Pure Benchmarks Privacy Policy

Effective Date: February 14, 2026

At Pure Benchmarks, Inc. ("Pure Benchmarks," "we," "us," or "our"), we are committed to protecting your financial privacy. This Privacy Policy explains how we collect, use, and safeguard your data when you use our portfolio benchmarking services, and your rights under U.S. federal and state law, including CFPB Section 1033 and the 2026 updates to CCPA.


1. Our Zero-Access Commitment

Pure Benchmarks operates strictly on a read-only basis. We do not—and cannot—access your brokerage or bank login credentials, move funds, execute trades, or modify your accounts. Our Service provides analytics only, not transactional capabilities.


2. Information We Collect

To provide the Service, we collect the following categories of information:

a. Account Identifiers: Name and email address provided at sign-up.
b. Financial Account Data: When you authorize account connections through third-party aggregators (e.g., Plaid), we receive read-only data including holdings, balances, cost basis, and transaction history.
c. Pseudonymized Benchmarking Data: We generate analytics by removing personal identifiers and comparing your portfolio's performance against other users. This aggregated data may be used for benchmarking, research, or statistical analysis but cannot be linked back to you personally.


3. How We Use Your Data

We use your information only for purposes you have authorized:

Portfolio Benchmarking: Calculating performance and comparing to peer groups.
Service Improvement: Refining algorithms, ensuring data accuracy, and improving the user experience.
Compliance and Security: Detecting anomalies, enforcing Terms of Use, and meeting legal obligations.
No Data Selling: We do not sell your personally identifiable information (PII) to third parties, advertisers, or mailing lists.


4. Data Aggregators & Third Parties

Aggregator Role: We use industry-standard aggregators to securely connect your accounts. These partners operate as a bridge between your brokerage and Pure Benchmarks. You agree to their privacy policies when you authorize account connections.

Service Providers: We may share data with cloud providers (e.g., Google Cloud Platform/Services) solely for the purpose of operating the Service. These providers are contractually prohibited from using your data for other purposes.

Lag / Latency Warning: Aggregators may have 24–48 hour delays or temporary syncing issues. Pure Benchmarks is not liable for financial decisions made based on stale data.


5. Your Rights & Data Control (CCPA / CFPB 1033)

You have the following rights under federal and state privacy laws:

Right to Delete (Permanent): You may delete your account and all associated financial data at any time. All deleted data is permanently removed and cannot be recovered, including historical portfolio records. You are responsible for retaining any data you wish to keep prior to deletion.
Right to Revoke: Disconnect your financial accounts at any time, which immediately terminates our access to that data.
Annual Re-authorization: Federal standards require users to re-authorize account connections every 12 months to confirm consent.
Right to Access: You may request a copy of the personal information we have collected about you since you created your account.


6. Data Security

We use enterprise-grade security measures to protect your information:

Encryption: All data is encrypted in transit (TLS 1.2+) and at rest (AES-256).
No Credential Storage: We never see or store your brokerage usernames or passwords. All authentication occurs via secure aggregator portals.
Security Reporting & Credential Safety: Pure Benchmarks will never request your brokerage or bank login credentials by email, phone, or any other channel. If anyone claims to be from Pure Benchmarks and asks for this information, do not provide it. Immediately contact us at support@purebenchmarks.com to report the attempt.
User Responsibility: You are responsible for maintaining the security of your Pure Benchmarks login credentials and must notify us immediately of unauthorized access.


7. Data Retention

Your personal and financial data is retained only while your account is active.

Upon account closure, all personal identifiers and financial records are deleted within 45 days.

Aggregated, anonymized benchmarking data may be retained indefinitely for research and global performance benchmarks but cannot be linked back to any individual user.


8. Children's Privacy

The Service is for individuals 18 years or older. We do not knowingly collect data from minors.


9. Cookies & Tracking (Website / App)

If we use analytics or performance-monitoring tools, they are limited to essential functions and do not collect personally identifiable information.


10. Contact Us

For privacy inquiries or to exercise your rights, contact our Data Privacy Officer:
Pure Benchmarks, Inc.
PMB 1159, 10900 Research Blvd, Ste 160C
Austin, TX 78759, United States
Email: privacy@purebenchmarks.com


11. Implementation Notes for Compliance

To comply with 2026 CCPA Dark Pattern Prohibitions and federal privacy standards:

"Accept" and "Decline" buttons must be equal in size and color.
Users may not be pre-checked for optional data-sharing programs.
Links to this Privacy Policy must be persistent in the website footer and app Settings.
During sign-up, users must actively click a checkbox stating "I have read and agree to the Privacy Policy." This ensures enforceability of consent, including arbitration clauses in the Terms of Use.

Disclaimer: Pure Benchmarks is not a registered investment advisor or broker/dealer. The materials and information accessible on or through the Services should be used solely for informational purposes. No Content published as part of the Services constitutes a recommendation that any particular investment, security, portfolio of securities, transaction or investment strategy is tailored to the investment needs of any specific person so it may not be suitable for you. You should not rely solely upon the research or opinions herein for purposes of transacting securities or other investments. You should always conduct your own research and due diligence and obtain professional advice before making any investment decision. You hereby acknowledge and agree that we do not operate the Services as an offer to, or solicitation of, any potential clients or investors for the provision by us of investment management, advisory or any other service. You agree not to construe any Content or materials listed on the Services as tax, legal, insurance or investment advice or as an offer to sell, or as a solicitation of an offer to buy, any security or other financial instrument. None of the Pure Benchmarks Parties (defined below) nor any other users will be liable for any loss or damage caused by reliance on any information obtained through or from the Services or any Content (including without limitation any User Content). NO GUARANTEE CAN BE MADE IF YOU INVEST BASED ON THE INFORMATION PROVIDED ON OR THROUGH THE SERVICES. Read all terms.

© 2026 Pure Benchmarks. All rights reserved.