Reflekt.Trade - Privacy Notice

1. Personal Data We Collect

Contact Information. In order to use our Service, you will be required to register an account and provide us with certain Personal Data, such as your E-mail address, name and nickname.

Wallet Information. You may alternatively register for, or access, your account by connecting a supported digital wallet. In that case, we collect your public wallet address. Registration and authentication are facilitated by a third-party authentication provider, as described below.

Transaction Information. We reserve the right to charge fees for the use of the Service. If we introduce any fees, payments you make will be processed by a third-party payment processor and your financial data (e.g., your credit card or bank account details) will not be collected by us.

Exchange Information. To continue with the onboarding process and provide you with the Service, you will be required to disclose your Exchange Account API keys and API secrets.

Trading Data. To provide you with the Service, we will access, store, retain and use financial data originating from your Exchange Account. This includes open trading positions, trade history, profit-loss records, and account balance (collectively, "Trading Data").

Technical Information. When you use the Platform, we may automatically gather certain information about your computer or mobile device, such as your operating system, your IP address, device ID, browser type, and subject to your consent as may be required under applicable law, geo-location, as well as your browsing history and any information regarding your use and interaction with the Platform and Service. This includes session recording technology, which captures your interactions with the Platform, such as pages viewed, clicks and navigation paths. Text content, form inputs and network request contents are masked and are not recorded.

Communication Information. We also collect Personal Data when you use the Platform or webpage, request information from us, update your profile, send us an inquiry through our contact information, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.

You are under no legal obligation to provide us with any such Personal Data. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information, we may not be able to register you on the Platform or provide you with certain services. Your approval for the collection and use of Personal Data is based on your consent pursuant to the performance of the contract as detailed in the Terms and this Privacy Notice.

2. How We Use Your Personal Data

General. We use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Service, including the AI Features; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct an analysis to improve our current products and services; (4) to contact you with informational newsletters and promotional/marketing materials relating to our Platform and services; (5) to review the usage and operations of our Platform; (6) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (7) to prevent fraud and protect the security of our Platform and Service, and address any problems with the Platform or Service and (8) to provide you with customer support.

Statistical Information and Analytics. We use analytics tools, including Google Analytics and PostHog, to collect and analyze information about the use of the Service, such as how often users visit the Platform or website, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Platform or website. Our PostHog instance is hosted in the European Union. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users. This helps us improve our Service by allowing us to identify new trends and customer needs, which in turn allows us to consider new products and services or tailor existing products and services accordingly. The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we determine in our sole discretion. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

3. Artificial Intelligence

We process certain Personal Data and your Trading Data using artificial intelligence algorithms to provide the Service (including the AI Features), improve our Service, and develop new products and services.

4. Sharing the Personal Data We Collect

We share your information, including Personal Data, as follows:

Affiliates. We share information, including your Personal Data, with our affiliated companies where this is necessary to provide you with our products and Service, and for business management purposes.

Platform Users. Your nickname and trading performance statistics are displayed to other Platform participants through the leaderboard by default. Other users may view additional Personal Data made available on your profile only where you have chosen to make your Platform profile public. You may adjust your profile visibility, or withdraw from the leaderboard, through your account settings.

Service Providers and Subcontractors. Below is a list of the types of service providers we use, the service each provides and the data types shared with each:

Generative AI Service Providers. We use certain generative AI service providers in order to provide you with the Services, specifically Anthropic, and will share data, including Personal Data and Trading Data, with them for that purpose. This data will be processed in accordance with their terms, and you acknowledge that it may be used for the improvement of their own services and models.

Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue to be subject to the provisions of this Privacy Notice.

Law Enforcement Related Disclosure. We may share your Personal Data with third-parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third-party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation, such as Know Your Customer (KYC); or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.

Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

Other Uses or Transfer of Your Personal Data. If you use the Platform and Service with or through a third-party service, site and/or mobile application, we may receive information (including Personal Data) about you from those third-parties. Please note that when you use or interact with third-parties outside of our Platform, their own terms and privacy policies will govern your use of those services.

5. International Transfers

Some of our service providers and affiliates are located in countries other than your own. When we transfer your Personal Data internationally, we will do so in accordance with applicable law.

6. Security

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security measures you use to protect user IDs and passwords, please take appropriate measures to protect this information.

7. Your Rights

Subject to applicable law, you may request to access or view any Personal Data you have provided to us and request that such Personal Data be corrected, updated, restricted, or deleted by emailing us at support@reflekt.trade. We may ask for reasonable evidence to verify your identity before complying with your request.

8. Data Retention

Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.

In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.

If you decide to delete your Platform account, we will maintain Personal Data in our possession in accordance with our data retention policy.

9. Cookies and Similar Technologies

We use cookies and similar technologies for various reasons, including to help personalize your experience. When visiting the Platform or website, you shall be notified of the use and placement of cookies and other similar technologies on your device as specified herein.

What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

How We Use Cookies. We use cookies and similar technologies for a number of reasons, as specified below.

The specific names and types of cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

How to Adjust Your Preferences. Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Service may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.

By changing your device settings, you can prevent your device's ad identifier from being used for interest-based advertising, or you can reset your device's ad identifier. Typically, you can find the ad identifier settings under "privacy" or "ads" in your device's settings, although settings may vary from device to device. Adjusting your preferences as described in this section does not mean you will no longer receive advertisements; it only means the advertisements that you do see will be less relevant to your interests.

10. Third-Party Applications and Services

You may have access to third-party services or integrations through our Services, such as generative AI providers used to provide you with AI Features or Supported Exchanges from which we collect and process Trading Data. All use of third-party applications or services is at your own risk and subject to such third-party's terms and privacy policies.

11. Communications

We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may delete your account.

12. Children

We do not knowingly collect Personal Data from children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) has enrolled without parental permission, please advise us immediately.

13. Changes to the Privacy Notice

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. You acknowledge and agree, that continued use of our Service following such changes constitutes their acceptance.

14. Comments and Questions

If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at support@reflekt.trade.