our backups until they are deleted — up to 15 days — and during that time the backup stays encrypted and is held "beyond use," meaning we do not access it or use it for anything. If we ever restore from a backup, we re-apply every deletion request made after that backup was taken, so data you asked us to delete is not brought back.

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. It checks your trades against rules you set for yourself and tells you what it finds; it does not tell you what to trade. 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).
• Coach Liv's responses are generated by an AI model provider under our account with it (currently Google, for Gemini). That provider's privacy policy and terms are 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