Privacy Policy & Data Protection

This Privacy Policy and Data Protection describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Data Protection and Privacy Policy.

Interpretation and Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Business refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Raitis Alferovs, trading as pipz, Am Römischen Hof 13, 61352 Bad Homburg, Germany.
• Consumer means a natural person.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website and Application, pipz, accessible from pipz.ai and its subdomains and related apps.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Personal Data. While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Address, State, Province, ZIP/Postal code, City
• Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication.
• To provide You with news, special offers and general information about other goods, services and events, unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Data Protection and Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Data Protection and Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Data Protection and Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions. If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Data Protection and Privacy Policy.

Law enforcement. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Service Providers and Recipients of Your Data

We do not sell Your Personal Data and We do not use it for advertising. To run the Service We do, however, rely on a small number of service providers. Each of them receives only the data listed below; where a provider processes data on Our behalf, a data processing agreement under Art. 28 GDPR is in place. The following list is complete.

Railway Corp., San Francisco, USA — hosting of the application and of the database. Railway stores every piece of account data described in this policy: your name, email address, password hash, subscription state, connected trading accounts and log entries. Our servers and the database currently run in Railway's us-west2 region in the United States, which means Your data is stored outside the European Economic Area. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Stripe Payments Europe, Ltd., Dublin, Ireland, together with Stripe, Inc., USA — payment processing and subscription management. Stripe receives your name, email address and billing details. Your card data is collected by Stripe directly: card numbers are entered on Stripe's own payment page and never reach Our servers. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

MetaCopier (metacopier.io) — the copy trading infrastructure that mirrors trades onto your trading account. When You connect a trading account, We transmit its server name, its account number and the password You provide for it, and We receive the resulting trade and position data back. Without this transfer the Service cannot be provided. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Telegram — support channel. Data reaches Telegram only if You choose to write to Us there. In that case Telegram processes your message, your Telegram user name and, depending on your own privacy settings, further profile data; Telegram's own privacy policy applies. Legal basis: performance of the contract and Our legitimate interest in providing support (Art. 6(1)(b) and (f) GDPR).

Apple Inc., Cupertino, USA — distribution of the iOS app. If You install the app through the App Store, Apple processes the download and, where applicable, the purchase data connected to your Apple Account. We receive aggregated statistics from Apple only, never your Apple Account details. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Partner brokers. Opening an account with a partner broker happens on the broker's own website, which You reach through a referral link. From that point the broker is the controller of your data under its own privacy policy, and it reports back to Us that an account was opened through Our link. We never receive your broker login credentials from the broker.

Have I Been Pwned (haveibeenpwned.com) — check against known leaked passwords when You choose a password. Only the first five characters of the SHA-1 hash of the password are transmitted — never the password itself and nothing that identifies You. Legal basis: Our legitimate interest in account security (Art. 6(1)(f) GDPR).

Myfxbook — the performance figures and charts shown for each trading system. These are fetched by Our server, not by your browser or the app. No data about You is transmitted to Myfxbook and it sets no cookies on your device.

Because Railway, Stripe, Apple and Telegram process data outside the European Economic Area, those transfers are based on the European Commission's Standard Contractual Clauses or an equivalent safeguard agreed with the provider. You may request a copy of the relevant safeguards from Us using the contact details at the end of this policy.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR. We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under the GDPR. The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Data Protection and Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data
• Request correction of Your Personal Data
• Request erasure of Your Personal Data
• Object to processing of Your Personal Data
• Request restriction of processing Your Personal Data
• Request transfer of Your Personal Data
• Withdraw Your consent

To exercise any of these rights, please contact us at ra.alferovs@gmail.com.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Cookies

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. We use both session and persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies (Session Cookies, administered by Us): essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.
• Cookies Policy / Notice Acceptance Cookies (Persistent Cookies, administered by Us): identify if users have accepted the use of cookies on the Website.
• Functionality Cookies (Persistent Cookies, administered by Us): allow us to remember choices You make when You use the Website, such as remembering your login details or language preference.

Your Choices Regarding Cookies. If You prefer to avoid the use of Cookies on the Website, first You must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. If You do not accept Our Cookies, You may experience some inconvenience in your use of the Website and some features may not function properly.

Additional Privacy Rights

Among other rights, you have the right to:

• Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
• Request that a business delete any personal data about the consumer that a business has collected.
• Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at ra.alferovs@gmail.com.

Contact Us

If you have any questions about this Privacy Policy, You can contact us at ra.alferovs@gmail.com.