Greekly Privacy Policy

VERSION: DRAFT-2026-07 (ATTORNEY REVIEW DRAFT)

EFFECTIVE DATE: [EFFECTIVE DATE: to be set at publication]

DRAFT STATUS: This document is a working draft prepared for attorney review. Bracketed items in [CAPITALS] are open decisions reserved for counsel. This draft must not be treated as final legal text.

1. Overview

This Privacy Policy explains how [LEGAL ENTITY NAME] ("Greekly," "we," "us," or "our") collects, uses, and shares information when you use the Greekly mobile application and related services (the "Service").

Plain-language summary (the full policy below controls): we collect the minimum we need to run Greekly: your email to sign you in, your app settings, your simulated trading activity, and a device token if you enable notifications. We never ask for your Social Security number or brokerage logins. Payments are processed by Apple, so we never see your card details. We do not sell your personal information, and we do not show third-party ads.

2. Information We Collect

Information you provide:

Account information: your email address and authentication credentials. Sign-in is handled by Firebase Authentication; we never store your password in readable form. If you sign in with Google, we receive basic profile information such as your email address.
Legal acceptance records: the date and document versions in effect when you accept our Terms of Service and this Privacy Policy.
Support communications: anything you choose to send us by email.

Information generated by your use of the Service:

Simulated trading activity: your paper trading orders, positions, balances, and history. This is simulated activity only; it involves no real money and no brokerage data.
Preferences and settings: notification preferences, display settings, and similar choices you make in the app.
Push notification token: a device token that lets us deliver notifications you have enabled.

Information collected automatically:

Device and technical data: device model, operating system version, app version, language, and similar technical information; IP addresses incidental to operating the Service; and diagnostic and crash data provided through Apple and our infrastructure providers.

Information we do not collect: Social Security numbers or other government identifiers; brokerage account credentials or real brokerage data; and payment card numbers (Apple processes subscription payments and shares subscription status with us, not your payment details). We do not use third-party advertising networks or advertising trackers.

3. How We Use Information

We use information to: operate and provide the Service, including maintaining your account and your simulated trading history; deliver notifications you have enabled; respond to support requests; keep the Service secure and prevent abuse; comply with legal obligations; and analyze usage in aggregate or de-identified form to improve the Service. The shared model portfolios shown in the app are product records generated by our systems; they are not built from your personal information.

4. How We Share Information

We share information with:

Service providers that process data for us, including Google Firebase (authentication, database, and push notification delivery), our cloud hosting providers, and Apple (subscription management and app distribution).
Professional advisers, such as lawyers or accountants, under confidentiality obligations, when needed.
Authorities or other parties when required by law, or to protect the rights, safety, or property of Greekly, our users, or others.
A successor entity in connection with a merger, acquisition, or sale of assets; this Policy would continue to apply to your information.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

5. Data Retention

We keep your information while your account is active. If you delete your account or ask us to delete your data, we will delete or de-identify your personal information within a reasonable period, except records we need to keep for legal, security, or dispute purposes (for example, legal acceptance records). Backup copies are purged on our providers' normal cycles.

6. Your Choices and Rights

Access, correction, and deletion: you can request a copy of, correction of, or deletion of your personal information by contacting customersupport@greekly.ai. [NOTE FOR COUNSEL AND PRODUCT: in-app account deletion is planned and is required by Apple before App Store publication.]
Notifications: you can change notification preferences in the app and in iOS Settings at any time.
California residents: California law gives you rights to know, access, correct, and delete personal information, to opt out of the sale or sharing of personal information, and to be free from discrimination for exercising these rights. We do not sell or share personal information as those terms are defined in California law. To exercise your rights, contact customersupport@greekly.ai; we will verify your request before acting on it, and you may use an authorized agent as permitted by law.
Other jurisdictions: where local law grants you similar rights, we will honor valid requests. [COUNSEL TO CONFIRM SCOPE, INCLUDING WHETHER DISTRIBUTION OUTSIDE THE UNITED STATES IS PLANNED.]

7. Children

The Service is for adults. It is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us personal information, contact customersupport@greekly.ai and we will delete it.

8. Security

We use reasonable technical and organizational safeguards, including encryption in transit and access controls on our databases. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

9. Where Information Is Processed

Greekly operates from the United States, and information is processed and stored in the United States by us and our service providers.

10. Changes to This Policy

We may update this Policy from time to time. The version identifier and effective date at the top will change when we do, and material changes will be flagged in the app.

11. Contact

Privacy questions or requests: customersupport@greekly.ai. Mailing address: [BUSINESS ADDRESS].

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