Panoramix Privacy Statement

Simply put, your data is your data. We don’t sell it, trade it, market it, use it to sell other products to you or your clients, or expose it in ways not expressly permitted by you. Your data is stored in the United States unless your national regulations specifically and expressly require data storage inside and confined to the European Union.

United States federal statutes, specifically the Gramm Leach Bliley Act, require us to disclose certain information about our practices regarding the nonpublic personal information we obtain from you and about you in the ordinary course of business.

At Sapphire Software Services, Inc. (makers of Panoramix) your privacy is important to us. We are fully committed to protecting your privacy and earning your trust. First and foremost, our practices of collecting data begin with you. We do not collect your personal data, or the data of your clients, without your express permission to do so. Our practices of information gathering to provide you financial portfolio management and other services are:

1. Usual;
2. appropriate; and
3. an acceptable method for the purposes of providing business solutions.

In providing all services Sapphire collects material commonly called nonpublic personally identifiable Information, PII, which generally means data provided directly by you, your custodian, your carriers, data aggregators you’ve authorized us to access on your behalf, otherwise obtained by us, or that results from transactions with us. It does not include information publicly available.

We collect information about people, accounts, holdings, and transactions plus advisory-level data in support of the functions and functionality provided by the Panoramix product, a portfolio management platform for financial advisors. We collect the following categories of nonpublic personal information in the normal course of business:

1. Information we receive from you during the process of using our services;
2. Information about your transactions with us, our affiliates, or others; and
3. Information we receive from your custodian(s).

We may disclose any of the nonpublic personal information you share with us to affiliates, however, we will do so only to affiliates or to third parties with whom you have active business relationships, licenses, contracts, or other enforceable instruments and for which you have provided express integration and sharing permission. We are also subject to applicable law and law enforcement. This includes the following types of nonaffiliated entities:

1. Custodians;
2. Rebalancing solution partners;
3. Third-party CRM solutions;
4. Risk Assessment solution partners;
5. Client portal solution partners;
6. Form letter, mass mailing, promotional materials partners;
7. Direct-to-customer invoicing partners (for clients not paying from a custodial account)
8. Government agencies with regulatory or court-ordered approval to access data; and
9. Other third-party solution providers of your choosing.

You may also elect to export non-public personal information pertaining to your clients from Panoramix to either Microsoft Excel or CSV files using features of the software. Once this data is outside of Panoramix, you are fully responsible for its security, control, retention, and disposal.

Sapphire employees access customer’s and consumer’s nonpublic personal information only during their servicing of our products. We notify each employee of our strict employment policy against any employee accessing nonpublic personal information for any reasons other than to fulfill their job requirements or as permitted by law. All employees are also required to report to their supervisor any unauthorized use of customer’s and consumer’s nonpublic personal information of which any employee becomes aware, which initiates an investigation into the matter for appropriate disciplinary action, up to and including termination and referral to law enforcement as dictated by the circumstances.

Panoramix MCP Connector and AI Services

Last updated: September 17, 2026

The Panoramix Model Context Protocol (MCP) connector allows authorized Panoramix users to access Panoramix features and data through supported third-party artificial intelligence services, such as ChatGPT and Claude. Use of the connector is optional and requires the user to authorize the connection.

Information processed. When you use the connector, Sapphire may process your Panoramix user and account identifiers, authorization credentials, connector requests, tool usage, and the Panoramix data necessary to fulfill the actions you request. The information processed depends on the tools you choose to use and the permissions associated with your Panoramix account.

How information is used. We use this information to authenticate you, maintain the authorized connection, carry out your requested actions, provide and support the connector, troubleshoot errors, protect the security of Panoramix, prevent misuse, and comply with applicable legal obligations.

Sharing with AI services. Information is sent to a supported third-party AI service only when you authorize the connection and use that service to request a Panoramix action. The AI service’s handling of information is governed by its own terms, privacy policy, account settings, and any agreement between you or your organization and that service. You should not use the connector to disclose information through an AI service unless you are authorized to do so.

Authentication and credential storage. The connector uses OAuth authorization. Panoramix stores the authorization records needed to maintain the connection, including protected refresh-token information. Access tokens are short-lived. Connector refresh authorization records are retained for up to 90 days, unless the connection is renewed, revoked, or deleted sooner. Stored credentials are used only to authenticate connector requests and maintain the connection you authorized.

Operational logs and retention. We may retain connector operational and security logs for up to one year. These logs may include user and account identifiers, timestamps, tool names, request status, and diagnostic or error information. We use these logs for support, reliability, security monitoring, misuse prevention, auditing, and legal compliance.

Revocation and privacy requests. You may revoke the connector’s access through the connected AI service or by contacting Panoramix Support. To request assistance with disconnection, deletion of connector authorization records, or another privacy matter related to the connector, email support@panoramixfinancial.com. We may retain information when required by law, necessary to protect the service, or otherwise permitted under applicable agreements and policies.

California Consumer Privacy Act (CCPA)

CCPA places new obligations on organizations that collect personal information of California consumers for certain companies. Sapphire is not a qualifying company. If your firm is subject to CCPA and you have a client concerned about data privacy for data held within Panoramix, we will consult with you on the impact of the language of your own privacy policy on the use of the software provided by Sapphire.

Virginia Consumer Data Protection Act (VCDPA) and Similar State Statutes

Virginia residents have specific rights under the VCDPA related to the collection, use, and disclosure of their personal information. Panoramix contains the tools necessary for the advisor to comply with the statue. Sapphire expects the advisor and client to work together to review, edit, delete, and opt-out in accordance with the VCDPA. Any opt-out implementation may adversely affect the ability of the advisor to service the client and comply with other applicable laws based on the data in Panoramix alone. The performance and reporting/billing accuracy of Panoramix could be negatively impacted, depending on the nature of the opt-out. Likewise, the advisor’s ability to comply with other federal and state requirements, such as Annual ADV Amendment filing, Schedule 13F reporting, for examples, may be affected if the data is not fully housed in Panoramix. The advisor and the client need to work together to balance the client’s data privacy desires and the advisor’s ability to be of service and to comply with other legal requirements.