Privacy Policy

This Privacy Policy (this “Policy”) describes how Aurean Technologies, Inc., a Texas corporation (“Aurean”, “we”, “us”, or “our”), collects, uses, discloses, and otherwise processes personal data about users of our websites, mobile applications, and software-as-a-service offerings that provide trade-related insights and related services (collectively, the “Services”). As used in this Policy, “personal data” has the meaning given to it under the Texas Data Privacy and Security Act (“TDPSA”). This Policy applies to data we collect through the Services, as well as data we receive in connection with marketing, customer support, and other business activities.

Our Services are intended for users who are eighteen (18) years of age or older. This Policy describes how we collect, use, and disclose personal data in connection with the Services.

1. Information We Collect

We collect the categories of personal data described below from and about our users, prospective users, and individuals identified by our users (for example, beneficiaries, joint account holders, or other persons whose data our users provide to us). The specific data we collect depends on how you interact with us and the Services.

1.1 Identity and Contact Information

Name;
Date of birth and/or age;
Gender;
Home or mailing address;
Telephone number;
Email address; and
Photographs that you upload or otherwise provide (for example, profile images).

1.2 Financial and Trading Information

Bank account details (such as account and routing numbers) provided to facilitate funding or payments;
Payment card information (such as card number, expiration date, and security code) processed through our payment processor;
Brokerage and trade-related data, including transaction history, holdings, order activity, and related account information that you authorize us, or a connected third party, to access for purposes of providing trade insights;
Billing records and transaction history with us.

1.3 Online Identifiers and Device/Usage Information

Internet Protocol (IP) address;
Cookie identifiers, pixel tags, software development kit (SDK) identifiers, and similar tracking data;
Application usage data, such as features accessed, pages viewed, interactions, session duration, and time/date of access; and
Social media handles you provide or that we obtain from social-sign-on or similar integrations.

1.4 Communications

The content and subject of messages, support requests, chat sessions, and other communications you direct to or through us; and
Information you provide in connection with surveys, promotions, feedback, or testimonials.

1.5 Information About Third Parties That You Provide

If you provide personal data about other individuals to us (for example, when you submit information about a co-account holder, beneficiary, or other person), you represent that you have the legal authority to do so and to permit us to process that data consistent with this Policy.

1.6 Sensitive Information

We do not seek to collect categories of “sensitive” personal data such as racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, precise geolocation, or data about children. If you choose to provide such data voluntarily (for example, in free-text fields), please do so only to the extent reasonably necessary.

2. Sources of Personal data

We obtain personal data from the following sources:

Directly from you, when you create an account, complete forms, communicate with us, upload content, or otherwise use the Services;
Automatically, from the devices, browsers, and applications you use to access the Services, including through cookies, pixels, SDKs, and similar technologies;
From third-party data sources, including brokerage and financial data providers that you authorize us or our service providers to access in order to deliver trade-related insights as part of our SaaS offering; and
From our service providers and business partners, such as analytics, payment, communications, and infrastructure providers that help us operate the Services.

3. How We Use Personal data

We use personal data for the following business and commercial purposes:

3.1 To Provide and Operate the Services

To create and administer user accounts and verify identity;
To deliver the Services, including providing trade-related insights, analytics, and recommendations using brokerage trade data and other inputs;
To process payments, manage billing, and maintain transaction records;
To provide customer support and respond to requests, questions, and feedback;
To send service-related communications, including confirmations, security alerts, technical notices, updates, and administrative messages.

3.2 To Improve, Personalize, and Develop the Services

To perform analytics, measure usage, troubleshoot issues, and evaluate the performance of the Services;
To personalize user experiences, including customizing content, recommendations, and insights;
To develop, test, and improve existing and new products, features, and offerings; and
To conduct research, including aggregating or de-identifying personal data for analytical purposes.

3.3 For Marketing and Communications

To send marketing and promotional communications about Aurean and our Services, where permitted by applicable law;
To conduct advertising activities, including measuring the effectiveness of our marketing campaigns; and
To invite you to participate in surveys, events, or other engagement opportunities.

You may opt out of marketing emails at any time using the “unsubscribe” link in such emails or by contacting us as described in the “How to Contact Us” section.

3.4 For Legal, Compliance, and Protection Purposes

To comply with applicable laws, regulations, court orders, subpoenas, and lawful requests from government authorities;
To enforce our Terms of Service and other agreements, and to protect the rights, property, or safety of Aurean, our users, or others;
To detect, investigate, prevent, and respond to fraud, security incidents, unauthorized activity, or other harmful or illegal activity; and
To establish, exercise, or defend legal claims.

3.5 For Business Transactions

To evaluate, negotiate, and complete a corporate transaction, including a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of services to another provider.

We do not sell personal data. We also do not process personal data for purposes of targeted advertising, except as expressly disclosed in this Policy. We may disclose personal data in the following circumstances:

4.1 Service Providers and Processors

We share personal data with vendors, contractors, and service providers that perform services on our behalf and that are contractually obligated to use the data only for the purposes for which we engage them. These categories include, without limitation:

Cloud hosting, storage, and infrastructure providers;
Brokerage and financial data aggregators that supply trade data used to deliver our insights;
Payment processors and billing platforms;
Analytics, performance monitoring, and product analytics providers;
Email, messaging, and customer support platforms;
Marketing, advertising, and communications platforms;
Identity verification, fraud prevention, and security providers; and
Professional advisors, including legal, accounting, audit, insurance, and consulting professionals.

4.2 Affiliates

We may share personal data with our parent, subsidiaries, and other affiliated entities (if any), for the purposes described in this Policy and subject to safeguards consistent with those described in Section 7. If we create or acquire affiliated entities that receive personal data under this provision, we will update this Policy accordingly.

4.3 Legal and Safety Disclosures

We may disclose personal data to government agencies, regulators, courts, law enforcement, or other third parties when we believe in good faith that disclosure is necessary to: (a) comply with applicable law or legal process; (b) respond to subpoenas, warrants, or court orders; (c) protect the rights, property, or safety of Aurean, our users, or others; (d) enforce our agreements or policies; or (e) detect, investigate, prevent, or respond to fraud, security incidents, or other unlawful activity.

4.4 Business Transfers

In connection with, or during negotiations of, any merger, acquisition, financing, sale of all or a portion of our business or assets, reorganization, bankruptcy, or similar corporate transaction, we may transfer personal data to the counterparty (and its advisors), subject to customary confidentiality protections.

We may share personal data with other third parties when you direct us to do so or otherwise consent to the sharing (for example, when you connect a third-party brokerage account to the Services or use a social-sign-on feature).

4.6 Aggregated or De-Identified Information

We may use, disclose, and otherwise process aggregated, anonymized, or de-identified data for any lawful purpose. Such data is not personal data when it cannot reasonably be linked to an identified or identifiable individual.

5. Cookies and Similar Technologies

We and our service providers use cookies, pixels, web beacons, SDKs, and similar tracking technologies (collectively, “Cookies”) on our website and within our applications to:

Enable essential functionality, such as authentication, security, and load balancing;
Remember user preferences and settings;
Analyze how the Services are used, including traffic patterns and feature engagement; and
Support our marketing and communications activities, including measuring campaign performance.

Most browsers allow you to manage Cookies through their settings (for example, to block or delete certain Cookies). Some Cookies are necessary for the Services to function properly, and disabling them may affect your ability to use certain features.

Do Not Track. Some browsers offer a “Do Not Track” (“DNT”) signal. Because no common industry standard for responding to DNT signals has been adopted, we currently do not respond to DNT signals. We do, however, honor recognized opt-out preference signals (such as the Global Privacy Control, https://globalprivacycontrol.org/) as required by applicable law.

6. Data Retention

We retain personal data for as long as reasonably necessary to fulfill the purposes described in this Policy, including to: (i) provide the Services to you; (ii) maintain business and financial records; (iii) comply with our legal, tax, accounting, audit, and regulatory obligations; (iv) resolve disputes; (v) enforce our agreements; and (vi) protect our and others’ rights and interests.

Where personal data is no longer needed for these purposes, we will delete, anonymize, or otherwise dispose of it in accordance with our retention practices and applicable law. Some data may be retained for longer periods where required by law or where it is necessary to meet ongoing legal or regulatory obligations.

7. Data Security

We maintain reasonable administrative, technical, organizational, and physical safeguards designed to protect personal data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. These safeguards are appropriate to the nature and sensitivity of the personal data we process and are regularly reviewed and updated.

Despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security. If you have reason to believe your interaction with us is no longer secure, please contact us immediately as described in the “How to Contact Us” section.

8. Children’s Privacy

The Services are not directed to, and are not intended to be used by, individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we learn that we have collected personal data from a child under 18 without verified parental consent (where required by law), we will take reasonable steps to delete that data. If you believe a child under 18 has provided us with personal data, please contact us as described in the “How to Contact Us” section.

9. Your Privacy Rights and Choices

Under applicable law, you have certain rights with respect to your personal data. We honor the rights described below to the extent required by applicable law.

9.1 Right to Know / Access

You may request confirmation of whether we process personal data about you, and to obtain a copy of, or specified categories of, the personal data we maintain about you.

9.2 Right to Correct

You may request that we correct inaccurate personal data that we maintain about you, taking into account the nature of the data and the purposes of the processing.

9.3 Right to Delete

You may request that we delete personal data that we have collected from you, subject to certain legal exceptions.

9.4 Right to Data Portability

You may request a copy of certain personal data you provided to us in a portable, machine-readable format.

9.5 Right to Opt Out of Targeted Advertising, Sale, and Profiling

You may opt out of (a) the processing of your personal data for purposes of targeted advertising, (b) the sale of your personal data, and (c) profiling in furtherance of decisions that produce legal or similarly significant effects. As described in Section 4, we do not currently sell personal data or process personal data for targeted advertising.

9.6 Right to Non-Discrimination

We will not unlawfully discriminate against or retaliate against you for exercising any of your privacy rights. This means we will not deny you Services, charge you different prices, or provide a different level or quality of Services solely because you exercised your rights, except as permitted by law.

9.7 How to Submit a Request

To exercise any of the rights described above, please submit a verifiable request using one of the methods listed in the “How to Contact Us” section. We may need to verify your identity before processing your request, which may involve asking you to provide information that matches what we have on file. We will respond to verifiable requests within the time period required by applicable law (generally 45 days, subject to extension where permitted).

You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of authorization and may require you to verify your own identity directly with us.

10. State-Specific Disclosures

This section provides additional disclosures required under the TDPSA. To the extent of any conflict between this section and the rest of this Policy, this section controls for Texas residents.

If you are a Texas resident, the TDPSA provides you with the following rights (subject to certain limitations and exceptions):

To confirm whether we process your personal data and to access such personal data;
To correct inaccuracies in your personal data;
To delete personal data we have collected about you;
To obtain a portable copy of personal data you provided to us; and
To opt out of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise these rights, please contact us using the contact information in Section 13. If we deny your request, you may appeal that decision by submitting a written appeal to us as described in Section 13. If your appeal is denied, you may contact the Texas Attorney General to submit a complaint at https://consumerprotection.texasattorneygeneral.gov/.

11. Third-Party Websites and Services

The Services may include links to, or be accessed through, websites, applications, or services operated by third parties (including brokerage providers and other partners). This Policy does not apply to those third parties’ data practices. We encourage you to review the privacy policies and terms of any third-party services you use.

12. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this Policy. If we make material changes, we will provide reasonable notice prior to the change taking effect, such as by posting a prominent notice on the Services or sending a notification through other appropriate channels. We encourage you to review this Policy periodically.

13. How to Contact Us

If you have any questions about this Policy or our privacy practices, or to submit a privacy rights request or appeal, please contact us using the information below.

Email vijay@aurean.ai