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Privacy Policy

Last Updated: 25 September 2024

1. In brief

We are Squadron Technologies Ltd ("Squadron Technologies," "we," "our" or "us"). We respect your privacy and are committed to protecting the confidentiality of the information you provide to us. This Privacy Policy outlines how we handle your Personal data when you use our services on the MarketAlpha platform ("Platform"). It is intended to help you understand your rights and how we use your data.

2. About us

Squadron Technologies Ltd is the data controller responsible for your Personal data. We are the sole owner of the MarketAlpha.Ai website ("Website"). This Privacy Policy applies to the Personal data we collect when you visit our Website, create an account, or use our applications or services ("you" or "your"). This policy details the types of Personal Data we collect, the reasons for collecting it, the lawful basis for processing your Personal Data, how we use and store it, and the ways in which we share this information.

"Personal data" refers to any information that relates to you and can directly or indirectly identify you.

By using our Website or submitting your Personal data, you agree to the terms of this Privacy Policy. Please read it carefully. If you disagree with any part of this Privacy Policy, you should stop using our Website and, if applicable, delete your user account.

3. Updates to our Privacy Policy

We may update this Privacy Policy from time to time at our discretion by posting an updated version on our Website. We encourage you to review this page periodically for any changes. If required by applicable law, we will notify you of any significant changes through email notifications with a clear subject line such as 'Important Update to MarketAlpha Privacy Policy,' and include a summary of the changes made.

4. Personal data we collect

We collect Personal data from you when you interact with our Platform, including but not limited to:

4.1. Data provided by you
  • pointSign Up Request: When you request beta access to the platform, you will be asked to provide your full name and email address.
  • pointAccount Information: When you create an account, you will be asked to provide a username and password.
  • pointProfile Information: If you choose to provide additional information, such as a profile picture or additional contact details, this data will also be collected and stored.
  • pointPayment Information: For Paid User accounts, our third-party payment processor collects and processes payment card and bank account information necessary for subscription registration. We do not store, nor have access to your payment information.
4.2. Data collected automatically
  • pointCookies and Other Technologies: We use cookies, web beacons, and other tracking technologies to manage our Website, gather statistical insights, enhance security, combat spam, and deliver targeted advertising. Cookies help improve your browsing experience by storing your preferences and enhancing website functionality. Further details on cookie usage can be found in our Cookie Policy.
  • pointLog Files: Like most websites, we collect log files, which may include your IP address, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, and date/time stamps. We use this data to administer the site, analyze trends, and gather broad demographic information.
  • pointDevice Information: We collect information about the devices you use to access our services, including IP addresses, device type, operating system, browser version, and application version. This helps us prevent fraud, abuse, and ensure the security of our services.
  • pointAnalytics: We use analytics tools, both internal and third-party, to collect information about how you use our Platform. This may include device identifiers (such as Google Advertising ID for Android or Advertising Identifier (IDFA) for iOS), interactions with our Website and applications, and general device details. We use pseudonymous data, ensuring no personally identifiable information (PII) is included in analytics reports.
4.3. Analytics information

During your use of our Platform, we may automatically collect analytics information. This includes general device details, device identifiers (such as Google Advertising ID for Android or Advertising Identifier (IDFA) for iOS), network information, and interactions with our Website and applications. We collect only pseudonymous Personal data, ensuring that no PII is included in our analytics reports. This data is used to analyse and enhance our services and applications, as well as for ongoing development and testing. We utilize both internal analytics tools and third-party service providers to achieve these purposes.

4.4. This website uses Mouseflow

Mouseflow is a website analytics tool that provides session replay, heatmaps, funnels, form analytics, feedback surveys, and similar features/functionality. Mouseflow may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (desktop/tablet/phone), screen resolution, visitor type (first time/returning), referrer, anonymized IP address, location (city/country), language, and similar meta data. Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser. If you'd like to opt-out, you can do so at https://mouseflow.com/opt-out. If you'd like to obtain a copy of your data, make a correction, or have it erased, please contact us first or, as a secondary option, contact Mouseflow at privacy@mouseflow.com.

5. How we use your Personal data

We process your Personal data for the following purposes:

  • pointProvision of Services: To provide you with the services you have requested, such as access to our platform components, account management, and customer support.
  • pointAccount Security: To authenticate and secure your user account, prevent fraud, and monitor for suspicious activity.
  • pointImprovement of Services: To analyse usage patterns and feedback, allowing us to improve the Platform and develop new features.
  • pointMarketing Communications: To send you marketing emails about products or services similar to those you have subscribed to, unless you have opted out. If you do not wish to receive these communications, you can manage your preferences under Account Settings or opt out by clicking "unsubscribe" in the emails. Any other promotional information will only be sent with your explicit consent, given at the time you provided us with your personal data. You can withdraw this consent at any time by adjusting your preferences in Account Settings.
  • pointLegal Obligations: To comply with legal obligations, such as tax laws, audits, and regulatory requirements.

6. Lawful basis for processing

We process your Personal data under the following lawful bases as defined by the UK GDPR:

  • pointContractual Necessity: Processing is necessary to fulfil our contractual obligations to you, such as providing access to our Platform.
  • pointLegitimate Interests: Processing is necessary for our legitimate business interests, such as improving our services, marketing, and ensuring security, provided that these interests do not override your rights and freedoms.
  • pointLegal Obligation: Processing is necessary to comply with legal requirements.
  • pointConsent: Where required, we will obtain your consent before processing your Personal data, such as for certain marketing communications. You can withdraw your consent at any time.

7. How we share your Personal data

We share your Personal data with third parties only under the following circumstances:

7.1. Service providers

We engage third-party service providers to support our operations, including:

  • pointPayment Processors: For processing payment information (refer to "Payment Information" above).
  • pointIT and Cloud Service Providers: For hosting our data and providing IT support.
  • pointAnalytics Providers: For tracking and analysing usage of our Platform.

These third parties are only permitted to process your personal data according to our instructions and are subject to strict confidentiality and data privacy obligations.

7.2. MarketAlpha affiliated businesses

We may share your Personal data with affiliated businesses within our corporate group for administrative purposes, marketing, and the provision of services you have requested. These affiliates are bound by the same data protection standards as outlined in this Privacy Policy.

7.4. Business transfers

We may share your Personal data with affiliated businesses within our corporate group for administrative purposes, marketing, and the provision of services you have requested. These affiliates are bound by the same data protection standards as outlined in this Privacy Policy.

7.5. Analytics sharing

We share pseudonymous analytics data with third-party service providers to analyse how our Platform is used, enhance our services, and support ongoing development. These providers are subject to strict confidentiality obligations and are only permitted to use this data according to our instructions and for the purposes outlined in this Privacy Policy.

8. Data Security

We implement robust technical and organizational measures to protect your Personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • pointEncryption: We use Transport Layer Security (TLS) to encrypt data during transmission.
  • pointAccess Controls: We restrict access to your Personal data to authorized personnel only.
  • pointPhysical Security: We maintain physical security measures to protect our data storage facilities.
  • pointOngoing Security Enhancements: We regularly update our security practices to address emerging threats.

Despite our efforts, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we continuously work to ensure that your Personal data is protected to the highest possible standard.

9. Offshore and sensitive Personal data

Our Platform is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected such data, please contact us immediately. We do not process sensitive Personal data as defined by UK GDPR Article 9, such as data concerning health, race, religion, or sexual orientation. If such data is inadvertently collected, we will take immediate steps to delete it.

10. Third-Party links

Our Platform may contain links to third-party websites. These sites operate independently of us and have their own privacy policies. We are not responsible for the content or privacy practices of these linked sites. We recommend that you review the privacy policies of any third-party sites you visit.

11. Deleting user accounts

You have the option to stop using our Platform and request the deletion of your account through the Account Settings page. Upon your confirmation, your account will be permanently deleted. This process includes the removal of any Personal data you have provided to us. However, certain content, such as published ideas/scripts and messages sent to other users, will be retained as they are integral to the platform's operation and integrity. For legitimate business purposes and to comply with legal obligations, including tax laws, audits, and security requirements, certain data may need to be retained for a longer period.

12. Your rights (EU and UK users)

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you have certain rights regarding your Personal data under applicable data protection laws:

  • pointAccess: You can request a copy of the Personal data we hold about you and relevant details of how we process it.
  • pointCorrection: You have the right to request the correction of inaccurate or incomplete Personal data.
  • pointDeletion: You can request the deletion of your Personal data, subject to certain exceptions, such as where retention is required by law.
  • pointRestriction: You have the right to request the restriction of processing your Personal data under certain circumstances.
  • pointObjection: You can object to the processing of your Personal data where we rely on legitimate interests or for direct marketing purposes.
  • pointData Portability: You have the right to receive your Personal data in a structured, commonly used, and machine-readable format and request its transmission to another controller.
  • pointWithdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights, please contact us at support@marketalpha.ai. We may need to verify your identity before processing your request. We aim to respond to all legitimate requests within one month, but it may take longer if your request is complex or if you have made multiple requests.

13. Data retention

We retain your Personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

  • pointService Provision: For the duration of your use of our Platform and services.
  • pointLegal Compliance: As required by applicable laws and regulations, including retention periods for tax and financial reporting.
  • pointDispute Resolution: To resolve disputes, enforce agreements, and prevent fraud or abuse.

Once your data is no longer needed, we will either delete it or anonymize it, ensuring it cannot be linked back to you.

14. International data transfers

Your Personal data may be transferred to, and stored in, countries outside the European Economic Area (EEA) or the United Kingdom (UK), including the United States. These countries may have different data protection standards compared to your home country.

We ensure that all international transfers of your Personal data are protected by appropriate safeguards, such as:

  • pointStandard Contractual Clauses (SCCs): We implement the up to date SCCs approved by the European Commission (Commission Implementing Decision 2021/914 on standard contractual clauses for the transfer of personal data to third countries dated 4th June 2021), or other lawful mechanisms that ensure adequate protection of your data.
  • pointThe UK's International Data Transfer Agreement (IDTAs): The international data transfer addendum to the European Commission's standard contractual clauses for international data transfers (Addendum).
  • pointUS Personal Data Transfer: For any transfer of Personal Data to the US we ensure that such transfers are subject to similar safeguards or rely on lawful transfer mechanisms such as the US-EU Data Privacy Framework or the US-UK data bridge. By using our Platform, you consent to the transfer of your data to countries outside your country of residence, which may provide different levels of data protection.

15. Your California Privacy rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

  • pointRight to Know: You can request information about the categories and specific pieces of Personal data we have collected about you over the past 12 months, the categories of sources from which the Personal data is collected, the purpose for collecting the Personal data, and the categories of third parties with whom we share it.
  • pointRight to Deletion: You can request that we delete any Personal data we have collected from you, subject to certain exceptions.
  • pointRight to Opt-Out: You have the right to opt-out of the sale of your Personal data. We do not sell your Personal data.
  • pointNon-Discrimination: We will not discriminate against you for exercising your CCPA rights. This means we will not deny you services, charge you different prices, or provide a different quality of services based solely on your exercise of these rights. To exercise your rights under the CCPA, please contact us at support@marketalpha.ai. We will verify your request by confirming your identity and residency before processing your request.

16. Contact us

Full name of legal entity: MarketAlpha Ltd

  • pointIf you have any questions or concerns about this Privacy Policy, or if you wish to exercise any of your data protection rights, please contact us at support@marketalpha.ai.

Alternatively, you may write to us at the following address:

  • pointHarben House Harben Parade, Finchley Road, London, United Kingdom, NW3 6LH.

You have the right to make a complaint to the Information Commissioners Officer (ICO), the UK's regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.