SignalDesk Privacy Policy

This Privacy Policy explains how SignalDesk ("SignalDesk", "we", "us" or "our") collects, uses, stores and protects personal information when you use our website, application and services.

We handle personal information in accordance with applicable data-protection law, including the UK General Data Protection Regulation ("UK GDPR") and Data Protection Act 2018, where applicable.

1. Who we are

SignalDesk
Legal entity: Kernal Tech
Privacy email: support@kernaltech.co.uk

2. Information we collect

Depending on how you use SignalDesk, we may collect:

Account information

• email address;
• name or other information you choose to provide;
• password credentials or password hashes;
• account preferences;
• authentication information; and
• account activity.

Passwords are not stored in plain text.

Subscription and billing information

If you purchase Premium, payment processing may be handled by a third-party payment provider.

We may receive information necessary to manage your subscription, including:

• subscription plan;
• subscription status;
• billing period;
• renewal date;
• payment status;
• transaction identifiers;
• invoices and receipts;
• billing country;
• refunds and refund status; and
• limited payment-method information.

Where payment details are processed directly by our payment provider, SignalDesk does not need to store your complete payment-card details.

We use subscription and billing information to:

• activate and manage Premium;
• process recurring subscription renewals;
• identify failed payments;
• administer cancellations;
• process refunds where applicable;
• provide billing support;
• maintain accounting records; and
• comply with legal and tax obligations.

Brokerage connection information

If you connect a supported brokerage account, we may process:

• brokerage account identifiers;
• API keys, tokens or other authentication credentials;
• account information;
• positions and holdings;
• available balances;
• orders;
• fills and execution information;
• trading permissions; and
• information returned by the brokerage API.

Brokerage credentials are encrypted and used only for purposes authorised by you and supported by the relevant integration.

Trading and strategy information

We may process:

• strategies you enable;
• signals delivered to you;
• strategy configuration;
• orders submitted through SignalDesk;
• execution results;
• timestamps;
• positions and portfolio information obtained from your brokerage;
• automation status; and
• actions taken through the SignalDesk application.

Technical and usage information

We may automatically collect:

• IP address;
• browser and device information;
• operating system;
• referring pages;
• pages and features accessed;
• timestamps;
• error logs;
• authentication events;
• security events; and
• other information required to operate and secure the service.

Cookies and similar technologies are described in our Cookie Policy.

3. How we use personal information

We may use personal information to:

• create and maintain accounts;
• authenticate users;
• provide SignalDesk;
• generate and deliver signals;
• operate enabled strategies;
• submit authorised brokerage orders;
• retrieve brokerage information required to operate the service;
• process and manage subscriptions;
• process recurring payments;
• administer cancellations and refunds;
• provide customer support;
• communicate about accounts and subscriptions;
• maintain security;
• detect fraud and abuse;
• troubleshoot technical problems;
• improve our services;
• maintain appropriate records; and
• comply with legal obligations.

We do not sell personal information.

4. Legal bases

Where UK GDPR applies, we process information using applicable lawful bases including:

• Contract — where processing is necessary to provide the services you requested.
• Legitimate interests — including security, fraud prevention, service improvement and defending legal claims.
• Legal obligation — where processing is required by law.
• Consent — where consent is required, including certain non-essential cookies or marketing.

5. Payment providers

Subscription payments are processed through third-party payment providers.

Payment providers may process payment-card information and other billing information directly under their own privacy policies.

SignalDesk receives information necessary to administer your subscription, including payment status, transaction information, subscription status, renewals, cancellations and refunds.

We do not sell payment information.

6. Brokerage credentials and connected accounts

Brokerage credentials are encrypted and protected using reasonable security measures.

SignalDesk does not hold your brokerage funds or use connected credentials to withdraw funds where the brokerage integration does not provide withdrawal permissions.

Depending on the integration and permissions granted, SignalDesk may submit orders and retrieve account, position, order and related information.

You remain responsible for reviewing the permissions granted to SignalDesk and monitoring your brokerage account.

7. Sharing information

We may share information with service providers that help operate SignalDesk, including providers of:

• payment processing;
• hosting and cloud infrastructure;
• databases;
• authentication and security;
• analytics and monitoring;
• email and communications;
• market data;
• brokerage integrations; and
• customer support.

We may also disclose information where required by law, to prevent fraud or abuse, protect users or SignalDesk, establish or defend legal claims, or in connection with a merger, acquisition, restructuring or sale of assets.

8. International transfers

Some providers may process information outside the United Kingdom.

Where required, we use legally recognised safeguards for international transfers, such as adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to EU Standard Contractual Clauses, or another lawful mechanism.

9. Retention

We retain personal information only for as long as reasonably necessary for the relevant purpose, unless a longer period is required or permitted by law.

Billing, payment and transaction records may be retained for accounting, tax, legal, fraud-prevention and dispute-resolution purposes.

Closing your account does not necessarily result in immediate deletion of records that we are legally required or legitimately permitted to retain.

10. Security

We use reasonable technical and organisational measures designed to protect personal information, including where appropriate:

• encryption;
• access controls;
• authentication controls;
• secure credential storage;
• logging and monitoring;
• security updates; and
• vulnerability management.

No online system can guarantee absolute security.

11. Your rights

Depending on applicable law, you may have rights to:

• access your personal information;
• correct inaccurate information;
• request deletion;
• restrict processing;
• object to certain processing;
• obtain data portability; and
• withdraw consent where processing is based on consent.

You may contact us to exercise these rights.

We may need to verify your identity before completing a request.

12. Complaints

Please contact us first if you have concerns about our handling of your personal information.

UK users may also complain to the Information Commissioner's Office ("ICO").

13. Marketing

We may send essential service and account communications.

Marketing communications will only be sent where permitted by applicable law.

You may unsubscribe from marketing communications at any time.

Unsubscribing from marketing does not prevent essential account, security, billing or service communications.

14. Cookies

SignalDesk uses cookies and similar technologies as described in our Cookie Policy.

Where required by law, consent will be obtained before non-essential cookies are used.

15. Automated processing

SignalDesk may use automated software to generate signals and operate strategies that you have selected.

These processes operate the trading functionality you have enabled and are not intended to make decisions about your eligibility for financial products based on personal circumstances.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated where required by law.

The "Last updated" date identifies the most recent revision.

17. Contact

SignalDesk
Legal entity: Kernal Tech
Privacy email: support@kernaltech.co.uk