PRIVACY POLICY

Here in our privacy policy, we outline what data we collect, how we collect data and all uses of data. We also discuss all third-party policies, explain our data retention/deletion policies and describe how a user can revoke consent and/or request the deletion of their data.

 

For this Privacy Policy, the following terms shall have the meanings specified below:

"Content" means all messages, email notifications, postings, chats, text, images, trading strategies, signals, video or any other content and materials shared, posted or published on, uploaded to, transmitted through, or linked from StrattyX. "StrattyX app" or "Application" means the StrattyX mobile application for iOS and Android; "StrattyX" means together with the Application and the Website; “Product” is all things(CONTENT, APP, WEBSITE, ETC) created by and organized by StrattyX that are available. means "Services" means the use and/or access to StrattyX and all the Content available therein. "We" or "the Company" means StrattyX Inc., 58 Plympton Street Cambridge, MA 02138; "Website" means our website at www.StrattyX.com. "You" or "the User" means every person using StrattyX, whether a visitor or a registered user.

 

This Privacy Policy is intended for Users of the Services offered by StrattyX and aims to inform them about our policies and procedures regarding the collection, use, and disclosure of the personal data received from the Users of StrattyX. We are committed to the protection of your personal data and we do not access or use it for any purpose other than providing, maintaining and improving our services and as otherwise required by law. This policy outlines how we manage such information to ensure we meet our obligations to respect our clients’ privacy and that all such information remains confidential. By using any of our Services, you consent to the collection, storage, disclosure, and use of your information as outlined in this Privacy Policy and in compliance with the applicable data protection legislation.

 

Information we Collect and Use

When you access our Website or the Application, connect to, sign up to, participate in, create an account for, make individual operations within or otherwise use our services, we may collect personal data about you. We also process data that we have legitimately received from publicly available sources or through your use of the Services. If you want to use our Services, you have to create an account in the Application or the Website. During the registration process, personal information will be required, such as your name and email address. When we collect your personal data, our goal is to provide You with the Services offered by StrattyX, to communicate with You, and to manage your account with us. Account related information may include information requests, customer service requests and notes or details explaining what you asked for and how we responded, information collected when you connect StrattyX with any broker, exchange, or external 3rd party platforms, such as the name of your broker, the currency of your account, purchases and orders, your trading preferences, used strategies, and instruments, and backtests.

 

We may contact you from time to time. When you access our mobile device options we will collect your cellular phone number. If you contact us by email, social media, websites with clear StrattyX connections, in-person events, discord, Slack, and any messaging service our team occupies, we may keep a record of your contact information and correspondence. In this case, we will be able to use your contact and any information that you provide to us in your contact to respond and answer You. We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. We may use your contact information to send you information about our Services or to help prevent spam, fraud, or abuse. In such instances, you will be given the opportunity to provide or decline that information. Email us at Team@Strattyx.com with the medium of communication you would like to discontinue and we will proceed to cease communication.

 

We may use the information to make inferences, like what topics you may be interested in, and to customize the Content we show you, including ads, new features, and partnerships.

Your use of the Website and related mobile applications and online services involves the automated collection of certain types of information, some of which may be considered personal information or in specific circumstances. This information includes: IP address, browser type, and operating system. We use our Users’ log data to monitor the use of our Services and for the Service's technical administration. We do not associate your IP address with any other personal data to identify you personally, except in case of violation of the Terms of Use to protect StrattyX and its users from abuse.

In addition, the Website uses a range of cookies to improve and personalize your experience. More information about these can be found in our Cookies Policy.

 

How we Process Information

We are dedicated to preserving the confidentiality of your personal information and we are committed to both minimize the data we collect and limit its use and purpose only to what is strictly necessary to:

(1) deliver the Services you interact with in accordance with our Terms of use - We use this information to improve and optimize the operation and performance of our Services; diagnose problems and identify any security risks, errors, or needed enhancements to the Services; detect and prevent fraud and abuse of our services and systems;

(2) in case the processing of personal data is necessary for the purposes of the legitimate interests pursued by us – for example, to ensure that we provide you with the best services and information we can and to continue improving our products in your best interest; to send you surveys for analytical and statistical purposes, as well as to collect aggregate statistics about your use of the services;

(3) for compliance with legal and regulatory obligations to which StrattyX is subject (including but not limited to anti-money laundering and countering terrorist financing regulatory obligations, any applicable tax legislation) and in case we are obliged to provide a reference about you to a public authority or agency in order to comply with a legal obligation of legal institutions;

(4) within the scope of your consent – for example, for marketing and promotional purposes. If you have granted us consent to process your personal data for marketing purposes, processing will only take place in accordance with the purposes set out in the declaration of consent and to the extent agreed therein. Any consent given may be revoked at any time by you with future effect.

We may keep track of how you interact with links across our Services, including our email notifications, notifications made through the Application, by redirecting clicks or through other methods. We do this to help improve our Services and to provide more relevant features, bug fixes, advertising, and tools.

We will process your personal data for the purposes of:

(1) providing the Services requested by you or used utilizing any Content accessed by you, including having chat or email communication;

(2) improving and personalizing our Services to enhance your experience by providing you with market information which we believe may be relevant to you and send you important account and Services related data by different communication channels, including surveys, in-app notifications, platform messages and emails we think would be of interest to you.

(3) preventing misuse and fraud, demonstrating business transactions and communications; managing transactions surveillance and monitoring and complying with reporting obligations; managing risks, disputes, complaints, litigation or in the context of prosecution;

 

Recipients of Personal Data and 3rd Party Extensions

Your personal data is received and processed by those employees of StrattyX that need it for the execution of contractual, legal and regulatory obligations. Further, we may disclose, to the extent we deem such disclosure or transmission is necessary for satisfying the purposes set out above, to the following recipients:

(1) Other companies within our group to allow us to provide a full service to you, where such other companies perform components of the full service offering such as IT maintenance, development services, and support services;

(2) Any lawyers, external auditors or advisors, professional consultants, as well as any courts, regulatory, governmental, administrative or other official bodies as may be required by law, where such disclosure is necessary (i) to comply with any applicable law or regulation; (ii) to enforce applicable terms and conditions or policies; (iii) to protect the security or integrity of our services; and (iv) to protect our rights and interests;

(3) third-party service providers that provide technology services, hosting, maintenance, advisory and consultancy services, analytics, research, which are only authorized to process your personal data strictly to provide these services and in accordance with our instructions. If applicable, we will enter with such third-party service providers into the relevant contractual agreements or the standard data protection clauses that would be required to ensure compliance with our instructions;

We will require any entity to whom we disclose your information or who may obtain it on our behalf to ensure its confidentiality, and to handle it in line with the legitimate purpose for which they are allowed to access it and in accordance with the applicable data protection legislation.

We will not share or sell your personal information with third parties for their own independent marketing purposes without your consent.

 

Your Rights

You have the right to:

(1) access and obtain information about your personal data – you have the right to request us what information (if any) we process for you and if so, provide you with an information containing your personal data and a copy of that personal data undergoing processing. To request information, we will need to verify your identity. If you require additional copies, we may need to charge a reasonable administration fee for requests.

(2) rectify any factual inaccuracies or incompleteness with respect to your personal data if the personal data we hold about you is inaccurate or incomplete.

(3) request deletion of your personal data - you can ask us to delete or remove your personal data in cases where we no longer need it or we don’t have a legal obligation to retain such data.

(4) request restriction of processing in certain circumstances such as where you contest the accuracy of that personal information.

(5) object to the processing of personal data and request portability of your personal data - you have the right, when applicable, to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another entity (data controller) of your choice when this is technically possible.

(6) lodge a complaint with a supervisory authority - you have the right to complain about our processing of your personal data with your supervisory authority.

Please contact us using the contact details provided below to make a request in respect of your rights. We will use commercially reasonable efforts to respond to your request within 30 days of receiving such a request. If we cannot honor your request within the 30-day period, we will let you know the reasons why and when we expect to be able to fulfill your request.

 

Security

We are very concerned about safeguarding the confidentiality of your personal data. We do our best to keep your personal data secure. We have in place systems and procedures to prevent unauthorized access, improper modification or disclosure, misuse or loss of information. We abide by technical and organizational norms to ensure that your personal data is secured and kept confidential. Any personal data that you provide to us is stored on secure modular servers and we use rigorous procedures to protect against the loss, misuse, unauthorized access, alteration, disclosure, or destruction of your personal data. We protect your personal information by maintaining electronic and procedural safeguards in compliance with the applicable laws and regulations. We provide a high level of security in terms of personal data management, including, among others pseudonymization, hashing, strict internal control on access to your personal data, penetration testing and ensuring ongoing application of integrity, confidentiality and education of all our employees.

We maintain security and incident response plans in the event of a physical or technical incident to handle this in a timely manner and limit any negative effect of such an incident. Although we work hard to protect your personal data, we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal data.

Please recognize that you play a vital role in protecting your own personal data. When registering with our services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account. If you believe that any of your account login details have been or might have been exposed, you can change your password at any time through our Website and application, as well as immediately contact our customer service. Given the nature of communications and information processing technology, we cannot guarantee that information, during transmission through the Internet, will be absolutely safe from intrusion by others.

 

Links to other websites

StrattyX may contain links to other websites. The fact that we link to a website is not an endorsement or authorization with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal data from you. Other sites follow different rules regarding the use or disclosure of the personal data you submit to them. We do not accept any responsibility or liability for these privacy policies. We encourage you to read the privacy policies or statements of the other websites you visit.

 

Our Policy Towards Minors

StrattyX is an educational tool and thus is geared towards all those who would like to learn about automated trading. However, StrattyX does not direct its products to children (usually considered to be under the age of 13, depending on the country where you reside). We also do not intentionally and/or knowingly collect personal information from children through StrattyX products. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, he or she should contact us at Team@StrattyX.com.

California Privacy Rights

California law permits visitors who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at Team@strattyx.com.

 

Changes to this Policy

StrattyX reserves the right to revise this Policy at any time without notice. By using StrattyX products, you are agreeing to be bound by the then-current version of this Policy, and your continued use of StrattyX products reaffirms your agreement to the then-current Policy. The most current version of the policy will always be at www.StrattyX.com/privacy-policy. Your continued use of the Services following any changes to this Privacy Policy will be regarded as your acceptance of any changes we push forward. You agree to consult StrattyX products regularly for up-to-date versions and information about this Policy. You are responsible for reviewing them. We will send correspondence to the best-kept contact on file upon any changes. If you have any comments or questions regarding this Privacy Policy, please contact us at Team@StrattyX.com.

 

CONTACT US AND FINAL WORDS

If you have any comments or questions regarding this Privacy Policy, please contact us at Team@StrattyX.com

If you are not satisfied with our response to any complaint with regard to your personal data, you have the right to lodge a complaint with the respective supervisory authority.

This Policy has been adopted and is effective as of July 1, 2019, without waiving or otherwise releasing any right or obligation under any prior privacy policy or similar document or agreement of StrattyX, including without limitation any prior privacy policy or similar document or agreement set forth on StrattyX products. This Policy hereby amends and restates any such prior privacy policy.

Those who choose to access and use StrattyX products, and the other products and services of StrattyX, from other locations, do so at their own risk and are responsible for compliance with all laws, rules, and regulations applicable thereto. StrattyX reserves the right to limit the availability of StrattyX products, and any other products or services of StrattyX, to any person, geographic area, or jurisdiction, in any manner and at any time, in its sole discretion.

If any provision of this Policy is found by a court of competent jurisdiction or arbitrator to be illegal, void, or unenforceable, the unenforceable provision will be modified so as to render it enforceable and effective to the maximum extent possible in order to effect the intention of the provision; and if a court or arbitrator finds the modified provision invalid, illegal, void or unenforceable, the validity, legality, and enforceability of the remaining provisions of this Policy will not be affected in any way.

If you do not agree with any term or provision of this policy, please refrain from using StrattyX Inc tools, software, websites, and mobile applications. Please be advised that your continued use of the company’s products or information provided thereby shall indicate your consent and agreement to this policy. Questions about this Policy should be addressed to Team@Strattyx.com.

The materials on this website are for illustration and discussion purposes only and do not constitute an offering. An offering may be made only by delivery of a confidential offering memorandum to appropriate investors. Past performance is no guarantee of future results.

ALL RIGHTS RESERVED

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