Privacy statement

1. Data we collect

1.1 Details you submit

When you register or use the Service, we may gather the following types of information:

• Personal identity: your first name, surname and date of birth.
• Contact information: your email address, telephone number and home address.
• Financial information: Broker API credentials restricted to reading and placing orders, together with your investment preferences and risk settings. We do not retain complete broker passwords or card payment numbers.
• Account profile: your username, strategy configuration and alert preferences.
• Correspondence: messages you send through support channels or email.

1.2 Data collected automatically

Using the Service results in the automatic collection of certain technical data:

• IP address, browser name and version, plus operating system.
• Pages viewed, functions used, time on the platform and clickstream information.
• Device identifiers and, where relevant, mobile advertising identifiers.
• Cookie and tracking technology data (see our Cookie Policy).

1.3 Data from other organisations

We may receive information from identity-check providers, anti-fraud services and analytics partners. It may be combined with data we already hold to improve reliability and safeguard the Service.

2. How we use data

Collected information may be used to:

• Set up, administer and deliver your account and the Service.
• Handle trading signals and automated orders through connected brokers.
• Tailor your experience and show suitable market information.
• Provide service messages, including confirmations, trading updates and security notifications.
• Send promotional messages where you have opted in or the law allows it.
• Identify, examine and prevent fraud or illegal activity.
• Meet legal and regulatory responsibilities.
• Build, evaluate and enhance the Service using aggregated, anonymised information.

3. Lawful grounds for processing (EEA and UK users)

For people located in the European Economic Area or the United Kingdom, personal data is processed on these lawful grounds:

• Contract performance: to deliver the Service requested when you create an account.
• Legitimate interests: to prevent fraud, secure the platform and improve the product.
• Legal requirement: to satisfy financial-law and tax obligations.
• Consent: for marketing and optional cookies, which you can withdraw at any time.

4. When information is shared

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

• Service providers: cloud hosting, email, analytics and support providers bound by contract to keep your information secure.
• Connected brokers and exchanges: only the API directions needed to carry out the strategy you have set.
• Public authorities: where required by law or court order, or where necessary to protect our legal rights.
• Business changes: as part of a merger, acquisition or asset transfer, provided the recipient remains subject to this policy.

5. Transfers outside the country

National Financial Inclusion Programme Inc. provides services in international markets. Your information may be processed or transferred outside your country of residence, including to the United States and EU Member States. Where necessary, we rely on Standard Contractual Clauses adopted by the European Commission for international transfers.

6. Keeping data

We keep personal information for as long as your account remains open, or for the period needed to deliver the Service. Once the account is closed, some records may be retained for up to seven years to meet financial compliance requirements. Aggregated, anonymised data may be stored without a time limit.

7. Rights relating to your data

Subject to your location and the applicable legislation, you may be entitled to:

• Obtain a copy of the personal data we hold about you.
• Request corrections to information that is incomplete or incorrect.
• Request deletion of your personal data, sometimes referred to as the “right to be forgotten”.
• Object to particular processing or ask us to limit how it is carried out.
• Request your information in a structured, machine-readable form.
• Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise a data right, please get in touch via [email protected]. We generally reply within 30 days.

8. Keeping information secure

Our safeguards include TLS 1.3 for data in transit, AES-256 for stored data, multi-factor authentication, role-based permissions and yearly independent penetration testing. No system can provide absolute security. Use a strong, unique password and turn on two-factor authentication.

9. Cookies and related technologies

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

10. Privacy for children

The Service is intended for people aged 18 or over. We do not knowingly gather personal data from children. If you think a child has provided information to us, tell us so that we can remove it promptly.

11. Updates to this policy

This Privacy Policy may be amended periodically. Significant changes will be posted on the website or communicated by email. Continuing to use the Service after an updated version takes effect means you accept the revised terms.

12. How to contact us

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

• Email address: [email protected]
• Registered postal address: National Financial Inclusion Programme Inc 200 Park Avenue, New York, NY 10166, United States, United States
• Representative in the EU: National Financial Inclusion Programme, 200 Park Avenue, New York, NY 10166, United States