Legal & Privacy

Section 1

Privacy Policy

Three·Lens is operated by Navam Digital LLC ("Navam Digital", "we", "us", "our"). Navam Digital is the data controller for personal information collected through the Service. This policy explains what we collect, where it goes, and the choices you have. Questions: contact us at threelens@navamdigital.com.

Our approach: your work stays on your device

Three·Lens is built local-first. The personal research you create — your dossiers, notes, positions, and watchlists — lives in your browser, on your device, not in your account on our servers. Three things change that, and you control all three: turning on cloud backup stores a copy that is encrypted on your device and that we cannot read; sharing a dossier stores a readable snapshot of it (including any notes in it) on our servers until the share expires; and generating an analysis caches the resulting reading and the market and filing data behind it on our servers in a shared, de-identified form keyed by company — never tied to you. Each is described below.

What we store on our servers

• Your email address, and a hashed form of it used to look up your account.
• A one-time sign-in code, stored only in hashed form and only for the few minutes until it expires. Sign-in is passwordless — we never store a password, because there isn't one.
• Sign-in tokens that keep you logged in.
• Your plan and subscription status and per-account usage counters (how many scans this month, tutor questions, and so on) so we can apply plan limits.
• If you turn on cloud backup, a single encrypted backup file for your account. It is encrypted on your device before upload; we store only the ciphertext and hold no key, so we cannot read it. You can delete it at any time.
• If you create a share link, a frozen snapshot of that one dossier — including any notes in it — stored so the designated recipients you choose can open it. Access is gated to each recipient's verified email and the snapshot auto-deletes after a few days. Unlike a backup, this snapshot is not encrypted — we can read it in order to serve it to your recipients — so share only what you're comfortable storing with us for that window. Sample readings we publish for anyone to view are kept until we remove them.
• A shared cache of generated analysis and the market and filing data behind it — lens readings, prices, fundamentals, and filing summaries — keyed by company and filing (for example a ticker or an SEC accession number), shared across all users and not linked to your identity, and auto-expiring (from minutes for prices up to a few months for annual-filing summaries). It lets a company someone has already scanned re-read faster and at lower cost.

Data categories, legal basis, and retention

What stays only on your device

• The content of your dossiers, notes, positions, and watchlists. Two exceptions you control: turning on cloud backup keeps an encrypted copy (which we can't read) on our servers; and sharing a dossier stores a readable snapshot of that one dossier — including its notes — on our servers until the share expires. A shared snapshot never includes your positions or watchlists.

What we never have access to

• Your portfolio holdings, cost basis, and any profit-and-loss in readable form — we compute these on your device and never send them to our AI or market-data providers. The only copy that ever leaves your device is the encrypted backup you choose to turn on, which we hold only as ciphertext we can't decrypt.
• The readable content of your dossiers and notes — except a dossier you choose to share (whose snapshot, including its notes, we store readably until it expires) or a backup you turn on (which we hold only as ciphertext we can't decrypt). Outside those two choices you control, your dossier and note content stays on your device.
• Your backup password, and therefore the key needed to read a backup.

Encrypted cloud backup (optional)

By default, your work lives only on your device. You can turn on cloud backup, so a copy survives clearing your browser or moving to another device. When you do, your data is encrypted on your device, before it leaves, using a key derived from a backup password only you know (AES-GCM encryption with PBKDF2 key derivation). We store only the resulting encrypted file — one per account, on Amazon Web Services — and we cannot read it: we never receive your backup password or the unencrypted contents. You can turn backup off or delete the stored copy at any time. Because the encryption happens on your device, if you forget your backup password we cannot recover or reset your data.

How analysis is generated, and who sees it

When you run a scan, the company identifier and the research context we assemble are sent to our servers, which forward them to our AI provider to produce the analysis, and may query news and market-data providers. We don't keep a per-user log of these requests tied to your identity. We do cache the generated reading and the market and filing data that feed it on our servers — but only keyed by company and filing, shared across all users and never linked to you — so re-reading a company anyone has already scanned is faster and cheaper; these caches expire automatically.

Service providers and processors

We rely on a small set of trusted providers. The following processors may receive data:

Security measures and data breaches

We implement reasonable technical and organizational measures to protect your data, including encryption in transit and at rest and strict access controls. In the event of a data breach compromising your personal data, we will notify you and applicable regulators as required by law.

International data transfers

Navam Digital and its processors operate primarily in the United States. If you are located in the EEA, UK, or Switzerland, your data will be transferred to the US pursuant to Standard Contractual Clauses (SCCs) or other approved transfer mechanisms. Enterprise customers may request a Data Processing Agreement (DPA) by contacting us.

Analytics

Separately from the per-account counters we keep to apply your plan limits, we measure product usage with anonymous, aggregate counts only — an action name (such as "scan started") plus a country code derived at the network edge, summed into daily totals. These aggregate counts are not linked to your identity or account. We run no third-party analytics, no advertising, and no tracking pixels.

Cookies & browser storage

We use browser storage only for essential functions: keeping you signed in and remembering that you've seen our privacy notice. We don't use cookies at all, and no tracking or advertising technologies of any kind. Because there is no non-essential storage, there is nothing to "consent" to — the first-visit banner is a notice, not a consent gate.

Email

We use your email address to send sign-in codes and essential account notices. We do not send marketing email unless you ask us to.

Retention & deletion

• Your account record is kept while your account is active.
• Sign-in codes expire within minutes; share blobs auto-delete at expiry. Published sample readings are kept until we remove them.
• If you turn on cloud backup, your encrypted backup file is kept until you turn backup off, delete it, or delete your account.
• Deleting your account. You can delete your account yourself, at any time, from the Account page — no email required. To protect you, deletion asks you to type DELETE and confirm with a one-time code sent to your email. Free accounts are erased immediately. If you have a paid plan, you choose how it ends: delete now — your subscription is cancelled on the spot, you are not charged again, and everything is erased immediately, with no refund for the current period; or delete at the end of your billing period — you keep access until the period ends and can restore the account any time before then, after which it is erased automatically.
• What erasing removes. Erasing your account deletes your account record, your usage counters, any dossier snapshots you shared, your encrypted cloud backup, and any feedback or suggestions tied to your email. Data held only on your device is removed when you use the in-app delete or clear your browser.
• What we keep, and why. After erasure we retain a minimal internal record that an account was deleted, together with references to any past invoices, because we are required to keep certain transaction records for legal, tax, and accounting purposes. This record is limited to deletion, accounting, and invoice references. It is held separately from active account data, is not used to re-identify or contact you, and is retained for no longer than seven (7) years from the date of account deletion, consistent with applicable legal obligations. Billing and invoice records held by Stripe are retained under Stripe's policies and applicable law.

Your privacy rights

California residents (CCPA/CPRA). Under the CCPA/CPRA, California residents have the rights to know, delete, correct, and to non-discrimination. We do not sell or share your personal information as those terms are defined under the CCPA/CPRA. To exercise these rights, email threelens@navamdigital.com. We may need to verify your identity before fulfilling a request. You may also designate an authorized agent to submit requests on your behalf; we may require written authorization or proof of authority before acting on an agent's request.

EEA, UK, and Swiss residents (GDPR, UK GDPR, Swiss FADP). If you are located in the EEA, UK, or Switzerland, you have rights under the GDPR, UK GDPR, and Swiss FADP to access, rectify, erase, restrict, and object to processing, as well as the right to data portability and to lodge a complaint with a supervisory authority. We do not use personal information for solely automated decisions that produce legal or similarly significant effects (GDPR Article 22). To exercise these rights, email threelens@navamdigital.com. We may need to verify your identity before fulfilling a request.

EU/UK representative. Navam Digital is evaluating whether to designate a formal EU/UK representative under GDPR Article 27 and will update this policy if one is appointed. In the interim, please direct all privacy inquiries to threelens@navamdigital.com.

Canadian residents (PIPEDA). Canadian residents have rights under PIPEDA and applicable provincial privacy legislation, including the right to access and correct personal information and to withdraw consent. To exercise these rights, email threelens@navamdigital.com.

Children

Three·Lens is intended for adults and is not directed to anyone under 18. We do not knowingly collect personal information from children under 13 in violation of COPPA, or from anyone under 18. If you are a parent or guardian and believe your child under 18 has provided us with personal information, please contact us at threelens@navamdigital.com so we can delete it. See Eligibility.

Changes

If we update this policy, we will change the date above. For material changes, we will provide at least 30 days' advance notice by email to the address on file, in-app notification, or a prominent notice on our website. Your continued use of the Service after the effective date of any update constitutes your acceptance of the revised policy.

Contact and privacy requests

For privacy requests, questions about this policy, or to exercise your rights, contact us at threelens@navamdigital.com. We will respond to verifiable requests within 30 days. We may ask you to verify your identity before processing your request.

Section 2

Terms of Service

By clicking "I Agree," creating an Account, or otherwise accessing or using the Service, you agree to be bound by these Terms of Service ("Terms"), the Privacy Policy, and the Disclaimer. If you do not agree to these Terms, you must not access or use the Service.

Definitions

• "Account" means the user account created upon registration.
• "Backup" means the optional encrypted cloud backup feature.
• "Dossier" means a collection of research notes and annotations created by a user.
• "Lens Reading" means an AI-generated analytical summary of a public company.
• "Output" means any content generated by the platform, including Lens Readings and Tutor chat.
• "Plan" means the subscription tier selected by a user.
• "Service" means the Three·Lens web application and all related features.
• "Share Link" means a feature allowing a user to share a snapshot of a Dossier.
• "Tutor" means the AI-powered conversational feature.

Eligibility & age

You must be at least 18 years old to use the Service. By using the Service, you confirm that you are 18 or older. If you are under 18, you must not access or use the Service. Navam Digital reserves the right to terminate any Account upon discovery that the account holder does not meet the eligibility requirements.

What Three·Lens is

The Service is an educational and research workbench. It is not a broker, dealer, investment adviser, or financial institution, and it does not give advice or recommendations. The Disclaimer set forth in Section 3 is incorporated herein by reference and constitutes a binding part of this agreement.

Beta features

Navam Digital may offer experimental or beta features ("Beta Features"). Beta Features are provided "AS IS" without any warranties and may be modified or discontinued at any time without prior notice, to the extent permitted by law.

Your account

Sign-in is passwordless and tied to your email. You are responsible for maintaining the security and confidentiality of the email account associated with your Account. You must notify Navam Digital immediately upon becoming aware of any unauthorized access to or use of your Account. Navam Digital is not liable for any loss or damage arising from your failure to comply with this obligation. You are responsible for all activity under your Account.

Plans & billing

The Service is fully managed: we supply the AI, news, market-data, and filing capacity your Plan includes — there are no API keys to bring or configure. A free tier is available, alongside paid subscription tiers with higher monthly limits.

AUTO-RENEWAL DISCLOSURE: PAID PLANS AUTOMATICALLY RENEW AT THE END OF EACH BILLING PERIOD UNTIL YOU CANCEL. BY SUBSCRIBING TO A PAID PLAN, YOU AUTHORIZE NAVAM DIGITAL TO CHARGE YOUR PAYMENT METHOD ON A RECURRING MONTHLY BASIS AT THE THEN-CURRENT PRICE FOR YOUR PLAN. YOU MAY CANCEL ONLINE AT ANY TIME THROUGH YOUR ACCOUNT PAGE WITHOUT CONTACTING CUSTOMER SUPPORT. CANCELLATION DOES NOT ENTITLE YOU TO A REFUND FOR ANY PORTION OF THE CURRENT BILLING PERIOD. UPON CANCELLATION, YOUR ACCESS CONTINUES UNTIL THE END OF THE CURRENT BILLING PERIOD.

Paid Plans are billed monthly through our payment processor, Stripe; we don't store your full card details. By subscribing you authorize a recurring monthly charge at the then-current price for your Plan, which renews automatically until you cancel. You can cancel at any time, effective at the end of the current billing period, and your access continues until then. You will receive confirmation of cancellation via email or can verify your status in your account settings.

No refunds. All fees paid to Navam Digital are non-refundable. If you delete your Account before the end of your current billing period, you will not receive a refund for any unused portion of that period.

We set, change, and enforce reasonable usage limits for each Plan. Current limits and prices are shown where you choose or manage your Plan. We may change prices or Plan features prospectively with at least 30 days' advance notice by email or in-app notice. If you do not cancel before the effective date, your continued use constitutes acceptance of the new price. You are responsible for any applicable taxes.

Before completing a subscription purchase, Navam Digital will display a summary of the auto-renewal terms, cancellation method, and no-refund policy adjacent to the subscribe button.

Failed payments. If a recurring charge fails, Navam Digital may retry the charge, downgrade your Account to the free tier, suspend your access, or cancel your subscription until payment is successfully processed.

Acceptable use

You shall not:

• (a) use the Service for any unlawful purpose;
• (b) attempt to gain unauthorized access, reverse engineer, or disrupt the Service;
• (c) use automated means to scrape the Service;
• (d) redistribute Output for commercial purposes;
• (e) represent Output as professional financial advice;
• (f) use the Service to manipulate any securities market; or
• (g) upload or share any content that infringes third-party rights or is otherwise unlawful.

Intellectual property

The Service — its software, design, and original content — belongs to Navam Digital and its licensors. The notes and Dossiers you create are yours, and you are responsible for them — including any Dossier you choose to share and whom you share it with.

Share Link license. By sharing a Dossier through the Share Link feature, you grant Navam Digital a limited, non-exclusive, royalty-free license to store, reproduce, and serve that Dossier snapshot solely for the purpose of operating the Share Link feature for your designated recipients.

Feedback license

If you provide Navam Digital with any feedback, suggestions, or ideas regarding the Service, you grant Navam Digital a perpetual, irrevocable, worldwide, royalty-free license to use and incorporate such feedback into the Service without compensation to you.

Third-party data

Market data, fundamentals, and news come from third parties and may be inaccurate, incomplete, or delayed, and are subject to those providers' terms. Company names, logos, and trademarks are the property of their respective owners, and SEC filings and other source documents remain the property of their issuers. The Lens Readings Three·Lens produces are original educational summaries we create from publicly available information; we claim no ownership of, sponsorship by, or affiliation with the companies analyzed.

Warranty disclaimer

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, NAVAM DIGITAL EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

Navam Digital does not guarantee that the Service will be uninterrupted or error-free; third-party providers, AI tools, market data feeds, and hosting outages may affect availability.

Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW: (A) NAVAM DIGITAL SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOST DATA, LOSS OF GOODWILL, LOST BUSINESS OPPORTUNITY, BUSINESS INTERRUPTION, OR CORRUPTION OF DATA, ARISING OUT OF YOUR USE OF THE SERVICE; AND (B) NAVAM DIGITAL'S TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS SHALL NOT EXCEED THE GREATER OF THE TOTAL FEES PAID BY YOU IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM OR US $100. THESE LIMITATIONS REPRESENT YOUR SOLE AND EXCLUSIVE REMEDY.

Consumer law carveout. Nothing in these Terms limits liability that cannot be legally limited under applicable law, including liability for fraud or willful misconduct.

Indemnification

You agree to indemnify, defend, and hold harmless Navam Digital and its affiliates from and against any third-party claims, damages, losses, and expenses (including reasonable attorneys' fees) arising out of: (a) your use or misuse of the Service; (b) your violation of these Terms; (c) any content you share; or (d) your infringement of any third-party intellectual property or other rights. Navam Digital reserves the right to assume the exclusive defense and control of any matter subject to indemnification. You may not settle any claim without Navam Digital's prior written consent if such settlement imposes any obligation or admission of liability on Navam Digital.

Termination

You may stop using the Service and delete your Account at any time. Navam Digital may suspend or terminate your access to the Service immediately and without notice for: (a) material violation of these Terms; (b) fraud or abuse; (c) suspected security incidents; (d) excessive automated use; or (e) regulatory concerns.

Survival

Upon termination of your Account, the following provisions shall survive: Intellectual Property, Feedback License, Warranty Disclaimer, Limitation of Liability, Indemnification, Governing Law & Dispute Resolution, and General Provisions.

Governing law & dispute resolution

These Terms are governed by the laws of the State of California, without regard to its conflict-of-laws rules. Any dispute not resolved informally within 30 days shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules. The allocation of filing, administration, and arbitrator fees will be governed by the AAA rules.

YOU WAIVE ANY RIGHT TO A JURY TRIAL OR TO PARTICIPATE IN A CLASS ACTION.

You may opt out of this arbitration agreement within 30 days of accepting these Terms by emailing threelens@navamdigital.com. Either party may bring an individual action in small claims court or seek injunctive relief in a court of competent jurisdiction. If arbitration is unenforceable, disputes will be handled in the state or federal courts in Los Angeles County, California. This dispute resolution provision survives termination of your Account.

Changes to these Terms

We may update these Terms from time to time. We will provide at least 30 days' advance notice by email or in-app notice for material changes. We may make immediate updates for legal or security reasons. Continued use of the Service after an update constitutes acceptance. Changes will not apply retroactively to accrued claims.

General provisions

• Force majeure. Navam Digital shall not be liable for any failure or delay in performance due to causes beyond its reasonable control, including acts of God, natural disasters, war, terrorism, labor disputes, or internet service interruptions.
• Assignment. You may not assign these Terms without our prior written consent. Navam Digital may freely assign these Terms in connection with a merger, acquisition, or sale of assets.
• Severability & waiver. If any provision is found unenforceable, the remainder will remain in effect. Failure to enforce any right does not constitute a waiver.
• Entire agreement. These Terms constitute the entire agreement between you and Navam Digital.
• Electronic communications. You consent to receive legal, billing, and account notices electronically at the email address associated with your Account.
• Export control. You agree to comply with all applicable U.S. and international export control and trade sanctions laws, including OFAC regulations.

Section 3

Disclaimer

Investment disclaimer

Three·Lens exists to help you learn how investors read companies. It is for educational and informational purposes and personal, recreational use. It does not provide investment, financial, tax, or legal advice, and nothing in the app, your Dossiers, the teaching layer, or any chat is a recommendation to buy, sell, or hold any security.

Navam Digital is not a registered investment adviser and is not registered with the U.S. Securities and Exchange Commission (SEC), the Securities and Exchange Board of India (SEBI), or any other regulator. Using Three·Lens creates no advisory or fiduciary relationship. The Lens Readings, bull/bear cases, and any ratings are outputs of an analytical framework, not buy or sell signals.

You agree that you are not relying on the Service or Output as investment, financial, tax, legal, or professional advice. You assume all risk associated with investment decisions or educational use of the Output. Do your own research and consider consulting a licensed professional. All investing carries risk, including loss of principal, and past performance does not indicate future results.

AI disclosure

Parts of the Service are generated by AI language models. AI can make mistakes — Output may contain errors, omissions, or outdated information, and can sound confident while being wrong. AI models may also generate plausible-sounding but entirely fabricated information ("hallucinations"). No AI Output is reviewed by licensed financial professionals before being presented to you. You must independently verify any important information against primary sources before relying on it. To the fullest extent permitted by law, Navam Digital is not liable for AI-generated errors or for decisions made in reliance on AI Output, which is not professional advice.

Section 4

Accessibility

We want Three·Lens to be usable by as many people as possible, and we work in good faith toward the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.

In practice that means we aim for semantic structure, full keyboard navigation, visible focus indicators, text alternatives for meaningful images, and sufficient colour contrast in our palette. Accessibility is ongoing — we test and improve as we go, and we won't always be perfect.

If you run into a barrier, please tell us. We'll do our best to help and to fix the issue.

Section 5

Contact

Three·Lens is operated by Navam Digital LLC. For privacy requests, support, legal questions, or accessibility feedback, email us:

threelens@navamdigital.com

We're a small team and will respond as soon as we reasonably can.