Privacy Policy

1. Introduction and Controller Identity

This Privacy Policy explains how Scryer Labs ("Scryer Labs," "we," "us," or "our"), collects, uses, stores, shares, and protects personal data when you visit our website (the "Website"), use our customer portal or application (the "App"), or use our trading strategy marketplace and related tools (collectively, the "Service").

If you are located in the European Economic Area ("EEA"), the United Kingdom ("UK"), or Switzerland, Scryer Labs is the controller responsible for your personal data under the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK GDPR, and the Swiss Federal Act on Data Protection ("FADP"), as applicable.

2. Data We Collect

We collect and process the following categories of personal data.

2.1 Data You Provide Directly

2.2 Data Collected Automatically

2.3 Data We Do Not Collect

For clarity, we do not collect, store, or access the following:

• Brokerage account credentials — We do not collect, store, or transmit your brokerage login credentials, API keys, passwords, or authentication tokens.
• Brokerage account data — We do not access your brokerage balances, positions, trade history, or other brokerage account information.
• TradingView account credentials — We do not have login access to your TradingView account. We provide invite-only script access through TradingView's native sharing mechanism.
• Verified financial information — We do not verify, validate, or independently obtain financial information about you.

3. Legal Bases for Processing

If you are located in the EEA, UK, or Switzerland, we process personal data only where we have a valid legal basis to do so.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

4. How We Use Your Data

4.1 Service Delivery and Operations

• To create and manage your account
• To deliver access to subscribed trading strategies via TradingView invite-only scripts
• To process subscription payments and manage billing
• To manage strategy subscription status and access controls

4.2 Service Improvement

• To analyse usage patterns and improve the Service, including in aggregated or anonymised form
• To debug technical issues and troubleshoot strategy access
• To develop new features and optimise existing functionality

4.3 Security and Compliance

• To detect and prevent fraud, abuse, and unauthorised access
• To maintain audit logs for compliance and dispute resolution
• To comply with legal, regulatory, and contractual obligations

4.4 Communications

• To respond to support requests and other inquiries
• To send transactional communications, including account confirmations, subscription updates, service notices, and security alerts
• To send marketing communications where you have opted in, subject to your right to opt out at any time

4.5 What We Do Not Use Your Data For

• We do not sell your personal data.
• We do not use your personal data to make automated decisions that produce legal or similarly significant effects on you.

5. Data Sharing and Third-Party Recipients

We share personal data only in the circumstances described below.

5.1 Service Providers (Processors)

We engage third-party service providers that process personal data on our behalf and under our instructions.

5.2 Legal and Regulatory Disclosures

We may disclose personal data where required by law, regulation, legal process, or governmental request.

5.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganisation, bankruptcy, or sale of all or part of our business or assets, personal data may be transferred as part of that transaction.

5.4 No Sale of Personal Data

6. International Data Transfers

Scryer Labs is based in the United States. If you access the Service from outside the United States, your personal data may be transferred to, stored in, and processed in the United States or other jurisdictions where we or our service providers operate.

7. Data Retention

We retain personal data only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy.

8. Cookies, Analytics and Similar Technologies

8.1 What We Store on Your Device

Our public website does not set any cookies. The only information we store on your device there is your display preference — whether you have chosen the light or dark theme — which is held in your browser's local storage, stays on your device, and is never sent to us. Our analytics, described below, store nothing on your device at all.

Where you log in to our customer portal, strictly necessary cookies are used to keep you signed in and to protect your session. These are essential to providing the service you have asked for and cannot be switched off. The portal also stores your display preference in local storage, in the same way and for the same reason as the public website.

8.2 Analytics

We use Microsoft Azure Application Insights to understand how our website and portal are used. It runs without cookies and writes nothing to your device — no identifier, no cookie, and no local or session storage entry. Because nothing is placed on your device, there is no consent for us to ask for and nothing for you to withdraw.

It records the pages you view and how long you spend on them, the approximate country and city the request came from, your browser, operating system, screen and window size, and timezone, the referral or campaign link you arrived through, and any errors the page encounters. Your IP address is used to derive that approximate location and is then discarded — it is not retained.

This processing rests on our legitimate interest in understanding and improving the Service (see Section 3). It is not used to build a profile of you, is not linked to your account, and is never sold or shared for advertising. You may object to it at any time using the contact details in Section 13.

8.3 If This Changes

We may introduce further analytics or similar technologies in future. If we do, we will update this Privacy Policy before those technologies are placed on your device, and — where the law requires consent — we will ask for it first and give you a way to withdraw it. You can also block or delete storage at any time through your browser settings.

9. Your Rights

9.1 Rights for Individuals in the EEA, UK, and Switzerland

Subject to applicable law, you may have the right to:

• Access your personal data and obtain information about how it is processed
• Correct inaccurate or incomplete personal data
• Delete your personal data in certain circumstances
• Restrict processing in certain circumstances
• Object to processing based on legitimate interests, including direct marketing
• Receive your personal data in a portable format where applicable
• Withdraw consent at any time where processing is based on consent
• Lodge a complaint with a competent supervisory authority

9.2 Rights Under U.S. State Privacy Laws

Depending on where you live, you may have rights such as the right to know, delete, correct, or opt out of certain processing of personal data. We do not sell personal data or share it for cross-context behavioural advertising.

9.3 How to Exercise Your Rights

To exercise your rights, please contact us at:

10. Automated Decision-Making

Scryer Labs does not engage in automated decision-making, including profiling, that produces legal or similarly significant effects on individuals.

11. Data Security

We implement reasonable and appropriate technical and organisational safeguards designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include encryption in transit and at rest, hashed password storage, access controls, monitoring, and security reviews.

No method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.

12. Children's Privacy

The Service is not directed to children and is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children under 18.

13. Privacy Contact

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date. If we make material changes, we will provide notice as required by law.

15. Contact Us

If you are located in the EEA, UK, or Switzerland, you may also have the right to contact your local data protection authority.