Introduction

Ooln, Inc. ("Ooln," "we," "us," or "our") is committed to protecting your privacy and maintaining the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you use our website, mobile application, and related services (collectively, the "Services").

By using our Services, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with our practices, please do not use our Services.

Information We Collect

1. Personal Information You Provide

Account Information:

• Full name and contact information (email, phone number, address)
• Date of birth and government-issued ID verification
• Employment information and income details
• Investment experience and risk tolerance assessments

Trading and Financial Information:

• Trading history and transaction records
• Portfolio holdings and performance data
• Broker account connection credentials (if you choose to link accounts)
• Payment information for subscription services

Profile and Preferences:

• Trading goals and investment objectives
• Platform settings and customizations
• Communication preferences
• Feedback and survey responses

2. Information We Collect Automatically

Usage Data:

• Platform interaction patterns and feature usage
• Time spent on different sections of the platform
• Trading opportunity views and responses
• Search queries and filters applied

Technical Information:

• Device information (type, operating system, browser)
• IP address and general location information
• Session data and timestamps
• Cookies and similar tracking technologies

AI Training Data:

• Anonymized trading patterns and market responses
• Platform engagement metrics
• Success rates of trading opportunities presented
• User feedback on AI-generated insights

3. Information from Third Parties

Market Data Providers:

• Real-time and historical market data
• Options pricing and volatility information
• Economic indicators and market news

Brokerage Integrations:

• Account balances and holdings (with your permission)
• Trade execution data
• Account verification information

Identity Verification Services:

• Identity confirmation and fraud prevention data
• Compliance and regulatory screening results

How We Use Your Information

1. Core Service Delivery

AI-Powered Insights:

• Analyze your trading history to personalize recommendations
• Generate market opportunities tailored to your risk profile
• Improve our AI algorithms and prediction accuracy
• Provide performance analytics and portfolio insights

Platform Functionality:

• Maintain and improve your user account
• Process subscription payments and billing
• Deliver customer support and technical assistance
• Send important service-related communications

2. Product Development and Improvement

AI Model Training:

• Enhance our proprietary algorithms using aggregated, anonymized data
• Develop new features and trading tools
• Improve user experience and platform performance
• Conduct research and analytics on market trends

Quality Assurance:

• Monitor platform performance and reliability
• Identify and fix technical issues
• Test new features and improvements
• Ensure compliance with financial regulations

3. Legal and Regulatory Compliance

Regulatory Requirements:

• Comply with financial services regulations
• Maintain records as required by law
• Report suspicious activities to appropriate authorities
• Respond to legal requests and court orders

Risk Management:

• Detect and prevent fraudulent activities
• Monitor for unusual trading patterns
• Ensure platform security and integrity
• Protect against unauthorized access

How We Share Your Information

1. Service Providers and Partners

We may share your information with trusted third parties who help us operate our Services:

Technology Partners:

• Cloud hosting and data storage providers
• AI and machine learning service providers
• Payment processors and billing services
• Customer support and communication tools

Financial Service Providers:

• Market data vendors and exchanges
• Brokerage platforms (with your explicit consent)
• Identity verification and compliance services
• Banking and payment processing partners

2. Legal and Regulatory Disclosures

We may disclose your information when required by law or to protect our legitimate interests:

• In response to legal process, court orders, or government requests
• To comply with financial services regulations and reporting requirements
• To investigate fraud, security breaches, or violations of our Terms
• To protect the rights, property, or safety of Ooln, our users, or others

3. Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

4. Aggregated and Anonymized Data

We may share aggregated, anonymized data that cannot identify you personally for:

• Market research and industry analysis
• Academic research and publications
• Product development and improvement
• Marketing and promotional purposes

Data Security and Protection

1. Security Measures

We implement industry-standard security measures to protect your information:

Technical Safeguards:

• End-to-end encryption for data transmission
• Advanced encryption for data storage
• Multi-factor authentication for account access
• Regular security audits and penetration testing

Operational Safeguards:

• Employee background checks and training
• Strict access controls and monitoring
• Incident response and breach notification procedures
• Regular security policy reviews and updates

2. Data Retention

We retain your information for as long as necessary to:

• Provide our Services and maintain your account
• Comply with legal and regulatory requirements
• Resolve disputes and enforce our agreements
• Improve our AI models and Services

Retention Periods:

• Account information: Duration of account plus 7 years after closure
• Trading data: 7 years from transaction date (regulatory requirement)
• Usage analytics: 3 years from collection
• Marketing communications: Until you unsubscribe

3. Data Minimization

We collect and process only the information necessary to provide our Services effectively. We regularly review our data collection practices to ensure compliance with privacy principles.

Your Privacy Rights and Choices

1. Access and Control

You have the right to:

• Access: Request a copy of the personal information we hold about you
• Update: Correct or update your account information at any time
• Delete: Request deletion of your account and associated data
• Portability: Export your data in a machine-readable format

2. Communication Preferences

You can control how we communicate with you:

• Opt out of marketing emails and promotional communications
• Adjust notification settings for trading alerts and platform updates
• Choose preferred communication channels (email, SMS, push notifications)

3. Cookie and Tracking Preferences

You can manage cookies and tracking through:

• Browser settings to block or delete cookies
• Platform settings to disable certain tracking features
• Third-party opt-out tools for advertising cookies

4. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

• Right to know what personal information we collect and how it's used
• Right to delete your personal information (subject to certain exceptions)
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights

5. European Privacy Rights (GDPR)

If you are located in the European Union, you have rights under the General Data Protection Regulation:

• Right of access, rectification, erasure, and data portability
• Right to restrict or object to processing
• Right to withdraw consent at any time
• Right to lodge a complaint with a supervisory authority

Cookies and Tracking Technologies

1. Types of Cookies We Use

Essential Cookies:

• Required for platform functionality and security
• Cannot be disabled without affecting service quality

Analytics Cookies:

• Help us understand platform usage and performance
• Used to improve user experience and features

Preference Cookies:

• Remember your settings and customizations
• Enhance personalization of the platform

2. Third-Party Cookies

We may use third-party services that place cookies on your device:

• Google Analytics for usage analytics
• Customer support and chat services
• Payment processing and fraud prevention
• Marketing and advertising platforms (if applicable)

3. Managing Cookies

You can control cookies through your browser settings, but disabling certain cookies may limit platform functionality.

International Data Transfers

Ooln is based in the United States, and your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. We ensure appropriate safeguards are in place for international transfers, including:

• Standard contractual clauses approved by regulatory authorities
• Adequacy decisions for data transfers to certain countries
• Certification schemes and codes of conduct
• Binding corporate rules for intra-group transfers

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 information from a child under 18, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy on our website with a new effective date
• Sending an email notification to your registered email address
• Displaying a prominent notice on our platform

Your continued use of our Services after the effective date of any changes constitutes acceptance of the updated Privacy Policy.

Contact Us

If you have questions about this Privacy Policy, want to exercise your privacy rights, or need to report a privacy concern, please contact us:

Last Updated: July 10, 2025