Privacy Policy

Information We Collect or Receive

In the course of operating the Platform and providing the Services, we collect or receive the following types of information

1. Personal Information

When you register to become a Customer, you will be asked to provide us with certain information about you, such as, your name, date of birth, National ID number and scan, citizenship,, home address, telephone number, email address, employer name, employment status, job position, whether you are a “politically exposed person,” whether you are a “control person” (pursuant to FINRA Rule 3210), annual Income range, total net worth range, and other information as appropriate for our legitimate business needs (collectively and together with information referenced in Sections 2-6 below, the “Personal Information”). We may also collect Personal Information when you voluntarily provide us with Personal Information as a Visitor, such as when you use our “Contact” form.

2. Nonpublic Personal Information

When you register to become a Customer and at certain times following initial registration during the provision of our Services to you, we will also collect your nonpublic personal information which means (i) any information you provide to us to obtain a financial product or service from us, (ii) any information about you resulting from any transaction involving a financial product or service between us and you, or (iii) any information we otherwise obtain about you in connection with providing a financial product or service to you (collectively, the “Nonpublic Personal Information”). Nonpublic Personal Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy. We may also collect Nonpublic Personal Information from Visitors, who are consumers of our Platform.

3. Investment Style Information

When you register as a Customer, you will be asked to provide information about your investment preferences and investment style such as, your risk tolerance, time horizon, liquidity needs, investment objectives and investment experiences (collectively, the “Investment Style Information”). Investment Style Information may be updated or modified following initial registration during the provision of our Services to you. Investment Style Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy.

4. Transaction Information

When Customers wish to make a purchase, sale or any other transaction through the Platform, they must provide us with certain information about the transaction they are seeking to execute. Such information is collectively called the “Transaction Information.” Transaction Information is a subset of Personal Information and shall be considered Personal Information under this Privacy Policy.

5. Other Information

We may automatically collect or receive additional information about you, your use of our Platform, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our Platform (collectively, the “Other Information”). Such Other Information may include, but is not limited to, the following:

From Your Activity

IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;

Browser type and language;

Referring and exit pages and URLs;

Date and time; and

Details regarding your activity on the Platform, such as search queries and other performance and usage data.

About Your Device

Type of device;

Universally Unique Identifier (“UUID”);

Advertising Identifier (“IDFA” or “AdID”);

Operating system and version (e.g., iOS, Android or Windows);

Wireless carrier; and

Network type (WiFi, 3G, 4G, or LTE).

From Cookies, Web Beacons, and Other Similar Tracking Techniques

In operating the Platform, we may also use data collection and tracking tools such as web beacons, pixel tags, embedded links, cookies, and other similar tracking techniques. A cookie is a piece of information that the computer that hosts our Platform gives to your browser when you access the Platform. Our cookies help provide additional functionality to the Platform and help us analyze the Platform usage more accurately. For example, our Platform may set a cookie on your browser that allows you to access the Platform without needing to remember and then enter a password more than once during a visit to the Platform. In all cases in which we use cookies, we will not collect Personal Information unless we obtain your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. If you do not want 9am to place cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still use the Platform, although your ability to use some of the features may be affected.

Third-Party Analytics

We may use third-party analytics services (for example, we use Google Analytics, Mixpanel, and others) to evaluate your use of the Platform, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, Including how to opt out from certain data collection, please visit or Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.

Information Collected by or Received from Third-Party Sources

We may also collect Personal Information and information about your transactions with us and those you engage in with our affiliates, unaffiliated third parties, banking verification services and information from consumer reporting agencies. We may further collect information about you from third-party data sources, such as brokers, banks and government databases. We may combine data we collect about you from third-party data sources with data we collect from you and may use and share such data as described in this Privacy Policy. All information we collect and/or receive from such third-party sources is collectively referred to as “Third-Party Information.”

Information Collected by or Through Third-Party Advertising

We may share Other Information about you with third parties that 9am has selected and approved for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data. 

How the Information is Used and Shared

You authorize us to use the Personal Information, the Third-Party Information, and the Other Information (collectively, the “Information”) to provide and improve our Platform and Services; to help us improve the content and functionality of our Platform and Services; to provide trade recommendations; to advise you about your portfolio; to solicit your feedback; and to inform you about our products and services and those of third parties.

You also authorize us to use and/or share Information as described below.

We will access, use, and share the Information as required fulfilling our contractual obligations to you or subsequent requests for support by you.

To track your purchases, match your purchases with the other Information we have about you and provide suggestions to you about potential trade recommendations, saving money, and other financial services and offers that we believe may help you.

9am, like many businesses, sometimes hires other companies to perform certain business-related functions on our behalf. Examples of such functions include website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide it with the information that it needs to perform its specific function. These companies are authorized to use your Information only as necessary to provide these services to us.

As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Platform of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

In an ongoing effort to better understand our Customers, the Platform, the Services, and the products and services of 9am, we may analyze certain Information to compile information about our Customer demographics, interests and behaviors and to create data analytics on an aggregate basis. This aggregate information does not identify you personally. We may share this aggregate information with our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Platform, the Services and our products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

9am may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of 9am, (iii) act in urgent circumstances to protect the financial security of users of the Platform or the public against fraud or other harm, or (iv) protect against legal liability.

9am may from time to time enter into agreements with third parties, such as employers or affiliate membership groups, pursuant to which the third-party may pay a portion or all of the advisory fees of its employees or members, and may on occasion make direct or indirect contributions to the 9am account of its employees or members. This is generally implemented by distributed “promotional codes” that are sponsored by the employer or affiliate membership group. If you use the benefit provided by an employer or affiliate group, you consent to additional anonymized reporting with respect to the participation, contribution rates, engagement, etc., of the employees or members, and consent to personalized reporting (i.e., where you may be specifically identified) solely and exclusively to (x) confirm your use of 9am to your employer or affiliate membership group, and (y) if the employer or affiliate membership group makes a contribution to your 9am account, to confirm receipt of the specific amounts contributed. In addition, if the benefit the employer or affiliate group provides includes embedding the 9am experience in a broader experience hosted by the employer or affiliate, by using such benefit you consent to 9am embedding the 9am experience in the hosted experience, and understand that your Personal Information may be shared in order to implement the hosted experience.

We may share your Information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate market research data for us which will not identify you personally. Such third parties will provide us market research data to help us better segment our customer base and understand what products and services would likely work best for our customers.

If you would like to opt-out of 9am sharing of your Information with affiliates and third parties please contact us at email. We will use your Information for our internal business purposes, including but not limited to, creating user state modelling and comprehensive behavioural profiling.

If 9am intends on using your Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Information is collected.

Sharing of Your Information with Non-affiliated Third Parties

We will not share your Information with non-affiliated third parties that may use your Information to market to you, without obtaining your opt-in consent. For example, we may offer you with a product opportunity that requires us to share your Information with non-affiliated third parties that may use your Information to market to you. We will obtain your opt-in consent to such sharing of your Information when we present you with the terms of such offer.

Communication Preferences

When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future newsletters or marketing communications or you wish to have your name deleted from our mailing lists, please following the unsubscribe instructions included in these emails or contact us at (website name ). We will use commercially reasonable efforts to process such requests in a timely manner. Note however that as a user of the Services we and/or our custodian(s) will send you administrative and transactional communications that are reasonably necessary to provide the Services, such as billing, brokerage or service notifications and you cannot opt out of receiving such communications.

We may also deliver notifications to your phone or mobile device. You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.


We may, from time to time, ask you to participate in surveys on our Sites. Participation in these surveys is completely voluntary. These surveys may be conducted by our third-party service providers. Such third-party service providers are authorized to use your information only as necessary to conduct these surveys for us. We will use survey results to continue to improve the Platform and the Services. We will use your Personal Information from our surveys to send you information about our products and services and about third-party products and services. We may combine your survey information with other data we have about you, and if such other data is Personal Information, the combined data shall be considered Personal Information under this Privacy Policy. We may also anonymize and aggregate the survey information and sell it to third parties.

How We Protect Your Information

The security of your information is important to us. When you enter sensitive information in our App, we encrypt the transmission of that information using secure socket layer technology (SSL). We and our custodian also use third-party ID verification to ensure our users’ true identities are validated.

We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. If you have any questions about security on our website, you can contact us at (website name )

Retention of Your Information

We will retain your Information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We will also retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


This Privacy Policy does not apply to any Personal Information collected by 9am other than Personal Information collected through the Platform and/or Services. This Privacy Policy shall not apply to any unsolicited information you provide to 9am through the Platform, or through any other means. This includes, but is not limited to, information posted to any public areas of the Platform (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and 9am shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

Suspicious Email

We do not email you or send you other electronic communications to request nonpublic information or account information (such as username and password). If you receive an unsolicited email or other electronic communication that appears to be from 9am but you suspect it may be from some other source or fraudulent, please email us at (website name )


The Platform is not directed to children under 18, and 9am does not knowingly collect or receive Personal Information from children under the age of 18 through the Platform and/or the Services.

Links to Other Websites and Integration of Third-Party Content

This Privacy Policy applies only to the Platform. The Platform may contain links to other websites or services not operated or controlled by 9am  (the “Third-Party Sites”). The policies and procedures we describe here do not apply to the Third-Party Sites. The links from the Platform do not imply that 9am  endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Federal Privacy Notice

9am is required by US federal law to provide consumers with information regarding our collection and sharing of nonpublic personal information.

Former Customers

If your customer relationship with 9 am ends, we will not destroy your Information unless required or permitted by law. We will continue to treat your Personal Information in accordance with this Privacy Policy and applicable laws.

Changes to 9am Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes to this Privacy Policy we will notify you appropriately. By visiting and/or using the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect such information. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting 9am 

Please feel free to contact us if you have any questions about 9am’s Privacy Policy or our information practices: Email: