Privacy
Version 1.0. Last updated 2 August 2026.
Written to be read by whoever at your firm has to approve a vendor, so it says what the software does rather than what the law lets us get away with saying.
Who we are
Trueband is software for registered investment advisers. It watches portfolio drift and prepares client outreach for an advisor to review before anything is sent. For anything below, including a request to see or delete what we hold, write to hello@trueband.app.
Two relationships, and they work differently
When you browse this website, we decide what happens with the small amount of data that involves, which makes us the controller of it.
When your firm connects its Orion account, everything after that is your clients' data, processed on your firm's instructions. Your firm is the controller and we are the processor. The data processing terms govern that relationship; what follows here summarises it.
The website
We set no cookies of any kind. There is no analytics product, no advertising pixel and no third-party tracker on any page. Open your browser's network tab and check rather than taking our word for it.
Two things still involve someone else. Cloudflare serves the site and keeps standard request logs, including IP addresses, for a short period for security and abuse handling. Typefaces come from Google Fonts, so your browser requests them from Google and Google sees your IP address. That is the only outbound request these pages make, and we intend to remove it by serving the fonts ourselves.
If you email us we keep the message, so we can reply and so there is a record of what was agreed. We will not add you to a mailing list.
The application
No firm is connected today, so the only client-shaped data on this site is fictional and lives in the demo. Once a firm connects, this applies.
Trueband reads household and account records, holdings and account performance from Orion, and portfolios, assigned models, target weights and tolerance bands from Eclipse. It computes one drift record per household and stores that record. Where an advisor records a video we store the video and a still frame from it. Where an advisor edits the draft email we store that text, so it survives a page reload.
Household names are part of that, as is a client email address where your firm already holds one in Orion. We hold no account numbers, no tax identifiers, no dates of birth, no transaction history and nothing in a special category under GDPR.
Why we process it, and on what basis
For the website, our basis is legitimate interest: running a site securely and replying to people who write to us. Inside the application we act on your firm's documented instructions as its processor, and your firm determines the lawful basis for its own clients' data.
Client videos
A client who watches a video from their advisor has no account with us and we do not create one. The page is reachable only through an unguessable link in the email their own advisor sent, and it shows the video and nothing about the portfolio. We do not track whether it was opened.
Who else touches it
Cloudflare provides the compute, the stored drift records, the video storage and the access control. It is our only sub-processor.
Two other parties appear and neither is a sub-processor of ours, which is worth being precise about. Microsoft receives the draft email, but that draft is created inside your firm's own Microsoft 365 tenant under your own agreement with Microsoft. Orion and Eclipse are your firm's existing systems, read with credentials your firm supplies and can revoke without talking to us.
We do not sell personal data and we do not share it for cross-context behavioural advertising, as those terms are used in California law. We never have, and the product has no mechanism that would allow it.
Where it is processed
On Cloudflare's network. Drift records live in Workers KV, which is globally replicated, so a record may be stored in Cloudflare data centres outside the United States. If your firm needs processing pinned to one region, raise it before signing, because today we cannot promise it.
How long we keep it
Drift records are overwritten on each sync and expire if syncing stops. Videos and saved draft text persist until your firm asks us to remove them. Email you send us is kept while the conversation is useful and then deleted.
Configurable retention is designed and not yet built. That matters more to a compliance officer than to anyone else, which is why it is here rather than left to be discovered.
Security
The application sits behind Cloudflare Access with your identity provider in front of it, and it re-checks the signed identity on every request against an allowlist your firm controls. Data is encrypted in transit and at rest by the underlying Cloudflare services. The security page sets out what we have not done yet, including the absence of a SOC 2 report and of an independent penetration test.
Your rights
If you are a client of a firm that uses Trueband, your relationship is with that firm. Ask them. They can ask us, and we will answer them promptly.
If you are a firm, or you have emailed us directly, write to hello@trueband.app and we will tell you what we hold, correct it, export it or delete it. Depending on where you live you may have rights of access, correction, deletion and portability, rights to object to or restrict processing, and a right to complain to your data protection authority. Asking costs nothing and will not make the service worse for you.
Children
Trueband is sold to advisory firms and is not directed at children. We do not knowingly process the data of anyone under 16, except where a household record from your firm's own system happens to include a minor beneficiary.
Changes
When this changes materially we will update the version and the date above, and tell connected firms directly rather than relying on anyone to notice.
See it on fictional households first.
No signup, no call, nothing sends. It runs on fictional households and the buttons in it do not reach a mailbox. Questions it does not answer go to hello@trueband.app.