Privacy policy

Last updated: 26 September 2022
This Privacy Policy applies to Alluvie, located on the Web site www.alluvie.com (the “Platform”). The Platform is owned and operated by TBD-RESEARCH. Alluvie is a data and analytics platform that is used by retail investors to create and backtest trading strategies. This Privacy Policy identifies the information that TBD-RESEARCH collects from Alluvie participants and users and describes how we will use the information we have collected.

A. WHAT INFORMATION DO WE COLLECT

Retail investors(“Participants”) provide TBD-RESEARCH a name and an email adress to be able to log into the platform and recieve email about the strategy they have created. After a user registers, User Data may be edited or updated by the user.
TBD-RESEARCH complies with applicable laws, regulations, industry standards, and contracts and agreements pertaining to the safeguarding of Institutional and User Data (when discussed together, referred to as “TBD-RESEARCH Data”).

B. HOW WE PROTECT AND SECURE THE DATA

The security and privacy of TBD-RESEARCH Data is our highest priority. TBD-RESEARCH is committed to protecting both the Institutional Data and the User Data that we maintain on behalf of Alluvie participants. We utilize and continually review appropriate technical, administrative and physical procedures to ensure TBD-RESEARCH Data is protected from unauthorized access, disclosure or alteration. In particular:
Data Storage and Security: Secure servers house all TBD-RESEARCH Data. These data centers are constantly monitored and tested for maximum security. Access to the data center infrastructure is strictly controlled and we adhere to industry standard administrative, technical and physical safeguards.
Disclosures: The uses and disclosures of TBD-RESEARCH Data are in compliance with state and federal laws designed to protect such information. Only authorized individuals with a demonstrated business need, including TBD-RESEARCH employees and subcontractors, have access to unit record level data and their authorization is constantly reviewed and verified.
Accountability: All TBD-RESEARCH personnel and subcontractors are accountable for the Security and Privacy of the Institutional and User Data we maintain on our Participants’ behalf. Every employee or subcontractor who has access to TBD-RESEARCH Data has the responsibility to keep the information safe and to only use it for authorized purposes as described below. This policy applies to all computing systems, networks, business processes and the verbal transmission of information.

C. HOW WE USE THE INFORMATION WE COLLECT

Only for Authorized Purposes: We only use information we collect for the purposes for which we were authorized by our Participants.
User Data: We use User Data solely for user registration and authentication.

D. WHEN AND HOW WE SHARE INFORMATION

Only for the purpose of the work: We do not use TBD-RESEARCH Data for advertising or any use outside of the purpose of the collection of such information. We vigilantly review our policies and practices to ensure compliance with the Federal Educational Rights and Privacy Act (FERPA), applicable state law and regulations, and Participant polices. We will not disclose any of the TBD-RESEARCH Data to any third parties except in the following limited circumstances:
Disclosures that are necessary to carry out the scope of work: We may use subcontractors to carry out functions within the scope of work when it is in compliance with federal and state law and with applicable Participant agreements. In such circumstances, the subcontractor is acting as a TBD-RESEARCH employee and is required to comply with the privacy and security requirements and safeguards that apply to TBD-RESEARCH and all of its employees. This includes all applicable federal laws, state laws and regulations, contractual agreements and applicable Participant policies.
Legally compelled disclosures: We will disclose the data we collect if required to do so by law or in the good-faith belief that disclosure is necessary (a) to obey the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or the rights or property of other users of our website; or (c) to act in an emergency to protect the personal safety of users of our website or the public.
Company acquisition: In the event that our company is acquired, we may share the data with the acquirer to continue to provide services to you. The acquirer will be bound by this Privacy Policy.
We do not sell or rent your data: TBD-RESEARCH does not sell or rent any TBD-RESEARCH Data.

E. HOW USERS CAN CORRECT THEIR INFORMATION

Users can manage the data they entered: Our authorized users are able to manage and modify the information that they provide to us. They may correct or change any of their User Data by logging onto the Platform and updating or correcting their User Data.

F. DATA TRACKING

Tracking Information: We use the anonymous information we collect to administer the Platform, improve our services, determine how the Platform is being used, identify popular areas of the Platform, and analyze trends and usage patterns. We may use the IP address of our authorized users to help diagnose problems with our servers. This anonymous information cannot be used to personally identify users.

G. CHANGES TO OUR PRIVACY POLICY

TBD-RESEARCH may modify or update this Privacy Policy from time to time. The Policy is posted at www.alluvie.com. We encourage you to review this page periodically. If we change the policy in a material manner, such as using personal information in a different way than prior practice, we will provide at least 30 days notice to our users so that they will have sufficient time to evaluate the change in practice.

H. DISCLAIMER OF LIABILITY

The information contained herein reflects the privacy policy and practices that TBD-RESEARCH has adopted for the Platform. In legal terms, it shall not be construed as a contractual promise, and TBD-RESEARCH reserves the right to amend it at any time in accordance with Section G above. Any such amendment will become effective immediately upon posting on the Platform. Neither TBD-RESEARCH nor any of its affiliates, employees or agents shall be held liable for any improper or incorrect use of the information described and/or contained in the Platform and assumes no responsibility for anyone’s use of the information.

I. QUESTIONS

If you have any questions or concerns about TBD-RESEARCH information collection and use practices, please e-mail contact@alluvie.com.