Privacy notice

1. Information we collect

1.1 Information provided by you

When you open an account or use the Service, we may gather the following types of information:

• Identity information: your first name, last name and date of birth.
• Contact information: your email address, telephone number and home address.
• Financial information: Broker API credentials restricted to reading and execution, investment choices and risk settings. We do not retain complete broker passwords or entire card numbers.
• Account profile: your user identifier, selected strategies and alert preferences.
• Correspondence: messages sent through support channels or by email.

1.2 Information gathered automatically

Using the Service may automatically produce technical data, including:

• IP address, browser type and version, and operating system details.
• Pages visited, tools used, time on page and clickstream information.
• Device identifiers and, where relevant, mobile advertising identifiers.
• Cookie and tracking technology data (see our Cookie Policy).

1.3 Information supplied by third parties

Data may be provided by identity-check vendors, fraud-prevention services and analytics partners. We may compare it with existing information to strengthen accuracy and security.

2. How we use information

Collected information may be used to:

• Set up, administer and maintain your account and deliver the Service.
• Handle trading signals and automated orders through connected brokers.
• Tailor your experience and display relevant market information.
• Deliver service messages, including confirmations, trading updates and security notifications.
• Provide marketing messages where you consent or applicable law allows.
• Identify, examine and prevent fraud or unauthorised access.
• Meet applicable legal and regulatory responsibilities.
• Enhance, test and build Service functions with aggregated, anonymised information.

3. Legal grounds for EEA and UK individuals

For people located in the European Economic Area or the United Kingdom, we process personal information under the following legal grounds:

• Contract performance: to provide the Service you asked us to deliver.
• Legitimate interests: to secure the Service, prevent fraud and improve the product.
• Legal requirement: to meet financial and tax obligations.
• Consent: for marketing and optional cookies, which may be withdrawn at any time.

4. When information is shared

We do not sell personal information. We may disclose it to:

• Service providers: cloud, email, analytics and support vendors bound by contract to safeguard your information.
• Connected brokers and exchanges: only the API instructions necessary to carry out the strategy you selected.
• Public authorities: where legislation or a court order requires it, or where disclosure is needed to protect our legal interests.
• Business transactions: in connection with a merger, acquisition or asset transfer, provided the successor remains subject to this policy.

5. Transfers across borders

Harlow Alliance Resolution Inc. operates internationally. Your personal information may be transferred to and handled in countries beyond your place of residence, including the United States and European Union member states. Where applicable, international transfers use Standard Contractual Clauses adopted by the European Commission.

6. Keeping information

We keep personal information while your account remains open or for as long as needed to provide the Service. After closure, some records may be retained for up to seven years to meet financial and regulatory requirements. Aggregated, anonymised analytics may be retained without a fixed end date.

7. Your privacy choices

Subject to your location, you may have the right to:

• Request a copy of the personal data we hold about you.
• Ask us to fix information that is incorrect or incomplete.
• Request deletion of your information, where no legal exception applies (the “right to be forgotten”).
• Challenge certain uses of your information or ask us to limit the way it is processed.
• Data portability — receive your personal information in a structured, commonly used, machine-readable format.
• Withdraw consent whenever you choose; this will not affect processing that was lawful before withdrawal.

To exercise any of these rights, please contact us at [email protected]. We generally respond within 30 days.

8. Information security

Our controls include TLS 1.3 for data in transit, AES-256 for stored information, multi-factor authentication, role-based permissions and independent penetration testing each year. Absolute security cannot be promised. Use a strong, unique password and turn on two-factor authentication.

9. Cookies and related tools

Cookies and comparable technologies help us operate and enhance the Service. Further information is available in our Cookie Policy.

10. Privacy of children

The Service is intended for people aged 18 or older. We do not knowingly collect personal information from minors. If you think a minor has shared data with us, notify us so we can take reasonable steps to remove it promptly.

11. Updates to this policy

This Privacy Policy may be amended periodically. Material updates will appear online or be sent by email. Continuing to use the Service after an update takes effect means you accept the revised policy.

12. Contact information

For privacy questions or requests concerning your rights, please reach our Data Protection Officer:

• Email address: [email protected]
• Postal address: Harlow Alliance Resolution Inc. 200 Park Avenue, New York, NY 10166, United States, United States
• Representative in the EU: Harlow Alliance Resolution, 200 Park Avenue, New York, NY 10166, United States