Privacy Policy

The data controller for personal information collected through AlphaFind is Phronesis Technologies Limited, incorporated in New Zealand (NZBN: [to be confirmed]), trading as AlphaFind.

This Privacy Policy is made in accordance with the New Zealand Privacy Act 2020. We also comply with applicable data protection requirements for users in the UK, EU, Australia, and other jurisdictions where we operate, as described in the relevant sections below.

For privacy-related enquiries, contact us at: [email protected]

• Account information: name, email address, password (hashed);
• Profile information: display name, biography, professional background (optional);
• Billing information: handled by our payment processor — we receive only a tokenised payment reference and billing address;
• Communications: support enquiries, feedback, community posts, forum messages, and any correspondence with us.

• Usage data: features accessed, strategies created, backtest runs, pages viewed, time spent on features;
• Technical data: IP address, browser type and version, operating system, device identifiers, referring URLs;
• Log data: access logs, error logs, and API request logs for security and performance purposes;
• Cookies and similar technologies: see Section 11.

• If you connect a broker account or third-party service, we receive the technical data necessary to establish that connection — we do not receive or store your broker login credentials;
• If you sign up via a social login (e.g. Google), we receive basic profile information (name, email) from that provider per their data sharing settings.

We do not use your personal information to make automated decisions that produce legal or similarly significant effects on you without human review.

We do not sell your personal information. We share it only in the following circumstances:

We use trusted third-party providers to operate the platform, including cloud hosting, payment processing, analytics, and email delivery. These providers process data only on our instructions and are contractually required to protect it.

Information you choose to make public — such as forum posts, shared strategies, challenge leaderboard entries, or your public profile — is visible to other users of the platform.

We may disclose your information where required by law, court order, or regulatory authority, or where we believe in good faith that disclosure is necessary to protect the safety of any person or to prevent fraud or illegal activity.

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a materially different privacy policy.

We retain your personal information for as long as your account is active or as needed to provide the service. Specifically:

• Account data: retained for the duration of your account and for up to 3 years after closure, for legal and dispute resolution purposes;
• Billing records: retained for 7 years as required by applicable financial and tax regulations;
• Usage and log data: typically retained for 12–24 months for security and performance analysis;
• Marketing preferences: retained until you withdraw consent or close your account.

When data is no longer required, it is securely deleted or anonymised.

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit and at rest, access controls, and regular security reviews.

In the event of a privacy breach that poses a risk of serious harm, we will notify affected individuals and the Office of the Privacy Commissioner (NZ) in accordance with the mandatory notification requirements of the Privacy Act 2020.

Under the New Zealand Privacy Act 2020, you have the right to:

• Access the personal information we hold about you;
• Correct personal information that is inaccurate, incomplete, or misleading;
• Request deletion of your personal information, subject to our legal retention obligations.

To exercise these rights, contact us at [email protected]. We will respond within 20 working days. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner at www.privacy.org.nz.

If you are located in the United Kingdom or European Economic Area, you have additional rights under the UK GDPR / EU GDPR:

• Right to erasure ("right to be forgotten") — request deletion of your data in certain circumstances;
• Right to data portability — receive your data in a structured, machine-readable format;
• Right to restriction — request that we restrict processing of your data in certain circumstances;
• Right to object — object to processing based on legitimate interests or for direct marketing; and
• Right not to be subject to automated decision-making — we do not use solely automated decision-making to make decisions with significant effects on you.

You have the right to lodge a complaint with your local supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

If you are located in Australia, your personal information is also handled in accordance with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs). You have the right to access and correct your personal information, and to make a complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au if you believe we have not handled your data appropriately.

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the "sale" or "sharing" of personal information. We do not sell or share your personal information for cross-context behavioural advertising. To exercise your rights, contact us at [email protected].

We use cookies and similar technologies to operate the platform, remember your preferences, analyse usage, and (with your consent) deliver relevant content. For full details, see our Cookie Policy. You can manage your cookie preferences at any time via the cookie settings link in the footer.

AlphaFind is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us at [email protected] and we will delete it promptly.

As a platform serving users globally, your personal information may be stored and processed in countries outside your country of residence — including New Zealand, the United States, and other countries where our service providers operate. We take steps to ensure that cross-border transfers meet applicable legal standards, including the New Zealand Privacy Act 2020's requirements for overseas disclosure and, where required, GDPR-compliant transfer mechanisms such as Standard Contractual Clauses.

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email or by prominent notice within the platform. The "last updated" date at the top of this page reflects the most recent revision. Continued use of AlphaFind following notice of changes constitutes your acceptance of the updated policy.

For any privacy enquiries, access requests, or complaints, please contact:

• Email: [email protected]
• Entity: Phronesis Technologies Limited, trading as AlphaFind, New Zealand

We aim to respond to all privacy enquiries within 10 working days. If you are not satisfied with our response, you may contact the relevant supervisory authority in your jurisdiction (see Sections 7–10 above).