PRIVACY POLICY

1. Introduction

At STKtracker LLC ("STKtracker", "we"), we are committed to protecting the privacy of our users. This Privacy Policy describes how we collect, use, store, and protect personal information when you use our investment analysis platform.

By registering or using STKtracker, you agree to the practices described in this policy. If you do not agree, please do not use our services.

2. Data We Collect

We collect the following categories of information:

• Registration data: name, last name, email address, and encrypted password.
• Profile data: preferred language, time zone, and display preferences.
• Portfolio data: investment positions, watchlists, column configurations, and saved analyses.
• Broker connection data: tokenized SnapTrade credentials (we never store direct access credentials to your brokerage account).
• Usage data: pages visited, features used, access frequency, and device type.
• Payment data: managed entirely by Stripe. We do not store card numbers or bank details.

3. How We Use Data

We use your personal information exclusively for:

• Providing you access to the platform and its analysis features.
• Managing your account, subscription, and preferences.
• Syncing portfolio data with your broker via SnapTrade.
• Sending essential service communications (email verification, account alerts).
• Improving and optimizing the platform through aggregated and anonymized analytics.
• Complying with applicable legal and tax obligations.

4. Legal Basis for Processing (GDPR)

The processing of your data is based on:

• Contract performance: necessary to provide you the service you have contracted.
• Consent: granted when accepting this policy and the disclaimer during registration.
• Legitimate interest: service improvement and fraud prevention.
• Legal obligation: compliance with tax and commercial regulations.

5. Data Sharing

We do not sell, rent, or share your personal information with third parties for marketing purposes. We only share data with:

• Stripe: payment processing and subscription management.
• SnapTrade: portfolio data synchronization with your broker (only if you connect a broker).
• Financial data providers: market data queries (only ticker symbols are sent, never personal data).
• Infrastructure providers: hosting and databases, subject to confidentiality agreements.

6. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Passwords encrypted with bcrypt (one-way hash).
• HTTPS connections across the entire platform.
• Session tokens with automatic expiration.
• Database access restricted by IP and encrypted credentials.
• Mandatory email verification to activate accounts.

7. Data Retention

We retain your data as long as your account is active. If you request account closure, your data will be marked for deletion with a 30-day grace period during which you can reactivate your account. After that period, your personal data will be permanently deleted.

Anonymized and aggregated data may be retained indefinitely for statistical purposes.

8. Your Rights

As a user, you have the right to:

• Access: request a copy of your personal data.
• Rectification: correct inaccurate or incomplete data.
• Erasure: request deletion of your account and personal data.
• Portability: receive your data in a structured, machine-readable format.
• Objection: object to processing based on legitimate interest.
• Restriction: request restriction of processing in certain circumstances.

9. Cookies and Tracking Technologies

STKtracker uses strictly necessary cookies for service operation (authentication session, language and theme preferences). These require no consent because they are essential to provide the service.

With your prior, explicit consent, we also use optional cookies in two categories, which you can accept, reject or configure granularly in the banner shown on your first visit:

• Analytics (Google Analytics 4): to understand which features are used most and fix issues. Internal use only.
• Measurement (Google Ads): to measure and analyze how you found us and the effectiveness of our campaigns. No personal data is shared or used to sell you other products. Internal use only.
• None of these cookies activate until you give consent. Until then, we apply Google Consent Mode, which stores no identifiers on your device.
• You can change or withdraw your consent anytime via the "Cookie preferences" link in the footer.
• We never sell your data or share it with third parties for purposes unrelated to internal service improvement.

10. International Transfers

STKtracker LLC is incorporated in Wyoming, United States. Your data may be processed on servers located in the United States. If you reside in the European Economic Area (EEA), these transfers are covered by the Standard Contractual Clauses approved by the European Commission.

11. Contact

To exercise your rights or resolve questions about this policy, you can contact us at:

STKtracker LLC — 30 N Gould St, STE R, Sheridan, WY 82801, USA

Email: [email protected]

12. Changes

We reserve the right to update this Privacy Policy at any time. Substantial modifications will be notified to registered users with a minimum of fifteen (15) calendar days' notice via email or a prominent notice on the platform. The current version will always be available on this page with the update date.

Continued use of the platform after publication of changes constitutes acceptance of the modified policy, subject to mandatory local regulations for EU consumers.