Privacy Policy
Last updated: October 16, 2025
Effective Date: October 16, 2025
1. Introduction and Scope
Pairfolio, Inc. ("Company," "we," "us," or "our") is committed to protecting the privacy and confidentiality of our institutional clients, qualified investors, and other users of our quantitative trading platform. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you use our services, including our website, mobile applications, and trading platform (collectively, the "Services").
This Privacy Policy applies to all users of our Services, including institutional clients, accredited investors, and prospective clients. By using our Services, you consent to the data practices described in this Privacy Policy.
2. Information We Collect
2.1 Personal Information
We collect personal information that you voluntarily provide to us, including:
- Contact information (name, email address, phone number, mailing address)
- Professional information (job title, company name, industry)
- Financial information necessary for accredited investor verification
- Investment experience and risk tolerance assessments
- Account credentials and authentication information
- Communication preferences and marketing consent
2.2 Financial Information
To comply with applicable securities regulations and verify your eligibility for our Services, we may collect:
- Net worth and income information for accredited investor verification
- Investment portfolio information and trading history
- Banking and financial account information for fund transfers
- Tax identification numbers and other regulatory identifiers
- Investment objectives and risk tolerance assessments
2.3 Technical Information
We automatically collect certain technical information when you use our Services:
- Device information (IP address, browser type, operating system)
- Usage data (pages visited, time spent, features used)
- Log files and analytics data
- Cookies and similar tracking technologies
- Location data (if permitted by your device settings)
3. How We Use Your Information
We use the information we collect for the following purposes:
- To provide, maintain, and improve our Services
- To verify your identity and accredited investor status
- To process transactions and manage your account
- To communicate with you about our Services and updates
- To comply with applicable laws and regulations
- To prevent fraud and ensure platform security
- To conduct research and analytics to improve our algorithms
- To provide customer support and respond to inquiries
- To send marketing communications (with your consent)
4. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:
- Service Providers: With trusted third-party vendors who assist us in operating our platform
- Legal Requirements: When required by law, court order, or regulatory authority
- Business Transfers: In connection with a merger, acquisition, or sale of assets
- Consent: When you have given us explicit consent to share your information
- Protection of Rights: To protect our rights, property, or safety, or that of our users
5. Data Security
We implement comprehensive security measures to protect your personal information:
- End-to-end encryption for all data transmission
- Secure data centers with physical and digital access controls
- Regular security audits and penetration testing
- Employee training on data protection and privacy
- Incident response procedures and breach notification protocols
- Compliance with industry security standards (SOC 2, ISO 27001)
6. Data Retention
We retain your personal information for as long as necessary to provide our Services and comply with applicable legal obligations:
- Account information: Retained while your account is active and for 7 years after closure
- Financial records: Retained for 7 years as required by securities regulations
- Marketing data: Retained until you opt out or for 3 years of inactivity
- Technical logs: Retained for 1 year for security and debugging purposes
7. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: Request access to your personal information
- Correction: Request correction of inaccurate information
- Deletion: Request deletion of your personal information
- Portability: Request a copy of your data in a portable format
- Restriction: Request restriction of processing in certain circumstances
- Objection: Object to processing for marketing purposes
- Withdrawal of Consent: Withdraw consent where processing is based on consent
To exercise these rights, please contact us at [email protected]. We will respond to your request within 30 days.
8. International Data Transfers
Your personal information may be transferred to and processed in countries other than your country of residence. We ensure that such transfers comply with applicable data protection laws and implement appropriate safeguards, including standard contractual clauses and adequacy decisions.
9. Children's Privacy
Our Services are not intended for individuals under the age of 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 delete such information.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated Privacy Policy on our website and updating the "Last updated" date. Your continued use of our Services after such changes constitutes acceptance of the updated Privacy Policy.
11. Contact Information
If you have any questions about this Privacy Policy or our data practices, please contact us:
General Support: [email protected]