MakeCents.ai Privacy Policy

This Privacy Policy describes how we collect, use, disclose, and protect your information when you access or use the MakeCents.ai website, applications, APIs, and related services (collectively, the "Service"). This Policy is incorporated into and forms part of our Terms of Use (the "Terms"). Capitalized terms not defined herein have the meanings given in the Terms. By using the Service, you consent to the practices described in this Policy. If you do not agree, do not use the Service.

We may update this Policy from time to time. Material changes will be notified via the Service, email, or a prominent notice on our website. Continued use after changes constitutes acceptance. For users in the European Union ("EU") or European Economic Area ("EEA") (collectively, "EU Users"), this Policy complies with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and is supplemented by the EU/EEA-Specific Addendum to the Terms.

1. Information We Collect

   We collect information to provide, improve, and secure the Service. This includes:

   a) Information You Provide Directly:

   • Account Information: When you create an account, we collect your email address, username, password, and any other details you provide (e.g., preferences or settings).
   • User Content: Text, prompts, code, strategies, configurations, and other inputs you submit (as defined in the Terms).
   • Broker/Exchange Integrations: If you connect accounts (e.g., via Alpaca Markets), we may access account information, positions, balances, and trade instructions with your authorization. We do not store sensitive financial details like full account numbers.
   • Communications: Information from emails, support requests, or feedback you send us.
   • Payment Information: Billing details (e.g., payment method) processed through secure third-party providers; we do not store full card details.
   b) Automatically Collected Information:

   • Usage Data: Device information (e.g., IP address, browser type, OS), access times, pages viewed, interactions with features (e.g., automation triggers, token usage via the Token Counter), and error logs.
   • Cookies and Similar Technologies: We use cookies, web beacons, and analytics tools for functionality, performance, and targeted features. Essential cookies enable core Service functions; analytics cookies track usage (e.g., via Google Analytics). You can manage preferences via browser settings or our cookie banner.
   • Location Data: Inferred from IP address for compliance (e.g., export controls), but not precise geolocation unless you enable it.
   c) Information from Third Parties:

   • AI Model Providers: Outputs from providers like OpenAI, xAI, Anthropic, and Google based on your inputs.
   • Broker/Data Providers: Market data, account details from Alpaca or others you connect.
   • Aggregated Data: De-identified insights from analytics partners.

   We do not collect sensitive personal data (e.g., racial/ethnic origin, health data) unless inadvertently included in User Content, which you must not submit (per the Terms).

2. How We Use Your Information

   We use your information for legitimate business purposes, including:

   • Providing the Service: Process prompts, generate outputs, enable integrations, automate trades (with your consent), and bill via token usage.
   • Improving and Personalizing: Analyze usage to enhance features, debug issues, and suggest improvements (using de-identified data where possible).
   • Security and Compliance: Detect fraud, enforce Terms, monitor for prohibited uses, and comply with laws (e.g., export controls, sanctions).
   • Communications: Send service updates, notifications (e.g., security incidents), renewal reminders, or marketing (with opt-out options).
   • Research and Analytics: Aggregate data for internal insights; no individual profiling without consent.
   • Legal Obligations: Respond to subpoenas, audits, or regulatory requests.

   For EU Users, processing is based on GDPR lawful grounds: contract performance (e.g., providing the Service), consent (e.g., marketing), legitimate interests (e.g., security, balanced against your rights), or legal obligations.

3. Sharing Your Information

   We share information only as necessary and with safeguards:

   a) With Service Providers:

   Third parties helping us operate (e.g., cloud hosting like AWS, analytics like Google, payment processors like Stripe). They are bound by confidentiality and data protection agreements.

   b) AI Model Providers:

   As described in the Terms (Section 7A), we transmit prompts, configurations, and inputs to OpenAI, xAI, Anthropic, Google, or others for processing. These providers handle data under their policies; we use modes limiting training where available but cannot guarantee confidentiality.

   c) Broker/Exchange Partners:

   Trade instructions and account data to Alpaca or connected providers, per your authorization.

   d) Aggregated/De-Identified Data:

   Shared for research or analytics without identifying you.

   e) Business Transfers:

   In mergers, acquisitions, or asset sales, subject to confidentiality.

   f) Legal Requirements:

   If required by law, court order, or to protect rights/safety.

   We do not sell your personal data. For CCPA-eligible California residents, "sharing" for targeted advertising may occur via cookies; opt-out via our "Do Not Sell/Share My Personal Information" link.

4. Data Security

   We implement commercially reasonable safeguards, including encryption (in transit/at rest), access controls, secure key vaults, vendor reviews, and adherence to standards like SOC 2 Type II (where applicable). We conduct regular audits and risk assessments. However, no system is impenetrable; you must protect your credentials (per Terms Section 9). In case of a Security Incident, we notify affected users promptly (per Terms Section 10 and GDPR Article 34 for EU Users).

5. Your Rights and Choices

   You have control over your data:

   • Access/Update/Delete: Log in to view/edit account info; request deletion via legal@makecents.ai.
   • Opt-Outs: From marketing emails (unsubscribe link), model-training use (account settings, per Terms Section 8), or cookies (banner/settings).
   • Do Not Track: We honor browser DNT signals for analytics.
   • California Rights (CCPA/CPRA): Access, delete, correct, opt-out of sales/sharing, limit sensitive data use. Submit requests via legal@makecents.ai; we respond within 45 days (extendable).
   • Nevada Rights: Opt-out of sales (though we do not sell data).

   For EU Users (per GDPR and Addendum Section 2):

   • Rights: Access, rectification, erasure, restriction, portability, objection, and against automated decisions.
   • Withdraw Consent: Anytime, without affecting prior processing.
   • Complaints: To your supervisory authority (e.g., via https://edpb.europa.eu/about-edpb/about-edpb/members_en).
   • Requests: Free, responded to within one month; identity verification required.

6. International Data Transfers

   As a U.S.-based company, data may transfer outside your jurisdiction. For EU Users, transfers use GDPR safeguards like Standard Contractual Clauses (SCCs) or adequacy decisions. We ensure equivalent protections with recipients (e.g., AI providers).

7. Children's Privacy

   The Service is not for children under 13 (or 16 in EEA). We do not knowingly collect data from minors; if discovered, we delete it. Parental consent is required for EEA users under 16 (per GDPR Article 8 and Terms Section 2).

8. Data Retention

   We retain data as needed for the Service, legal obligations, or disputes (e.g., account info until deletion request; logs for 1 year). De-identified data may be kept indefinitely. Upon deletion, we erase or anonymize within 30 days, subject to backups.

9. Changes to This Policy

   We post updates here with the revised effective date. For material changes affecting your rights, we provide advance notice.

10. Contact Us

    For questions or requests: legal@makecents.ai. For EU Users, contact our EU Representative: Include Name and Contact Details of your EU Representative or DPO and write to legal@makecents.ai.

This Policy complements the Terms and does not create additional rights beyond applicable law.