Privacy Policy

Welcome to Hedgly (“we”, “our”, or “us”). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the Hedgly platform, website, and notification services (the “Service”).

For the purpose of the UK General Data Protection Regulation (UK GDPR) and the Data Use and Access Act (DUAA), the Data Controller is [Your Limited Company Name], a company registered in England and Wales with company number [Number].

Registered Office: [Formation Agent Virtual Address] · Data Protection Contact: support@hedgly.app

We collect and process the following data about you:

• Identity & Contact Data: Name, email address, and phone number (if you opt in for SMS or encrypted messaging alerts).
• Financial & Transaction Data: Subscription tier details and payment history. We do not store your full credit card details — all payments are processed securely by our payment gateway, Stripe.
• Profile & Portfolio Data: The stock tickers you choose to monitor, your alert thresholds, and your notification preferences (e.g., private RSS feed URLs).
• Technical Data: IP addresses, browser types, time zone settings, and operating systems collected via our web dashboard and secure routing infrastructure.

Under UK data protection law, we must have a “lawful basis” for processing your data. We use your data in the following ways:

• To provide the Service (Contractual Necessity): We use your Contact and Portfolio Data to monitor your selected tickers via market APIs and dispatch your alerts and reports via your chosen channels.
• To process payments (Contractual Necessity): We route your Financial Data to Stripe to manage your subscription.
• To improve and secure the Service (Legitimate Interest): We use Technical Data to ensure our automated data pipelines and secure hosting infrastructure remain load-balanced, operational, and protected against unauthorized access.
• To comply with regulations (Legal Obligation): We maintain notification logs to keep a compliance audit trail in accordance with financial and data protection regulations.

Note regarding AI: Hedgly utilises Large Language Models hosted on our private processing environments to analyse market news. Your personal data is never used to train these models.

We do not sell your personal data. To run Hedgly effectively, we share strictly necessary data with the following trusted third-party processors:

• Payment Processors: Stripe (for handling subscription billing).
• Infrastructure Providers: Secure cloud hosting and routing providers that manage our database and maintain the automated workflows powering the Service.
• Communication APIs: Third-party messaging networks (for dispatching your chosen alerts) and text-to-speech providers (solely for audio generation; no personal portfolio identities are linked to the audio generation requests).

Some of our third-party processors are based outside of the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards, such as the UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs), are in place with the provider.

Security: Your data is stored on our secure database infrastructure. We use end-to-end encryption, automated rate-limiting, and secure tunneling to prevent unauthorized access.

Retention: We only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

• Active account data is kept for the lifetime of your account.
• If you cancel your subscription and delete your account, your personal identity data is deleted within 30 days.
• Notification logs (which may contain identifiers) are kept for up to 6 years to satisfy legal and regulatory compliance audits.

Under UK data protection law, you have the right to:

• Request access to your personal data.
• Request correction of inaccurate data.
• Request erasure of your data (“the right to be forgotten”).
• Object to or restrict processing of your data.
• Request the transfer of your data (Data Portability).

To exercise any of these rights, please email us at support@hedgly.app.

If you have any concerns about how we use your personal data, the UK Data Use and Access Act requires that you first lodge a complaint directly with us. We will acknowledge your complaint within 30 days and investigate it without undue delay. Please contact support@hedgly.app.

If you remain dissatisfied with our response, you have the right to escalate your complaint to the Information Commissioner’s Office (ICO): www.ico.org.uk · Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.