Terms, Privacy & Disclaimers.

1. Financial Services Disclaimer

Regulatory Status

PortWorth Group (ABN 64 870 145 318) is not a licensed financial adviser, stockbroker, securities dealer, credit provider, or insurance broker. PortWorth does not hold an Australian Financial Services Licence (AFSL) issued by the Australian Securities and Investments Commission (ASIC) under Part 7.6 of the Corporations Act 2001 (Cth), and is not authorised to carry on a financial services business as defined in section 911A of that Act.

PortWorth is a portfolio tracking, data aggregation, and reporting tool. It does not provide, and is not licensed to provide, any regulated financial service including but not limited to: financial product advice (whether general or personal), dealing in financial products, making a market for financial products, or operating a managed investment scheme.

Not Financial Advice

All content, analysis, data, AI-generated insights, analyst consensus information, price targets, property valuations, superannuation projections, scenario modelling, and any other information provided through PortWorth are of a general informational nature only and do not constitute:

• Financial product advice (whether general or personal) as defined in section 766B of the Corporations Act 2001 (Cth)
• A recommendation, opinion, or guidance intended to influence you in making a decision about a particular financial product or class of financial products
• A recommendation to buy, sell, hold, or otherwise deal in any security, financial product, cryptocurrency, real property, or other asset
• An offer or solicitation to buy or sell any financial product
• Tax advice, legal advice, credit advice, or insurance advice
• A securities recommendation within the meaning of any applicable law

Nothing on this platform should be interpreted as a signal, suggestion, or endorsement that any particular investment action is appropriate for any person. The platform displays data — it does not tell you what to do with that data.

No Fiduciary or Advisory Relationship

Your use of PortWorth does not create a fiduciary relationship, advisory relationship, financial planning relationship, or any other professional relationship between you and PortWorth Group, and its employees and contractors. PortWorth owes you no duty of care, duty of loyalty, or fiduciary duty in connection with the information displayed on the platform or any investment decision you make.

PortWorth does not know your personal financial situation, investment objectives, risk tolerance, or specific needs. No content on this platform has been tailored to your individual circumstances.

No Liability for Investment Decisions

You acknowledge and agree that any investment, trading, or financial decisions you make are entirely your own and are made at your sole risk and discretion. PortWorth Group, and its employees and contractors, accept no liability whatsoever for any loss, damage, cost, or expense (whether direct, indirect, consequential, incidental, special, or punitive) arising directly or indirectly from:

• Your use of or reliance on any information, data, analysis, or content provided through the platform
• Any investment, trading, or financial decision you make based on information obtained from the platform
• Any inaccuracy, error, omission, delay, or interruption in data, prices, or analysis
• Any AI-generated content, scenario analysis, or portfolio observation
• Any third-party analyst consensus rating, price target, or broker opinion displayed on the platform
• Any property valuation estimate or superannuation projection

Assumption of Risk & Indemnification

By using PortWorth, you expressly assume all risks associated with your use of the platform and any reliance on its content. You acknowledge that investing in securities, property, cryptocurrency, and other assets involves substantial risk, including the risk of total loss of capital.

You agree to indemnify and hold harmless PortWorth Group, and its employees and contractors, from and against any claims, liabilities, damages, losses, costs, and expenses (including legal fees on a full indemnity basis) arising out of or in connection with your use of the platform, your reliance on any information provided through the platform, or any breach of these terms.

Professional Advice Required

Before making any investment, financial, taxation, legal, or superannuation decision, you must seek independent professional advice from an appropriately licensed and qualified adviser who holds an AFSL (or is an authorised representative of an AFSL holder) and who can take into account your personal financial situation, objectives, and needs. Past performance is not indicative of future results.

AI-Generated Content

PortWorth uses artificial intelligence (Claude by Anthropic) to generate scenario analyses, portfolio observations, market intelligence briefings, and research-style reports. You acknowledge and agree that all AI-generated content is informational only and:

• Does not constitute a recommendation to buy, sell, or hold any financial product, security, or asset
• Does not constitute personal or general financial product advice within the meaning of the Corporations Act 2001 (Cth)
• May contain factual inaccuracies, outdated information, or errors — AI outputs should always be independently verified before reliance
• Is generated by a third-party AI model; PortWorth does not guarantee its accuracy, completeness, or reliability
• Should never be relied upon as the sole or primary basis for any investment or financial decision

Analyst consensus ratings, price targets, and broker opinions are sourced from third-party data providers and are presented as third-party data only, not as PortWorth's own analysis or endorsements.

Property valuation estimates are AI-generated approximations based on publicly available data and are not formal property valuations conducted by a licensed valuer. They should not be relied upon for any property transaction, mortgage, or legal purpose.

Data Accuracy & Third-Party Sources

PortWorth makes no representation or warranty as to the accuracy, completeness, timeliness, or reliability of any data, prices, or projections. All information is provided on an "as is" and "as available" basis. Market data is sourced from Yahoo Finance, Twelve Data, CoinGecko, Finnhub, and Domain Group. Such data may be delayed, inaccurate, or unavailable and PortWorth is not responsible for errors or omissions by third-party data providers.

Business Identity

PortWorth Group (ABN 64 870 145 318) is the registered business name of a sole trader based on the Gold Coast, Queensland. PortWorth is not affiliated with, endorsed by, or associated with any other entity using the name "Emery Capital" or any similar name in any jurisdiction worldwide.

2. Terms & Conditions

Agreement

By accessing or using PortWorth ("the Platform", "the Service"), you agree to be bound by these Terms & Conditions. If you do not agree, do not use the Platform.

Eligibility

You must be at least 18 years of age and a resident of Australia to use PortWorth. By using the Platform you represent and warrant that you meet these requirements.

Your Account

• You are responsible for maintaining the confidentiality of your login credentials.
• You must not share your account with any other person.
• You must notify us immediately if you suspect unauthorised access to your account.
• We reserve the right to suspend or terminate accounts that breach these terms.
• You are responsible for ensuring that all information you enter into the Platform is accurate.

Acceptable Use

You agree not to use the Platform to:

• Violate any applicable law or regulation
• Attempt to gain unauthorised access to any part of the Platform or other users' data
• Transmit malicious code, viruses, or harmful data
• Reverse engineer or copy any part of the Platform
• Use automated tools to scrape or extract data
• Impersonate any person or entity or misrepresent your affiliation with any person or entity

Subscription & Payment

• Subscriptions are billed monthly or as agreed in your service plan.
• All prices are in Australian dollars (AUD) and inclusive of GST where applicable.
• Invoices are issued by PortWorth Group (ABN 64 870 145 318).
• Payment is due within 14 days of invoice unless otherwise agreed.
• Accepted payment methods: bank transfer (EFT) or as otherwise agreed.
• You may cancel your subscription at any time with 30 days' written notice. No refunds are provided for partial billing periods.
• We reserve the right to modify pricing with 30 days' written notice.
• Late payments may result in suspension of access until the account is brought current.

Service Plans

PortWorth offers the following service tiers:

• Starter — Portfolio tracking, live prices, and core reporting ($19/month).
• Essential — Everything in Starter plus extended analytics and additional asset classes ($49/month).
• Professional — Everything in Essential plus AI analysis, property valuations, analyst targets, IBKR integration, and priority support ($99/month).
• Private Office — Custom pricing for multi-entity, SMSF, trust, or family office structures. Contact us for details.

Feature availability is determined by your plan tier and may be adjusted by your account administrator. Plan details and current pricing are confirmed during onboarding and in your service agreement.

Intellectual Property

All content, design, software, and materials on the Platform are the intellectual property of PortWorth Group or its licensors. You may not copy, reproduce, or distribute any part of the Platform without prior written permission.

Service Availability

We endeavour to maintain high availability but do not warrant uninterrupted access. The Platform may be unavailable for scheduled maintenance, updates, or due to circumstances beyond our control including third-party service outages. We are not liable for any loss arising from Platform unavailability.

Disclaimer of Warranties

The Platform and all information, data, content, and services provided through it are provided on an "as is" and "as available" basis without warranties of any kind, whether express, implied, or statutory, including but not limited to implied warranties of merchantability, fitness for a particular purpose, accuracy, and non-infringement.

Limitation of Liability

To the maximum extent permitted by the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010 (Cth)) and all other applicable law:

• PortWorth's total aggregate liability to you for any and all claims shall not exceed the total subscription fees actually paid by you in the three (3) months immediately preceding the event giving rise to the claim.
• In no event shall PortWorth be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, loss of data, loss of opportunity, or investment losses.
• PortWorth is not liable for any loss arising from your reliance on any information, data, AI-generated content, analyst data, or valuations displayed on the Platform.

Nothing in these terms excludes, restricts, or modifies any consumer guarantee, right, or remedy conferred on you by the Australian Consumer Law that cannot be excluded by agreement.

Governing Law & Jurisdiction

These terms are governed by and construed in accordance with the laws of Queensland, Australia. Any disputes arising out of or in connection with these terms shall be subject to the exclusive jurisdiction of the courts of Queensland.

Severability

If any provision of these terms is found to be invalid or unenforceable, that provision shall be severed and the remaining provisions shall continue in full force and effect.

Amendments

We may update these Terms at any time. Continued use of the Platform after changes constitutes acceptance of the revised Terms. Material changes will be notified by email with at least 14 days' notice. The "Last updated" date at the top of this page will be revised accordingly.

3. Privacy Policy

This Privacy Policy describes how PortWorth Group ("we", "us", "our") collects, uses, stores, and discloses your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We are bound by the APPs as an APP entity that handles personal information in the course of providing our services.

What Personal Information We Collect

We collect and hold the following categories of personal information:

• Identity & account information: Your name and email address, collected when your account is created by an administrator.
• Authentication data: A hashed, salted version of your password (PBKDF2-SHA256, 200,000 iterations). Your actual password is never stored or transmitted in plain text. If you use two-factor authentication (TOTP or passkey/WebAuthn), the associated credential data is stored securely.
• Financial portfolio data: Investment holdings, property details, superannuation balances, cash accounts, loan balances, and trade history that you or your administrator choose to enter into the platform. This constitutes sensitive financial information.
• Third-party linked account data: Where you connect Open Banking accounts, transactional data (account balances, transaction history) provided by your bank via the Consumer Data Right framework or authorised data intermediary.
• Usage and audit data: Login times, features accessed, portfolio change history (audit trail, last 500 entries per user), and client-side error logs used for debugging and platform improvement.
• Communications: Enquiries and correspondence you send to us via the contact form or email.

Sensitive Information

Financial information about an individual is sensitive information under the Privacy Act. We handle your financial portfolio data with heightened care: it is stored encrypted in transit (TLS 1.2+), access is strictly controlled by authentication and per-user data isolation, and it is never shared with other clients or used for any purpose other than providing your dashboard.

How We Collect Personal Information

• Directly from you — when you log in, enter portfolio data, submit enquiries, or connect bank accounts.
• From your administrator — when your account is created and configured on your behalf.
• From third-party data providers — market prices, property data, and company news are fetched automatically from external APIs to populate your dashboard. These providers do not receive your personal information.
• From your bank (if Open Banking is enabled) — via an authorised CDR data intermediary, with your explicit consent.

Purpose of Collection & Use

We use your personal information only for the following purposes:

• To create and manage your account and authenticate your identity
• To provide and display your personalised portfolio dashboard
• To generate AI-assisted portfolio summaries and intelligence reports (see AI Processing below)
• To send transactional emails: password resets, account notifications, and scheduled intelligence reports you have opted into
• To maintain an audit trail of portfolio changes for your own records
• To respond to your enquiries and provide client support
• To detect and prevent fraudulent or unauthorised access
• To comply with our legal obligations
• To improve the reliability and performance of the platform (via anonymised error logs)

We will not use your personal information for any purpose that is incompatible with the above without your consent.

AI Processing of Portfolio Data

When you use the AI analysis or intelligence report features, a summary of your portfolio holdings (ticker symbols, position sizes, and performance data) is sent to Anthropic's Claude API to generate the analysis. We take the following precautions:

• We do not send your name, email address, or other directly identifying information to Anthropic.
• We do not send bank account numbers, tax file numbers, or login credentials to Anthropic.
• Anthropic processes this data under their API terms of service and privacy policy. Data submitted via the API is not used to train Anthropic's models.
• AI features are opt-in — you can use the platform without using any AI features.

Data Storage & Security

Your data is stored in Upstash Redis hosted in the Sydney, Australia region. We implement the following security controls:

• All data in transit is encrypted using TLS 1.2 or higher.
• Passwords are hashed using PBKDF2-SHA256 with 200,000 iterations and a unique salt per user. Your actual password is never stored.
• Sessions are managed via HMAC-SHA256 signed JSON Web Tokens (JWTs). Tokens are invalidated immediately on logout and cannot be reused.
• Two-factor authentication (TOTP authenticator app) and passkeys (WebAuthn / Face ID / Touch ID) are available and recommended.
• Strict per-user data isolation is enforced at the application and database layers. No user can access another user's data.
• All API endpoints require authenticated JWT Bearer tokens. Unauthenticated requests are rejected.
• Client-side JavaScript errors are logged to Sentry for debugging purposes. Error reports contain technical stack trace data only, not financial portfolio content.

Your Rights Under the Privacy Act

Under the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the following rights:

• Access (APP 12): You may request access to the personal information we hold about you. We will respond within 30 days. We may charge a reasonable fee for providing access in complex cases.
• Correction (APP 13): If you believe personal information we hold is inaccurate, incomplete, or out of date, you may request correction. We will respond within 30 days.
• Deletion: You may request deletion of your account and all associated personal information. We will action this within 30 days, subject to any legal retention obligations.
• Anonymity (APP 2): Where lawful and practicable, you may interact with us anonymously or using a pseudonym. Note that using the platform itself requires an account.
• Complaint: If you believe we have breached the APPs, you may make a complaint to us (see Section 7). If unsatisfied with our response, you may escalate to the Office of the Australian Information Commissioner (OAIC).
• Opt-out of communications: You may opt out of non-essential email communications (intelligence reports, alerts) via the Settings → Notifications panel at any time.

To exercise any of these rights, contact us at angus@portworth.com.au.

Data Retention

We retain your personal information for as long as your account is active and for a period of 7 years after account closure, unless a shorter period is required by law or you request earlier deletion. Financial records may be subject to statutory retention obligations under Australian taxation law. Audit trail entries are automatically capped at the 500 most recent entries per user on a rolling basis.

Cross-Border Disclosure

Some of our infrastructure providers are located or operate servers outside Australia (see Section 4). Before disclosing personal information to overseas recipients, we take reasonable steps to ensure those recipients do not breach the Australian Privacy Principles in relation to that information, including by only engaging providers with appropriate data processing agreements, certifications, and privacy frameworks. By using the Platform you acknowledge and consent to these cross-border disclosures where necessary for service delivery.

What We Do Not Do

• We do not sell your personal information to any third party.
• We do not use your data for advertising, profiling, or marketing purposes.
• We do not share your financial data with other clients of the Platform.
• We do not store your brokerage login credentials or bank account passwords.
• We do not use third-party advertising trackers, analytics pixels, or behavioural tracking tools.

Children

PortWorth is not intended for persons under 18 years of age. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

4. Third-Party Data Processors

We engage the following third-party service providers in the course of operating the Platform. Each is engaged under a data processing agreement or equivalent contractual terms. Personal data is shared with these providers only to the minimum extent necessary for the specified purpose.

Provider	Purpose	Location	Personal data shared
Vercel Inc.	Platform hosting & serverless functions	USA (AWS us-east-1)	All requests pass through Vercel infrastructure. Vercel processes request metadata (IP, headers) in the normal course of serving the application.
Upstash	Database storage (Redis)	Australia (Sydney region)	All user data, portfolio data, authentication credentials (hashed), session tokens, and configuration data.
Anthropic PBC	AI analysis (Claude API)	USA	Anonymised portfolio summaries (ticker symbols, position values). No name, email, or account credentials. API data is not used for model training.
Resend	Transactional email delivery	USA	Your name and email address, and the content of emails sent to you (password resets, alerts, reports).
Sentry	Error monitoring & debugging	USA	JavaScript error stack traces and browser metadata. No financial portfolio data or credentials are included in error reports.
Google LLC	OAuth sign-in (optional)	USA	If you choose to sign in with Google, we receive your Google account email address and a unique identifier. No other Google data is accessed.
Apple Inc.	Sign in with Apple (optional)	USA	If you choose to sign in with Apple, we receive an Apple-issued identifier and optionally your email address. No other Apple data is accessed.
Yahoo Finance / Twelve Data / CoinGecko / Finnhub / Domain	Market data & property prices	USA / Global	No personal data is shared. These providers receive ticker symbol queries only.
CDR Data Intermediary (if Open Banking enabled)	Open Banking — bank account aggregation	Australia	Your bank account information and transaction data, processed under your explicit CDR consent. The intermediary is an ACCC-accredited CDR data recipient.

5. Cookie & Storage Policy

PortWorth uses a minimal set of browser storage mechanisms. We do not use advertising cookies or third-party tracking technologies.

Session Storage (cleared when browser tab closes)

• Authentication token — your signed JWT session token, used to authenticate API requests. Automatically cleared when you close your browser tab or explicitly log out.

Local Storage (persists across sessions)

• Theme preference — your chosen display theme (Dark/Light). No personal information.
• Onboarding state — whether you have completed the onboarding tour. No personal information.
• Cookie consent acknowledgement — records that you have viewed this notice.
• UI preferences — tab state, chart preferences, and similar interface settings. No personal information.

What We Do Not Use

• No advertising cookies or tracking pixels.
• No Google Analytics, Facebook Pixel, or any third-party behavioural analytics.
• No fingerprinting or cross-site tracking technologies.

Service Worker

The Platform uses a service worker for offline capability and performance optimisation (PWA). The service worker caches application assets (HTML, scripts, styles) locally on your device. It does not cache your financial data or authentication tokens. You can clear the service worker cache by clearing your browser's site data.

6. Data Breach Response

PortWorth takes data security seriously and maintains a data breach response procedure in accordance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth).

What Constitutes a Notifiable Breach

A data breach is notifiable when it is likely to result in serious harm to one or more individuals whose information is involved. This includes unauthorised access to, disclosure of, or loss of personal information where serious harm is likely.

Our Response Obligations

• Upon becoming aware of a suspected data breach, we will conduct a prompt assessment (within 30 days) to determine whether it is an eligible data breach.
• If we determine that a notifiable data breach has occurred, we will notify the Office of the Australian Information Commissioner (OAIC) and all affected individuals as soon as practicable.
• Notification will include: a description of the breach, the kinds of information involved, what steps we have taken in response, and what steps affected individuals can take.
• In the case of a breach involving financial credentials or portfolio data, we will immediately revoke all active sessions for affected accounts.

Reporting a Security Issue

If you discover a security vulnerability in the Platform, please report it responsibly to angus@portworth.com.au. We will acknowledge receipt within 2 business days and aim to remediate critical issues within 14 days.

7. Contact & Complaints

For privacy enquiries, data access or deletion requests, security reports, billing questions, or complaints:

• Email: angus@portworth.com.au
• Business: PortWorth Group
• ABN: 64 870 145 318
• Structure: Registered business name of a sole trader (Angus Emery)
• Location: Gold Coast, Queensland, Australia

Privacy Complaints

If you have a complaint about how we have handled your personal information, please contact us in the first instance. We will respond to privacy complaints within 30 days. If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):

• Website: oaic.gov.au
• Phone: 1300 363 992
• GPO Box 5218, Sydney NSW 2001

Response Timeframes

• General enquiries: 2 business days
• Privacy access / correction requests: 30 days
• Account deletion requests: 30 days
• Privacy complaints: 30 days (initial response)
• Security vulnerability reports: 2 business days (acknowledgement)