Privacy Policy

1. Scope

This policy covers personal information we handle as the operator of the Platform. It does not cover third-party services you choose to connect or visit, which have their own privacy policies. A Product may provide additional privacy details in its Supplemental Terms.

2. Information we collect

Information you give us

• Email sign-up: your email address, if you sign up for product announcements.
• Account information: your name, email address, password (stored in hashed form) and account settings, when a Product requires an account.
• Content you enter into Products: for example, in Ledgerline, [list what Ledgerline stores, such as trade records (instrument, date, direction, size, price, fees), account labels, notes, tags, journal entries and uploaded files].
• Communications: what you send us when you contact us, including feedback and support requests.

Information collected automatically

• Log data: IP address, browser type, device type, pages requested, referring page, and date and time of access, recorded by our servers for security and operations.

We do not ask for, and ask you not to enter, government ID numbers, full bank or brokerage account numbers, or brokerage login credentials.

3. How we use information

We use personal information to:

• provide, operate and maintain the Platform and its Products
• create and manage accounts, and authenticate users
• send product announcements you signed up for, and service messages about your account
• respond to your requests and provide support
• monitor, secure and protect the Platform, and prevent fraud and abuse
• understand how the Platform is used and improve it
• comply with legal obligations and enforce our Terms

We do not use the financial records you enter to give you investment advice or recommendations. We do not sell personal information, and we do not use it for targeted advertising.

4. Legal bases (EEA and UK users)

If you are in the European Economic Area or the United Kingdom, we process personal information on these legal bases: to perform our contract with you (providing the Products); with your consent (announcement emails, which you can withdraw at any time); for our legitimate interests (securing and improving the Platform), balanced against your rights; and to comply with legal obligations.

5. How we share information

We share personal information only as described here:

• Service providers that process data for us under contract and only on our instructions: hosting ([Hosting provider]) and email delivery ([Email service provider]).
• Legal and safety: when required by law, subpoena or court order, or when needed to protect the rights, safety or property of WiseWink LLC, our users or others.
• Business transfers: in connection with a merger, acquisition, financing or sale of assets, subject to this policy’s protections.
• With your direction: when you ask us to share or connect information.

We may share aggregated or de-identified information that cannot reasonably identify you.

6. Data retention

We keep personal information only as long as needed for the purposes in this policy:

• Email sign-up data: until you unsubscribe or ask us to delete it.
• Account information and Product content: for as long as your account is active. After you close your account, we delete or de-identify it within 90 days, except where we must keep it longer by law.
• Server logs: 90 days, unless needed longer to investigate a security incident.
• Backups: removed on our regular backup cycle of 30 days.

7. Security

We use reasonable technical and organizational safeguards, including encryption in transit (HTTPS), hashed passwords, access controls and restricted server access. No system is completely secure, so we cannot guarantee absolute security. If a breach affects your personal information, we will notify you as required by law.

8. Cookies and similar technologies

The WiseWink LLC website does not use advertising or analytics cookies. Products that require sign-in use strictly necessary cookies or local storage to keep you signed in and remember preferences. These are required for the Product to work.

9. Your choices and rights

• Emails: unsubscribe from announcements using the link in any email, or by contacting us. We may still send essential service messages about your account.
• Access, correction and deletion: you can ask for a copy of your personal information, ask us to correct it, or ask us to delete it.
• Export: where a Product supports it, you can export your content. Otherwise, contact us for a copy.
• EEA and UK users also have the right to restrict or object to processing, to data portability, to withdraw consent, and to complain to their local data protection authority.

To make a request, email [legal@wisewinkllc.com]. We will verify your identity before acting on it and respond within the time required by law. We will not discriminate against you for exercising your rights.

10. U.S. state privacy rights

Residents of some U.S. states, including California, have rights to know what personal information we collect and how we use and share it, and to access, correct and delete it. In the past 12 months we have collected the categories described in Section 2 for the purposes in Section 3, and disclosed them only to the recipients in Section 5.

We do not sell or “share” personal information for cross-context behavioral advertising, as those terms are defined under California law. We do not use or disclose sensitive personal information for purposes that would give you a right to limit it. You may use an authorized agent to make a request on your behalf.

11. Children

The Platform is intended for adults and is not directed to anyone under 18. We do not knowingly collect personal information from children under 13. If you believe a child has given us personal information, contact us and we will delete it.

12. International users

WiseWink LLC is based in the United States, and our servers are located in the United States. If you use the Platform from outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your country. Where required, we use appropriate safeguards for these transfers, such as standard contractual clauses.

13. Changes to this policy

We may update this Privacy Policy. We will post the new version with a new effective date and, for material changes, give reasonable notice, such as by email or an in-product notice.

14. Contact

For privacy questions or requests: