Your affirmative act of using our website located at www.intraalpha.com (and all associated sites linked to it) or services (“IntraAlpha”) signifies that you agree to the following terms and conditions of use (“Terms of Use”). If you do not agree, do not use IntraAlpha. IntraAlpha is the property of IntraAlpha Inc. (“us”, “we” or “our”).

1. Changes to the terms of use

We may change these Terms of Use at any time. If you continue to use IntraAlpha after we post changes to these Terms of Use, you are signifying your acceptance of the new terms. You will always have access to our Terms of Use and will be able to check it at any time. By reloading this page, you will have the most up-to-date version available to IntraAlpha users.

2. Changes to IntraAlpha

We may discontinue or change any service or feature on IntraAlpha at any time without notice. We do not guarantee backward compatibility of our services and Application Programming Interface (API) in this case.

3. Ownership of information; License to use IntraAlpha; redistribution of data

Unless otherwise noted, all rights, titles, and interests in IntraAlpha, and all information made available through IntraAlpha or our services, in all languages, formats, and media throughout the world, including, but not limited to, all copyrights and trademarks therein, are the exclusive property of IntraAlpha, our affiliates or our Data Providers, as defined in section 6 (disclaimer regarding content) below.

All rights, title and interest in and to any data or/and other information provided by Interactive Data (IDCO), and all such data/information made available by Interactive Data (IDCO) through IntraAlpha or our services, in all languages, formats and media throughout the world, including all copyrights and trademarks therein, are the property of Interactive Data (IDCO), our affiliates or our Data Providers (as applicable).

You may not use any data mining, robots or similar data gathering and extraction tools on the IntraAlpha content, frame any portion of IntraAlpha or its content, sublicense, assign, transfer, sell, loan, or otherwise distribute for payment the IntraAlpha content without our prior written consent. You may not circumvent any mechanisms included in the IntraAlpha content for preventing the unauthorized reproduction or distribution of the IntraAlpha content. For additional information on commercial and partnership inquiries with us, please see the Contacts page.

Except as otherwise expressly permitted by the preceding paragraph, you agree not to sell any of the services or materials in any manner or for any purposes, without the prior expressed written consent of IntraAlpha and/or our Data Providers. In addition, you shall not, without the prior expressed written consent of IntraAlpha and the relevant Data Providers, make copies of any of the software or documentation that may be provided, electronically or otherwise, including, but not limited to, translating, decompiling, disassembling or creating derivative works.

Except as otherwise expressly permitted by additional agreement, we do not permit commercial usage of any of our services or APIs. We make no warranty and assume no obligation or liability for third party services or software. Please see section 19 (third party software) below for further information.

4. Attribution

IntraAlpha grants all users of intraalpha.com, and all other available versions of the site, to use snapshots of IntraAlpha charts in analysis, press releases, books, articles, blog posts and other publications. In addition, IntraAlpha grants the use of all previously mentioned materials in education sessions, the display of IntraAlpha charts during video broadcasts, which includes overviews, news, analytics and otherwise use or promote IntraAlpha charts or any products from the IntraAlpha website on the condition that IntraAlpha attribution is clearly visible at all times when such charts and products are used.

Attribution must include a reference to IntraAlpha, including, but not limited to, those described herein.

Use of IntraAlpha charts during video or other promotions where IntraAlpha attribution is not visible, must include a description of the product used therein. For instance: “Charting platform used for this analysis is provided by IntraAlpha,” or simply “Charts by IntraAlpha.” Font size should not be less than 10 PT = 13PX = 3.4MM.

You can use the “Snapshot” button in the top toolbar of the chart to instantly create a picture file of your current chart. IntraAlpha will automatically take a snapshot with all required attributions and provide a link where you can view your chart, download it or share it. The use of any IntraAlpha products outside the IntraAlpha website, without a proper attribution of IntraAlpha, is not allowed. This extends to any tools (such as widgets) obtained on the IntraAlpha website and utilized on the outside resources, where attribution should remain as was originally designed and intended. Users who disobey this attribution rule herein may be banned permanently, and other legal actions may be taken to ensure compliance. This includes, but is not limited to, cease-and-desist warnings, court orders, injunctions, fines, damages relief, and so on.

5. Third party sites and advertisers

IntraAlpha may include links to third party websites. Some of these sites may contain materials that are objectionable, unlawful, or inaccurate. You agree that IntraAlpha shall not be held liable for any trading activities or other activities that occur on any website you access through links on IntraAlpha. We provide these links as a convenience and do not endorse the content or services offered by these other sites. Any dealings that you have with advertisers found on IntraAlpha are between you and the advertiser and you acknowledge and agree that we are not liable for any loss or claim you may have against an advertiser.

Unauthorized soliciting on IntraAlpha is strictly prohibited and may result in penalties, including, but not limited to, temporary or permanent bans of the account found in violation, and any appropriate and available legal action for monetary and other damages.

6. Disclaimer regarding content

IntraAlpha cannot and does not represent or guarantee that any of the information available through our services or on IntraAlpha is accurate, reliable, current, complete or appropriate for your needs. Various information available through our services or on IntraAlpha may be specially obtained by IntraAlpha from professional businesses or organizations, such as exchanges, news providers, market data providers and other content providers (e.g. Cboe BZX and possibly other established financial exchanges such as the New York Stock Exchange, NASDAQ, New York Mercantile Exchange and Dow Jones), who are believed to be sources of reliable information (collectively, the “Data Providers”). Nevertheless, due to various factors — including the inherent possibility of human and mechanical error — the accuracy, completeness, timeliness, results obtained from use, and correct sequencing of information available through our services and website are not and cannot be guaranteed by IntraAlpha. We make no warranty and assume no obligation or liability for scripts, indicators, ideas and other content of third parties. Your use of any third-party scripts, indicators, ideas and other content is at your sole risk.

7. Disclaimer regarding investment decisions and trading

Decisions to buy, sell, hold or trade in securities, commodities and other investments involve risk and are best made based on the advice of qualified financial professionals. Any trading in securities or other investments involves a risk of substantial losses. The practice of “Day Trading” involves particularly high risks and can cause you to lose substantial sums of money. Before undertaking any trading program, you should consult a qualified financial professional. Please consider carefully whether such trading is suitable for you in light of your financial condition and ability to bear financial risks. Under no circumstances shall we be liable for any loss or damage you or anyone else incurs as a result of any trading or investment activity that you or anyone else engages in based on any information or material you receive through IntraAlpha or our services.

8. Disclaimer regarding hypothetical performance results

Hypothetical performance results have many inherent limitations, some of which are mentioned below. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown. In fact, there are frequently sharp differences between hypothetical performance results and actual results subsequently achieved by any trading program.

One of the limitations of hypothetical performance results is that they are generally prepared with the benefit of hindsight. In addition, hypothetical trading does not involve financial risk and no hypothetical trading record can completely account for the impact of financial risk in actual trading. For example, the ability to withstand losses or to adhere to a particular trading program in spite of the trading losses are material points, which can also adversely affect trading results. There are numerous other factors related to the market in general or to the implementation of any specific trading program which cannot be fully accounted for in the preparation of hypothetical performance results and all of which can adversely affect actual trading results.

9. Registered users

Certain services, such as saving charts, publishing them, or the ability to comment on published charts, are available only to registered users of the IntraAlpha website and require you to sign in with a username and password to use them. If you register as a user (a “Subscriber”) of any of the features of IntraAlpha, during the registration process you may be prompted to click “Register Now”, “Submit” or a similar button; your clicking on such button will further confirm your agreement to be legally bound by these Terms of Use.

In consideration of your use of the IntraAlpha website, you represent that you are of legal age to form a binding contract and are not a person barred from receiving IntraAlpha services under the laws of the United States or other applicable jurisdiction. You also agree to: (a) provide true, accurate, current and complete information about yourself as prompted by the IntraAlpha’s registration form (the “Registration Data”) and (b) maintain and promptly update the Registration Data to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or IntraAlpha has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, IntraAlpha has the right to suspend or terminate your account and refuse any and all current or future use of the IntraAlpha services (or any portion thereof).

You represent and warrant that you have all intellectual property rights, including all necessary patent, trademark, trade secret, copyright or other proprietary rights, in and to your content. If you use third-party materials, you represent and warrant that you have the right to distribute third-party material in the content. You agree that you will not submit material that is copyrighted, protected by trade secret, or otherwise subject to third-party proprietary rights, including patent, privacy and publicity rights unless you are the owner of such rights or have permission from their rightful owner to submit the material.

We may remove your content without notice if we reasonably believe that you’re in violation of our Terms of Use.

10. Non-Professional subscriber status

As a vendor of official real-time market data from exchanges (e.g. Nasdaq) for end users, we are required to identify the ‘Non-Professional’ status of any Subscriber. By ordering a subscription for market data on IntraAlpha (except for the following subscriptions: CME GLOBEX, CBOT, COMEX, NYMEX) you confirm the following:

1. You use market data solely for personal use, not for your business or any other entity.
2. You are not registered or qualified with the Securities Exchange Commission (SEC) or the Commodities Futures Trading Commission (CFTC).
3. You are not registered or qualified with any securities agency, any securities exchange, association or regulatory body in any country.
4. You do not perform any functions that are similar to those that require an individual to register or qualify with the SEC, the CFTC, any other securities agency, any securities exchange, or association or regulatory body, or any commodities or futures contract market, or association or regulatory body.
5. You are not engaged as an investment advisor (as that term is defined in Section 202 (a) (11) of the Investment Advisor’s Act of 1940) or asset manager and you are not engaged to provide investment advice to any individual or entity.
6. You are not subscribing to the service in your capacity as a principal, officer, partner, employee, or agent of any business or on behalf of any other individual.
7. You use your own capital, not provided by any other individual or entity in the conduct of your trading.
8. You do not conduct trading for the benefit of a corporation, partnership, or other entity.
9. You have not entered into any agreement to share the profit of your trading activities or receive compensation for your trading activities.
10. You are not receiving office space, and equipment or other benefits in exchange for your trading or work as a financial consultant to any person, firm or business entity.

11. Derived Data

Our proprietary derivation consumes raw market data and executes a 2-factor derivation process to produce the displayed price, later consumed by the price engine. Derived market data is sourced and supplied from various sources and can therefore be blended.

The derivation process involves changing the raw price by a factor determined by the volume of trading on the underlying market, a randomized variable and a maximum offset amount. The derived data price is only ever displayed to our non-professional clients, the derived data price then being the proprietary value of an organization.

At no point is raw data accessible by any client, nor can said data be reverse-engineered in any manner. All markets are passed through the same derivation engine.

12. Access and security

You accept responsibility for the confidentiality and use of any username and email address that use to register for your access to and use of our services. You are responsible for maintaining the confidentiality of your password and account and are fully responsible for all activities that occur under your password or account. You agree to (a) immediately notify IntraAlpha of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. IntraAlpha cannot and will not be liable for any loss or damage arising from your failure to comply.

IntraAlpha considers private information on the site (source code of protected or invite-only scripts, etc.) to be confidential to you. IntraAlpha protects such private information from unauthorized use, access, or disclosure in the same manner that it protects personal data (please refer to our Privacy Policy for more information).

13. Payment and cancellation of service

1. By ordering any subscription on www.intraalpha.com (including a free trial period) you confirm that you have read and accepted our Terms of Use and you authorize IntraAlpha to automatically charge your bank card or PayPal account according to the billing period manually selected by you.
2. Each user can try any paid plan for 30 days free of charge. If the trial is not canceled before its expiration date, it automatically converts to a monthly or annual paid plan depending on the user’s choice. There are no refunds for monthly plans, even if the subscription is canceled on the same day as the autoconversion payment has gone through. Refunds are available only after an automatic deduction for annual payments (i.e. after trial and after renewal) within 14 calendar days after the payment was made. Please note that users who filed a chargeback/dispute request or a claim are not eligible for a refund. Premium subscriptions automatically include market data that is available without additional per-user fees only. You can see which markets are available for free and which need to be purchased separately on the IntraAlpha Premium page. A canceled trial and associated services will stop immediately after cancellation, except for any data packages that were purchased.
3. The service is billed in advance on a monthly, annual, or 2-year basis. There will be no refunds or credits for partial months of service or refunds for months unused with an open user account. If auto-renewal fails for an annual plan you will automatically be switched to a monthly plan.
4. All billing is recurring, which means you will continue to get billed until you cancel your subscription. You are solely responsible for properly canceling your IntraAlpha subscription. An email request or support ticket asking for your subscription to be cancelled is not considered cancellation. You may cancel your subscription at any time by visiting the billing section of your Profile Settings page.
5. If you cancel the service before the end of your current paid-up period, your subscription will remain active until the next due date. After the due date, if no payment is received, your subscription will be stopped.
6. We do not offer refunds for initial payments. If you order the service for the first time, please make sure that the order is correct before the payment is made.
7. We do not offer refunds for recurring monthly payments. If you have been billed for automatic monthly renewal of the Service, you can cancel the subscription to avoid billing for next month.
8. We do not offer refunds for upgrades to a more expensive plan or a longer billing cycle. The remaining days are converted into an equivalent value of days on the new subscription.
9. We offer refunds for recurring annual and 2-year payments on demand. If you have been billed for automatic annual and 2-year renewal of the service, you have 14 calendar days (after the payment was made) to contact our support team. If you don’t do this, IntraAlpha assumes that renewal of the service is expected and the payment will not be refunded.
10. Refunds are available only after an automatic deduction for annual payments (i.e. after trial and after renewal) within 14 calendar days after the payment was made.
11. Our moderators are official IntraAlpha representatives, with the authority to warn or ban users (including those with a paid subscription) when they do not abide by the House Rules. We do not offer refunds in case you are banned from publishing content and interacting with others because your paid subscription and all of its data and/or features are still available during any such ban.
12. IntraAlpha, Inc. is registered for tax purposes in Australia, Canada, EU states, India, Norway, Saudi Arabia, Singapore, South Korea, Switzerland, Taiwan, Turkey.

14. Feedback to IntraAlpha

By submitting ideas, content, suggestions, documents, and/or proposals (“Contributions”) to IntraAlpha through our contact or feedback webpages, you acknowledge and agree that: (a) your Contributions do not contain confidential or proprietary information; (b) IntraAlpha is not under any obligation of confidentiality, expressed or implied, with respect to the Contributions; (c) IntraAlpha shall be entitled to use or disclose (or choose not to use or disclose) such Contributions for any purpose, in any way, in any media worldwide; (d) IntraAlpha may have something similar to the Contributions already under consideration or in development; (e) your Contributions automatically become the property of IntraAlpha, without any obligation of IntraAlpha to you; and (f) you are not entitled to any compensation or reimbursement of any kind from IntraAlpha under any circumstances.

15. Indemnity

You agree to indemnify and hold IntraAlpha and our subsidiaries, affiliates, officers, agents, employees, partners and licensors harmless from any claim or demand, including reasonable attorneys’ fees, made by any third party due to or arising out of content you submit, post, transmit, modify or otherwise make available through the IntraAlpha services, your use of the IntraAlpha services, your connection to the IntraAlpha services, your violation of the Terms of Use, or your violation of any rights of another.

16. Termination

Upon your request, your account can be deleted from IntraAlpha. You may delete your account at any time by visiting your Profile Settings page. If you requested your account be deleted, we will delete the personal data associated with your account, however certain personal data will be retained if it has been integrated into data that is integral to our systems and site, including data in communications you have sent via our site. This data is necessarily retained for the integrity of the data on the site and our legitimate business purposes, including auditing, security and other legitimate interests (please refer to our Privacy Policy for more information). Your published Contributions will remain on the site in our discretion. Once a Contribution has been published, it becomes part of the communal trading knowledge and should stay that way. This policy prevents users from keeping only their best ideas public, thus keeping everyone honest and maintaining public confidence in the reputation and integrity of the site.

You agree that IntraAlpha may, without prior notice, immediately terminate, limit your access to or suspend your IntraAlpha account, any associated email address, and access to the IntraAlpha services. Cause for such termination, limitation of access or suspension shall include, but not be limited to, (a) breaches or violations of the Terms of Use or other incorporated agreements or guidelines, (b)requests by law enforcement or other government agencies, (c) discontinuance or material modification to the IntraAlpha services (or any part thereof), (d) unexpected technical or security issues or problems, (e) extended periods of inactivity, (f) and/or engagement by you in fraudulent or illegal activities. Further, you agree that all terminations, limitations of access and suspensions for cause shall be made in IntraAlpha’s sole discretion and that IntraAlpha shall not be liable to you or any third party for any termination of your account, any associated email address, or access to the IntraAlpha services.

17. Emails

By creating an account with IntraAlpha, you agree that IntraAlpha can use your email address to send you marketing materials, service-related notices, important information messages, special offers, etc. You can unsubscribe from this by clicking on the link provided in the emails.

18. House rules

By creating and using an account on IntraAlpha you confirm you have read and agree to follow our House Rules.

19. Third-Party Software

Our software, website and/or services may include software components supplied by third parties which are utilized by permission of the respective licensors and/or copyright holders on the terms provided by such parties (“Third Party Software”). IntraAlpha expressly disclaims any warranty or other assurance to you regarding Third Party Software. Please note that your use of the Third Party Software will be governed by the terms and conditions of use and privacy policies of the Third Party Software providers and not by these Terms of Use or our Privacy Policy.

20. Scripts

You represent and warrant that you have all intellectual property rights, including all necessary patent, trademark, trade secret, copyright or other proprietary rights, in and to your script. If you use third-party materials, you represent and warrant that you have the right to distribute third-party material in the script. You agree that you will not submit material that is copyrighted, protected by trade secret or otherwise subject to third party proprietary rights, including patent, privacy and publicity rights, unless you are the owner of such rights or have permission from their rightful owner to submit the material.

You are solely responsible for any script that you create. IntraAlpha is not in any way responsible for the use or misuse of your script by any user. IntraAlpha is not in any way responsible for the use or misuse any user’s script by you.

By using the publish script feature, you grant us a world-wide, irrevocable, perpetual, royalty-free licence to:

• publish this script as well as the username of the author;
• disclose the source code of the script for open scripts;
• perform, display, use and make available your open or protected script for any user or an invite-only script for any user that received an invite.

We may remove your script without notice if we reasonably believe that you are in violation of these Terms of Use.

You can publish the script under any license. If you do not include the license in the comment section of a script, you agree that your script is licensed under the Mozilla Public License 2.0.

21. Publications – No Recommendation or Advice Status

The information and publications are not meant to be, and do not constitute, financial, investment, trading, or other types of advice or recommendations supplied or endorsed by IntraAlpha.

Any statement of view (which may be subject to change without notice) is the author’s personal opinion, and the author makes no representations or warranties as to the accuracy or completeness of any information or analysis provided.

The authors and IntraAlpha are not liable for any losses incurred as a result of any investment made on the basis of any perceived recommendation, forecast, or other information presented here.

The contents of these publications should not be interpreted as an express or implicit promise, guarantee, or indication by IntraAlpha that customers will profit or that losses in connection with them can or will be limited if they rely on the information provided.

IntraAlpha may update these Rules at any time.

PRIVACY NOTICE

Last updated May 13, 2023

This privacy notice for IntraAlpha, LLC (doing business as IntraAlpha) (“IntraAlpha,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

• Visit our website at intraalpha.com, or any website of ours that links to this privacy notice

• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with IntraAlpha and the Services, the choices you make, and the products and features you use. Click here to learn more.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Click here to learn more.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Click here to learn more.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what IntraAlpha does with any information we collect? Click here to review the notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

8. HOW LONG DO WE KEEP YOUR INFORMATION?

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

10. DO WE COLLECT INFORMATION FROM MINORS?

11. WHAT ARE YOUR PRIVACY RIGHTS?

12. CONTROLS FOR DO-NOT-TRACK FEATURES

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

14. DO WE MAKE UPDATES TO THIS NOTICE?

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• email addresses

• usernames

• passwords

• contact preferences

• contact or authentication data

• billing addresses

• debit/credit card numbers

• mailing addresses

• phone numbers

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• financial data

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?“ below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?“ below).

• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services

• Develop and display personalized and relevant advertising content for our users

• Analyze how our services are used so we can improve them to engage and retain users

• Support our marketing activities

• Diagnose problems and/or prevent fraudulent activities

• Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Ad Networks

• Affiliate Marketing Programs

• Cloud Computing Services

• Communication & Collaboration Tools

• Data Analytics Services

• Data Storage Service Providers

• Finance & Accounting Tools

• Payment Processors

• Performance Monitoring Tools

• Product Engineering & Design Tools

• Retargeting Platforms

• Sales & Marketing Tools

• Social Networks

• Testing Tools

• User Account Registration & Authentication Services

• Website Hosting Service Providers

• Order Fulfillment Service Providers

• Government Entities

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“ below.

We will consider and act upon any request in accordance with applicable data protection laws.

 

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“ below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at [email protected].

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	NO
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	NO
C. Protected classification characteristics under California or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

IntraAlpha, LLC collects and shares your personal information through:

• Targeting cookies/Marketing cookies

• Social media cookies

• Beacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

IntraAlpha, LLC has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. IntraAlpha, LLC has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?“.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;

• the categories of personal information that we collect;

• the purposes for which the collected personal information is used;

• whether we sell your personal information to third parties;

• the categories of personal information that we sold or disclosed for a business purpose;

• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.

• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

• You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or by post to:

IntraAlpha, LLC

252 A Ave

Suite 200

Lake Oswego, OR 97034-3164

United States

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by contacting us here: Contact IntraAlpha.