Privacy Policy

This Privacy Policy ("Policy") describes how Intra Capital Ventures LLC, doing business as IntraAlpha ("IntraAlpha," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information when you access or use the IntraAlpha website located at intraalpha.com and all related services, applications, tools, application programming interfaces ("APIs"), and features (collectively, the "Service"). This Policy also describes your rights and choices regarding your personal information.

By accessing or using the Service, you acknowledge that you have read, understood, and agree to the practices described in this Policy. If you do not agree with this Policy, you must not use the Service. This Policy is incorporated into and forms part of our Terms of Service.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

We collect information that you voluntarily provide to us, including:

(a) Account Registration Data: When you create an account, we collect your email address and any other information you provide during the registration process.

(b) Profile Information: Any additional information you choose to add to your account profile.

(c) Payment Information: When you subscribe to a paid plan, payment processing is handled entirely by our third-party payment processor, Stripe, Inc. ("Stripe"). Your payment card details are collected and processed directly by Stripe and are never transmitted to or stored on IntraAlpha's servers. We receive from Stripe only a transaction identifier, subscription status, and billing metadata (such as plan type and billing period) necessary to manage your subscription.

(d) Communications: Information you provide when you contact us for support, submit feedback, report a problem, or otherwise communicate with us.

(e) User-Generated Content: Content you post, submit, or transmit through community features, including comments, trade ideas, trade cards, and discussion forum posts.

1.2 Information from Third-Party Services

(a) Social Login Data: If you register or sign in using a third-party social media account (such as Facebook, X/Twitter, or Google), we receive certain information from that provider, which may include your name, email address, profile picture, and a unique account identifier. The specific information shared depends on your privacy settings with the social media provider and their API. We do not receive or store your social media password.

(b) Brokerage Data: If you choose to connect a third-party brokerage account (such as Fidelity, Wealthfront, or Robinhood), we collect and process the brokerage data you authorize us to import, which may include positions, orders, fills, trade history, account balances, and related transaction data ("Brokerage Data"). This data is collected solely at your direction and is used only to provide the Service to you.

1.3 Information Collected Automatically

When you access or use the Service, we automatically collect certain information, including:

(a) Device and Browser Information: IP address, browser type and version, operating system, device type, device identifiers, screen resolution, and language preferences.

(b) Usage Data: Pages visited, features used, links clicked, search queries within the Service, time spent on pages, referring URLs, and interaction patterns.

(c) Log Data: Server logs that record requests made to our servers, including timestamps, request URLs, response codes, and related technical data.

(d) Location Data: Approximate geographic location inferred from your IP address. We do not collect precise geolocation data.

(e) Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies as described in Section 6 below.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

(a) Providing and Maintaining the Service: To operate, maintain, and improve the Service; to process your transactions and manage your subscription; to authenticate your identity; and to provide customer support.

(b) Personalization: To personalize your experience, including displaying relevant content, customizing features, and remembering your preferences and settings.

(c) Analytics and Improvement: To analyze usage patterns, monitor performance, diagnose technical issues, and improve the functionality, content, and user experience of the Service.

(d) Communications: To send you transactional communications (such as account confirmations, billing notifications, and security alerts), respond to your inquiries, and provide customer support.

(e) Advertising and Marketing: To deliver targeted advertisements, promotional materials, and marketing communications; to measure the effectiveness of advertising campaigns; to conduct retargeting across third-party platforms; and to manage affiliate marketing relationships. You may opt out of marketing communications at any time by following the unsubscribe instructions in any marketing email or by contacting us at info@intraalpha.com.

(f) Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized access, and other illegal or harmful activities; to protect the rights, property, and safety of IntraAlpha, our users, and the public.

(g) Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.

(h) Aggregated and De-Identified Data: To create aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you, which we may use for any lawful purpose, including research, analytics, product development, and marketing.

3. LEGAL BASES FOR PROCESSING (EEA/UK USERS)

If you are located in the European Economic Area ("EEA") or the United Kingdom ("UK"), we process your personal data on the following legal bases:

(a) Contract: Processing necessary for the performance of our contract with you (the Terms of Service), including providing the Service, managing your account, and processing payments.

(b) Legitimate Interests: Processing necessary for our legitimate interests or those of a third party, where such interests are not overridden by your data protection rights, including analytics, fraud prevention, security, and product improvement.

(c) Consent: Processing based on your consent, such as for certain marketing communications and non-essential cookies. You may withdraw your consent at any time.

(d) Legal Obligation: Processing necessary for compliance with a legal obligation to which we are subject.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information in the traditional sense. We may share your information in the following circumstances:

(a) Service Providers and Processors: We share personal information with third-party service providers who perform services on our behalf, subject to contractual obligations to protect your data. These include:

• Stripe, Inc. — Payment processing

• Twilio SendGrid — Transactional and marketing email delivery

• Cloudflare, Inc. — Content delivery, edge computing, security, and DDoS protection

• Google Cloud Platform — Cloud infrastructure, data storage, and archival

• Market Data Providers (such as Alpha Vantage, Alpaca Markets, and ThetaData) — Equity, options, and market data services

(b) Advertising and Marketing Partners: We share certain information (such as device identifiers, cookie data, hashed email addresses, and usage data) with advertising networks, affiliate marketing partners, and retargeting platforms for the purpose of delivering targeted advertisements and measuring advertising effectiveness. This sharing may constitute a "sale" or "sharing" of personal information under the California Consumer Privacy Act ("CCPA"), as described in Section 15.

(c) Business Transfers: In connection with a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will notify you via email or prominent notice on the Service of any such change in ownership or use of your personal information.

(d) Legal Requirements: We may disclose your personal information if required to do so by law or in the good-faith belief that such disclosure is necessary to: comply with a legal obligation, court order, or legal process; protect and defend the rights, property, or safety of IntraAlpha, our users, or the public; or detect, prevent, or address fraud, security, or technical issues.

(e) With Your Consent: We may share your personal information for any other purpose with your prior consent.

5. DATA SECURITY

We implement commercially reasonable administrative, technical, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security assessments. However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, and you provide your information at your own risk.

6. COOKIES AND TRACKING TECHNOLOGIES

6.1 Essential Cookies

These cookies are strictly necessary for the operation of the Service. They enable core functionality such as user authentication, session management, security features, and load balancing. Essential cookies cannot be disabled without impairing the functionality of the Service.

6.2 Analytics and Performance Cookies

These cookies collect information about how you use the Service, including which pages you visit, how long you spend on pages, and any errors you encounter. We use this information to monitor and improve the performance and functionality of the Service. Analytics cookies may be provided by third-party analytics services.

6.3 Advertising and Targeting Cookies

These cookies are used to deliver advertisements that are relevant to you and your interests. They may be placed by advertising networks, affiliate marketing platforms, and retargeting services with which we partner. These cookies track your browsing activity across websites and may be used to build a profile of your interests and show you relevant advertisements on other sites. You may opt out of targeted advertising through the following mechanisms:

• Digital Advertising Alliance (DAA): https://optout.aboutads.info

• Network Advertising Initiative (NAI): https://optout.networkadvertising.org

• Your browser's cookie settings and "Do Not Track" preferences

6.4 Functional Cookies

These cookies enable enhanced functionality and personalization, such as remembering your preferences, display settings, and watchlist configurations. If you disable functional cookies, some features of the Service may not function as intended.

6.5 Managing Cookies

Most web browsers allow you to manage your cookie preferences through browser settings. You can set your browser to refuse cookies or to alert you when cookies are being set. Please note that disabling cookies may affect the functionality of the Service. For more information about cookies, visit www.allaboutcookies.org.

7. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. The following table summarizes our general retention periods:

When personal information is no longer needed for the purposes for which it was collected, we will securely delete or anonymize it. Anonymized data may be retained indefinitely for analytical and statistical purposes.

8. CHILDREN'S PRIVACY

The Service is not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to promptly delete such information. If you believe we may have collected information from a child under 18, please contact us at info@intraalpha.com.

9. DATA BREACH NOTIFICATION

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, we will: (a) notify the relevant supervisory authority within seventy-two (72) hours of becoming aware of the breach, where required by the General Data Protection Regulation ("GDPR") or other applicable law; and (b) notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms. We will also comply with all applicable U.S. state data breach notification laws, including those of Oregon and California.

10. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal information:

(a) Access: The right to request a copy of the personal information we hold about you.

(b) Correction: The right to request correction of inaccurate or incomplete personal information.

(c) Deletion: The right to request deletion of your personal information, subject to certain legal exceptions.

(d) Portability: The right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.

(e) Restriction: The right to request that we restrict the processing of your personal information in certain circumstances.

(f) Objection: The right to object to the processing of your personal information for certain purposes, including direct marketing.

(g) Withdrawal of Consent: Where we rely on consent as the legal basis for processing, you have the right to withdraw your consent at any time.

(h) Opt-Out of Sale/Sharing: If applicable, the right to opt out of the sale or sharing of your personal information (see Section 15).

To exercise any of these rights, please contact us at info@intraalpha.com. We will respond to your request within the time period required by applicable law.

11. DO NOT TRACK SIGNALS

Some web browsers transmit "Do Not Track" ("DNT") signals. Because there is no universally accepted standard for how to respond to DNT signals, we do not currently respond to DNT signals. However, you may opt out of targeted advertising as described in Section 6.3 and exercise your rights under applicable privacy laws as described in Sections 10, 15, and 16.

12. INTERNATIONAL DATA TRANSFERS

IntraAlpha is based in the United States. If you access the Service from outside the United States, your personal information will be transferred to and processed in the United States and potentially other countries where our service providers operate. These countries may have data protection laws that differ from those in your jurisdiction.

For transfers of personal data from the EEA, UK, or Switzerland to the United States or other countries not deemed to provide an adequate level of data protection, we rely on appropriate safeguards, including: (a) Standard Contractual Clauses ("SCCs") approved by the European Commission; (b) the UK International Data Transfer Addendum, where applicable; and (c) any other transfer mechanisms permitted under applicable law. You may request a copy of the applicable transfer safeguards by contacting us at info@intraalpha.com.

13. THIRD-PARTY LINKS AND SERVICES

The Service may contain links to third-party websites, services, or applications, including social media platforms (such as Discord and X/Twitter), brokerage platforms, advertising networks, and affiliate partners. This Policy does not apply to any third-party services. We encourage you to review the privacy policies of any third-party services you access through the Service. IntraAlpha is not responsible for the privacy practices or the content of third-party services.

14. AUTOMATED DECISION-MAKING

The Service uses automated processes to generate rankings, screening results, trade ideas, volatility calculations, and other analytical outputs. These automated processes are designed to assist your research and do not produce legal or similarly significant effects on you. If you are located in the EEA or UK and believe that an automated decision has produced legal or similarly significant effects on you, you may contact us at info@intraalpha.com to request human review.

15. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA").

15.1 Categories of Personal Information

In the preceding twelve (12) months, we have collected and disclosed the following categories of personal information:

15.2 Your CCPA Rights

As a California resident, you have the right to:

(a) Know what personal information we collect, use, disclose, sell, or share about you.

(b) Delete your personal information, subject to certain exceptions.

(c) Correct inaccurate personal information.

(d) Opt out of the sale or sharing of your personal information. To opt out, visit our "Do Not Sell or Share My Personal Information" link on the Service or contact us at info@intraalpha.com.

(e) Limit the use of your sensitive personal information, if applicable.

(f) Non-discrimination for exercising your CCPA rights.

15.3 Exercising Your Rights

To submit a verifiable consumer request, please contact us at info@intraalpha.com. We will verify your identity by matching the information you provide with the information we have on file. You may designate an authorized agent to make a request on your behalf by providing a written authorization.

15.4 Sharing for Cross-Context Behavioral Advertising

We share certain personal information (such as device identifiers, cookie data, hashed email addresses, and browsing activity) with advertising partners for cross-context behavioral advertising. Under the CCPA, this constitutes "sharing" of personal information. You may opt out of this sharing as described in Section 15.2(d) above.

16. EUROPEAN PRIVACY RIGHTS (GDPR)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following additional rights under the General Data Protection Regulation ("GDPR") and equivalent UK and Swiss data protection legislation:

(a) The rights described in Section 10 of this Policy.

(b) The right to lodge a complaint with your local supervisory authority if you believe that our processing of your personal data violates applicable data protection law.

(c) The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of a contract, authorized by law, or based on your explicit consent.

For the purposes of the GDPR, the data controller is Intra Capital Ventures LLC, doing business as IntraAlpha, contactable at info@intraalpha.com.

17. CANADIAN PRIVACY RIGHTS (PIPEDA)

If you are a resident of Canada, your personal information is protected under the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy legislation. Under PIPEDA, you have the right to:

(a) Access the personal information we hold about you.

(b) Challenge the accuracy and completeness of your personal information and have it amended as appropriate.

(c) Withdraw your consent to the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice.

(d) File a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances. To exercise your rights under PIPEDA, please contact us at info@intraalpha.com.

18. DISCORD INTEGRATION

The Service may include community features hosted on Discord. If you participate in IntraAlpha's Discord server or any Discord-based feature, your interactions are also subject to Discord's privacy policy and terms of service. We may collect your Discord username and user identifier for the purpose of linking your Discord participation to your IntraAlpha account. We do not collect private messages or content from channels you access outside IntraAlpha-operated channels.

19. CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will post the updated Policy on the Service with a revised "Last Updated" date. For material changes, we will provide additional notice by email to the address associated with your account at least fifteen (15) days in advance. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Policy.

20. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

For privacy-related inquiries from EEA, UK, or Swiss residents, you may also contact us at the email address above with the subject line "GDPR Request" or "UK Data Protection Request."