Privacy Policy

    QuantGenie Inc.

    Effective Date: August 1, 2026

    Version 1.0

    This Privacy Policy describes how QuantGenie Inc., a Delaware corporation (“QuantGenie,” “we,” “our,” or “us”), collects, uses, retains, and discloses information in connection with the QuantGenie websites, applications, and platform (the “Platform”) and the services we make available through the Platform (the “Services”). It also describes the rights and choices available to you.

    This Policy is a disclosure document describing QuantGenie’s data practices. It is not a contract, and it is not incorporated into and does not form part of the QuantGenie Terms of Service. We may update this Policy as described in Section 13.

    1. SCOPE OF THIS POLICY

    1.1 What this Policy covers. This Policy applies to personal information we collect when you visit our websites, register for or use the Platform and Services, communicate with us, interact with our marketing, or interact with us on social media platforms. “Personal information” means information that identifies, relates to, or could reasonably be linked with you.

    1.2 What this Policy does not cover. This Policy does not apply to: (a) information collected by any third-party broker-dealer, futures commission merchant, or other execution venue you choose to connect to your account (each, a “Connected Broker”), whose collection and use of your information is governed by that broker’s own agreements and privacy policy; (b) third-party websites, applications, or services that we link to or that link to us, which we do not control and whose privacy practices we encourage you to review; or (c) information practices of your employer or any other account holder, if you use the Services on behalf of an entity.

    1.3 United States only. The Services are offered only in the United States, and your information is stored and processed in the United States. If you access the Services from outside the United States, you do so on your own initiative, and you understand that your information will be transferred to and processed in the United States.

    2. INFORMATION WE COLLECT

    2.1 Information you provide to us.

    1. Account and registration information. Name, email address, password (stored in hashed form), authentication settings (including multi-factor authentication), and account preferences.

    2. Billing information. Subscription plan, billing contact details, and transaction history. Payments are handled by third-party payment processors. We do not receive or store your full payment card number; we may receive limited confirmation details such as card brand, last four digits, and payment status.

    3. Strategy content. The content you create or submit through the Platform, including natural-language strategy descriptions and prompts, trading strategies and their structured representations, parameters and configurations, backtest settings and results, and any source code, documents, images, or other materials you upload (“Strategy Content”). Strategy Content may reveal information about your financial interests and trading preferences. We do not ask for, and you should not include, Social Security numbers, brokerage statements, or full financial account numbers in Strategy Content.

    4. Communications. Messages you send us, including support requests, feedback, and survey responses.

    5. Agreement acceptance records. When you accept our Terms of Service or other terms, we record the timestamp, account identifier, version accepted, and IP address.

    2.2 Information we collect automatically. When you use the Platform or visit our websites, we automatically collect:

    1. Device and log information. IP address, browser type and version, operating system, device identifiers, referring pages, and access times.

    2. Usage information. Pages viewed, features used, strategy generation and backtest activity, consumption of metered allowances, session information, and interaction events.

    3. Cookie and tracking data. Information collected through cookies, pixels, and similar technologies, as described in Section

    2.3 Information we receive from third parties.

    1. Connected Brokers. If you choose to connect a brokerage account, we receive information from your Connected Broker needed to operate the connection, such as account identifiers and connection status, order acknowledgments, execution and fill reports, and position and balance information relevant to your deployed strategies. Authentication occurs directly between you and your broker; we do not receive or store your broker username or password. We store only the access credentials the broker issues (such as OAuth tokens), in encrypted form. Section 7 describes broker connections in more detail.

    2. Payment processors. Payment status and transaction confirmations.

    3. Analytics and advertising partners. Usage information, identifiers, and interaction data, as described in Section 5.

    4. Social media platforms. If you interact with QuantGenie on a social media platform — for example, by following our page or commenting on a post — we may receive information about that interaction. The platform’s own privacy policy governs its collection and use of your information.

    2.4 Information we do not collect. In providing the current Services we do not collect Social Security numbers or government identification numbers; we do not collect precise geolocation (we may derive general location, such as city and state, from your IP address); and we do not collect biometric information.

    3. HOW WE USE INFORMATION

    3.1 Our purposes. We use the information described in Section 2 to:

    1. Provide and operate the Services, including creating and maintaining your account; translating your natural-language descriptions into structured strategy representations; running backtests and analyses you request; transmitting the order instructions you have configured and confirmed to your Connected Broker; and displaying your content and results to you;

    2. Process payments and administer subscriptions, including billing, renewals, and metered allowances;

    3. Secure the Platform, including authenticating users, detecting and preventing fraud, abuse, unauthorized access, and violations of our Terms of Service (including market-integrity violations), and maintaining audit logs;

    4. Provide support, including responding to your requests and troubleshooting issues, which may involve authorized personnel accessing your account information and Strategy Content as needed to assist you;

    5. Improve and develop the Services, including analyzing usage, diagnosing errors and usability problems, and creating aggregated or de-identified data as described in Section 3.3;

    6. Communicate with you, including transactional messages about your account, security, billing, and changes to the Services or our terms, and — with the ability to opt out at any time — marketing communications about QuantGenie products and features;

    7. Advertise and measure, as described in Section 5; and

    8. Comply with law and protect rights, including responding to lawful requests, enforcing our agreements, and establishing or defending legal claims.

    3.2 No automated decisions about you. The Platform executes trading instructions that you configure and confirm; those are your decisions, not ours. We do not use your personal information to make automated decisions about you that produce legal or similarly significant effects, such as decisions about pricing, eligibility, or creditworthiness.

    3.3 Aggregated and de-identified data. We may create and use data that has been aggregated or de-identified so that it no longer identifies you and cannot reasonably be re-identified. We may use such data for any lawful business purpose, including improving the Services, research, and benchmarking, and we commit to maintaining and using it only in de-identified form.

    4. ARTIFICIAL INTELLIGENCE PROCESSING

    4.1 AI service providers. The Platform uses machine learning models, including large language models operated by third-party AI providers, to translate your descriptions into strategy specifications and to generate related output. Your prompts and relevant Strategy Content are transmitted to these providers for processing on our behalf.

    4.2 Limits on provider use. Our agreements with AI providers restrict their use of your content to providing services to us and prohibit them from using your identifiable content to train or improve their models.

    4.3 Our use. We may use aggregated or de-identified data derived from Platform usage, as described in Section 3.3, to evaluate and improve the quality of strategy generation. Generated output is produced automatically; QuantGenie personnel do not review your individual prompts or output in the ordinary course, and access them only for the operational, support, security, and legal purposes described in Section 3.

    5. COOKIES, ANALYTICS, AND ADVERTISING

    5.1 Technologies we use. We and our partners use cookies, pixels and web beacons, local storage, software development kits, and similar technologies. These fall into four categories:

    1. Essential — required for the Platform to function, including authentication, session management, and security;

    2. Functional — remember your settings and preferences;

    3. Analytics — help us understand how the websites and Platform are used, measure feature adoption, and diagnose problems. Our analytics tools may include session-analysis technologies that record interactions with our websites — such as clicks, scrolls, and navigation paths — to help us diagnose usability problems. These tools are configured for product improvement, not to capture the content of sensitive fields; and

    4. Advertising — used by us and third-party advertising partners to deliver and measure ads, including showing you QuantGenie ads on other sites and services (sometimes called retargeting or interest-based advertising).

    5.2 Targeted advertising disclosure. When advertising technologies operate on our websites, our advertising partners may collect identifiers, device information, and information about your activity on our sites. Some privacy laws treat this as “targeted advertising,” and some treat the disclosure of information to advertising partners as a “sale” or “sharing” of personal information, even though no money changes hands for it. We do not sell personal information for money. Section 10 describes how to opt out of targeted advertising.

    5.3 Your controls. You can manage cookies through our cookie preferences tool and your browser settings; you can opt out of targeted advertising as described in Section 10.3; you can limit use of your mobile device’s advertising identifier through your device settings; and you can use industry tools such as the Digital Advertising Alliance’s opt-out page (optout.aboutads.info). Blocking essential cookies may prevent the Platform from functioning.

    5.4 Global Privacy Control. We honor the Global Privacy Control (“GPC”) browser signal. If your browser or extension transmits a valid GPC signal, we treat it as a request to opt out of targeted advertising and any “sale” or “sharing” of personal information for that browser. We do not respond to older “Do Not Track” signals, for which no industry standard was adopted.

    6. HOW WE SHARE INFORMATION

    We share personal information only as described below.

    6.1 Service providers. We share information with vendors that perform services on our behalf under contracts that restrict their use of your information to providing those services. Categories include: cloud hosting and infrastructure providers; AI model providers (Section 4); payment processors; analytics providers; communications and email delivery providers; and customer support tooling providers.

    6.2 Advertising partners. As described in Section 5, we share limited identifiers, device data, and site activity with advertising partners (including advertising features of social media platforms) for ad delivery and measurement. This is the only sharing we engage in that privacy laws may classify as a “sale” or “sharing,” and you may opt out at any time under Section 10.3.

    6.3 Connected Brokers. At your direction, when you connect a brokerage account and enable a strategy, we transmit your order instructions and related information to your Connected Broker. Your broker’s handling of that information is governed by your agreement with the broker.

    6.4 Legal, safety, and compliance. We may disclose information to courts, regulators, self-regulatory organizations, exchanges, law enforcement, or other parties where we believe disclosure is required or permitted by law, including to comply with legal process, to cooperate with regulatory inquiries, to investigate suspected fraud, market abuse, or violations of our Terms of Service, or to protect the rights, property, or safety of QuantGenie, our users, or others.

    6.5 Business transfers. If QuantGenie is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction (including during negotiations and due diligence for such a transaction), subject to this Policy or successor terms disclosed to you.

    6.6 Professional advisors. We may share information with our lawyers, accountants, auditors, and insurers in connection with their services to us.

    6.7 With your consent. We share information for any other purpose you direct or consent to.

    6.8 Aggregated and de-identified data. We may share aggregated or de-identified data (Section 3.3) that does not identify you.

    7. BROKER CONNECTIONS

    7.1 Your election; authorization; credentials. Connecting a brokerage account is optional and initiated solely by you. Authentication is conducted directly between you and your Connected Broker through the broker’s own authorization flow; QuantGenie stores only the access credentials the broker issues, in encrypted form. We use the connection solely to transmit the order instructions you have configured and to receive the acknowledgment, execution, position, and balance information needed to operate and display your deployments.

    7.2 Revocation; no custody. You may revoke QuantGenie’s access at any time through your broker or through the Platform, and revocation disables associated deployments. QuantGenie does not hold or custody your funds or securities at any time.

    8. SECURITY

    8.1 Our safeguards. We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption of data in transit and at rest, encrypted storage of broker access credentials, access controls that limit personal information to personnel who need it to perform their roles, logging, and the availability of multi-factor authentication for your account. No system is completely secure, and we cannot guarantee the security of information transmitted to or stored by us.

    8.2 Your role. You are responsible for safeguarding your credentials and enabling available security features. If you believe your account has been compromised, contact us immediately at legal@quantgenie.ai.

    9. RETENTION

    9.1 Retention periods. We retain personal information for as long as your account is active and as needed for the purposes described in Section 3, and thereafter as required or permitted by law. In general: account records, billing records, and agreement acceptance records are retained for the life of the account and for the period required by tax, accounting, and other legal obligations; Strategy Content is retained until you delete it or close your account; and server logs and analytics data are retained for shorter operational periods. In determining retention periods, we consider the purpose for which information was collected, its sensitivity, legal requirements, and our legitimate operational needs, including security and dispute resolution.

    9.2 After account closure. Following account closure, personal information is deleted or de-identified in the ordinary course, subject to backup cycles and any legal hold. De-identified and aggregated data may be retained indefinitely. If you close your account, you are responsible for exporting any content you wish to keep before closure.

    10. YOUR RIGHTS AND CHOICES

    We extend the rights in this Section to all users in the United States, regardless of the state you live in.

    10.1 Access, correction, deletion, and portability. You may request: (a) confirmation of whether we process your personal information and access to a copy of it, in a portable format where technically feasible; (b) correction of inaccurate personal information; and (c) deletion of your personal information. You can exercise many of these directly in your account settings, or by emailing legal@quantgenie.ai with the subject line “Privacy Request.”

    10.2 Marketing opt-out. You may opt out of marketing emails at any time using the unsubscribe link in the message or your account settings. We will continue to send transactional and account messages, which are not marketing.

    10.3 Targeted advertising opt-out. You may opt out of targeted advertising and of any “sale” or “sharing” of your personal information by using the “Your Privacy Choices” link on our website, adjusting our cookie preferences tool, or transmitting a Global Privacy Control signal (Section 5.4).

    10.4 Verification, timing, and authorized agents. We will verify requests using your account email and, where appropriate, additional information, and we may decline requests we cannot verify. We will respond within the time required by applicable law — generally within forty-five (45) days, with an extension where permitted and with notice to you. An authorized agent may submit a request on your behalf with proof of authorization; we may still require you to verify your identity directly.

    10.5 No retaliation; appeals. We will not deny you the Services, charge you a different price, or provide a different level of quality because you exercised a privacy right. If we decline a request, we will explain why, and you may appeal by replying to our decision with the subject line “Privacy Appeal”; we will respond to appeals within the period required by applicable law, and if your appeal is denied you may contact your state Attorney General.

    10.6 Declining to provide information. Some personal information is necessary to provide the Services. If you decline to provide information we identify as required — for example, an email address for your account or billing information for a paid subscription — we may be unable to provide some or all of the Services.

    11. STATE PRIVACY DISCLOSURES

    11.1 Categories. For purposes of state privacy laws (including the California Consumer Privacy Act), in the preceding twelve months we have collected the following categories of personal information: identifiers (such as name, email, IP address, and account identifiers); commercial information (such as subscription and transaction history); internet or other electronic network activity information (such as usage and log data); limited financial information (such as payment confirmations and, if you connect a broker, the account and activity information described in Section 2.3(a)); general location information derived from IP address (not precise geolocation); audio or visual information only if you provide it (such as screenshots you upload); professional information only if you provide it in communications; and inferences limited to product analytics (such as feature-usage patterns). Sources, purposes, and recipients are described in Sections 2, 3, and 6.

    11.2 “Sale” and “sharing.” We disclose identifiers, device data, and internet activity to advertising partners for targeted advertising, which certain laws classify as a “sale” or “sharing.” We do not sell or share any other category of personal information, and we do not knowingly sell or share the personal information of any person under eighteen (18) years of age. Opt out as described in Section 10.3.

    11.3 Sensitive personal information. The only sensitive personal information we collect is account log-in and security information and, if you connect a broker, financial account access credentials issued by the broker (stored encrypted). We use sensitive personal information only to provide the Services you request, to secure the Platform, and for other purposes permitted by applicable law without a right to limit, and we do not use or disclose it to infer characteristics about you.

    11.4 California “Shine the Light.” California residents may request information about disclosure of personal information to third parties for those parties’ own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

    12. CHILDREN

    The Services are intended only for individuals who are at least eighteen (18) years of age. We do not knowingly collect personal information from anyone under eighteen. If you believe a person under eighteen has provided personal information to us, contact us at legal@quantgenie.ai and we will delete it.

    13. CHANGES TO THIS POLICY

    We may update this Policy from time to time. When we do, we will post the updated Policy with a new effective date. For changes that materially expand how we collect, use, or disclose personal information, we will provide advance notice by email to your account address or by prominent notice on the Platform before the change takes effect. Your use of the Services after the effective date of an updated Policy means the updated Policy applies to information we hold about you, to the extent permitted by law. We encourage you to review this Policy periodically.

    14. CONTACT US

    For questions, concerns, or complaints about this Policy or our privacy practices, or to exercise your rights under Section 10, contact us at:

    QuantGenie Inc.
    Attn: Legal — Privacy
    1111B S Governors Ave, STE 40352
    Dover, DE 19904
    United States
    Email: legal@quantgenie.ai

    Please use the subject line “Privacy Request” for requests under Section 10 so that your message is routed correctly. If you are reporting a concern about our compliance with this Policy, please describe the issue in as much detail as you can without including sensitive information in your message.