Privacy Policy

This privacy policy (“Policy”) informs you of our practices when handling your Personal Information through the Services (both as defined below). In this Policy, “AlgoPicks,” “we,” “us,” or “our” refers to Q6 Technology Holdings, Inc d/b/a AlgoPicks, a company registered in Delaware with its registered address located at 2261 Market St Ste 22871, San Francisco, CA 94114. We are the data controller under the applicable privacy laws.

For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual. This includes Personal Information you provide or generate when you use: (a) our AlgoPicks platform, including the web application, automated trading features, and any related APIs (the “App”); and (b) algopicks.com and any other dedicated AlgoPicks websites (the “Website”) (collectively, the “Services”). When you use the Services, you accept and understand that we collect, process, use, and store your Personal Information as described in this Policy.

If you are a California resident, our Privacy Notice for California Residents includes additional information about your rights and how we collect, use, and share information.

If you do not agree with this Policy, you must not use any of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights concerning your Personal Information as set out in this Policy.

1. Information We Collect

1.1 Information You Provide

We collect information that you voluntarily provide to us, including:

• Account Information: When you create an account, we collect your name, email address, and authentication credentials. We use Firebase Authentication for account management.
• Profile Information: Any additional information you choose to add to your profile, such as a display name or profile picture.
• User Content: Comments, articles, and other content you submit through the community features of the Services.
• Communications: Information you provide when you contact us for support or communicate with us by email or other means.
• Phone Number: If you provide your phone number for account verification, two-factor authentication, or SMS notifications, we collect and store your phone number along with your SMS consent status and opt-in/opt-out preferences.
• Payment Information: If you subscribe to a paid plan, we collect payment information through our third-party payment processor (Stripe). We do not directly store your full credit card number or banking details.
• Trading Preferences: If you enable the Automated Trading feature, we collect your configured risk parameters, position limits, approved market categories, confidence thresholds, and other trading preferences.

1.2 Information Collected Automatically

When you use the Services, we automatically collect certain information, including:

• Usage Data: Pages viewed, features used, markets browsed, search queries, picks viewed, articles read, time spent on pages, click patterns, and interaction data.
• Device Information: Device type, operating system, browser type and version, screen resolution, language preferences, and unique device identifiers.
• Log Data: IP address, access times, referring URLs, error logs, and server logs.
• Location Data: Approximate geographic location derived from your IP address. We do not collect precise GPS location data. Location data may be used to determine eligibility for prediction market trading in your jurisdiction.
• Cookies and Similar Technologies: We use cookies, local storage, and similar technologies to collect information about your browsing activity. See Section 3 for details.
• Consent Records: When you accept our cookie consent notice, we record your IP address, approximate geographic location, browser and device information, and the date and time of your consent. See Section 3.1 for details.

1.3 Information from Third Parties

We may receive information from third-party sources, including:

• Authentication Providers: If you sign in using a third-party service (e.g., Google), we receive your name, email address, and profile picture from that service.
• Market Data Providers: We receive market data, event data, and pricing information from third-party prediction market platforms, including Kalshi.
• News and Content Sources: We aggregate publicly available news articles and RSS feeds for the purpose of AI-powered analysis.
• Analytics Providers: We receive aggregated analytics data from third-party analytics services.

1.4 Kalshi Account and Financial Data

If you connect your Kalshi account and enable the Automated Trading feature, we access and collect the following data from your Kalshi account through the Kalshi API:

• Account Balance: Your current available balance and portfolio value on Kalshi.
• Portfolio Positions: Your current open positions, including contract details, quantities, average prices, and unrealized profit/loss.
• Order History: Your complete order history on Kalshi, including submitted, executed, cancelled, and expired orders, along with execution prices and timestamps.
• Trading Activity: Real-time data about trades executed on your behalf by the Automated Trading feature, including order submissions, fills, cancellations, and errors.
• Settlement Data: Information about resolved positions, payouts, and settlement outcomes.

We do not access or store your Kalshi account password. We access your Kalshi account through API credentials or OAuth tokens that you provide. We do not have the ability to withdraw funds from your Kalshi account.

2. How We Use Your Personal Information

We use the information we collect for the following purposes:

• Provide and Operate the Services: To create and manage your account, deliver the features you request, display market data and analysis, and provide customer support.
• Automated Trading: To execute trades on your connected Kalshi account based on algorithmic signals, enforce your configured risk parameters and position limits, monitor trading activity, and provide trade notifications and reporting.
• Risk Management: To monitor and enforce risk parameters, detect unusual trading patterns, prevent system errors, and protect against potential losses exceeding configured limits.
• Personalization: To personalize your experience, including displaying relevant markets, categories, and content based on your browsing history, trading activity, and preferences.
• AI and Algorithmic Analysis: To power our AI-driven analysis and trading features, including processing market data and news through large language models (LLMs) provided by Anthropic, Google, and other AI providers to generate event analysis, picks, trading signals, and recommendations.
• Algorithm Improvement: To analyze trading outcomes, measure algorithm performance, calibrate models, and improve our AI and algorithmic systems. We may use aggregated and de-identified trading data for this purpose.
• Improve and Develop the Services: To analyze usage patterns, identify trends, measure the effectiveness of our algorithms, and develop new features.
• Communications: To send you service-related notices, including trade confirmations, risk alerts, position updates, security alerts, and support messages. This includes SMS/text messages to your phone number if you have provided one and consented to receive them.
• SMS/Text Messages: To send account verification codes, two-factor authentication codes, trade confirmations, risk alerts, and other transactional notifications via SMS/text message. Message frequency varies based on your account activity. Message and data rates may apply. You may opt out at any time by replying STOP. Your phone number and SMS opt-in data will not be shared with or sold to third parties or affiliates for marketing or promotional purposes.
• Marketing: With your consent where required, to send you promotional communications about new features, content, or services. You may opt out at any time.
• Safety and Security: To detect, prevent, and address fraud, abuse, market manipulation, unauthorized access, security risks, and technical issues.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests, including CFTC regulations and anti-money laundering requirements.
• Aggregated and De-Identified Data: We may create aggregated, anonymized, or de-identified data from your Personal Information, including trading data. Such data is not considered Personal Information and may be used for any lawful purpose, including analytics, research, algorithm improvement, and performance reporting.

3. Cookies and Similar Technologies

We use the following types of cookies and similar technologies:

• Strictly Necessary Cookies: Required for the operation of the Services, including authentication, session management, security, and maintaining your Kalshi API connection.
• Functional Cookies: Used to remember your preferences, settings, trading parameters, and personalization choices.
• Analytical Cookies: Used to understand how visitors interact with the Services, including page views, navigation patterns, and feature usage. We may use third-party analytics services such as Google Analytics.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Services, including the Automated Trading feature.

3.1 Cookie Consent and Audit Records

When you first visit the Services, we present a cookie consent notice. When you accept this notice, we create an auditable consent record that includes: your IP address, approximate geographic location (country, region, and city derived from your IP address), browser user-agent string, browser language preferences, screen resolution, operating system platform, the page URL at the time of consent, the date and time of consent, and your user ID if you are logged in. By clicking “Got it” or otherwise accepting the cookie consent notice, you acknowledge and agree to the collection of this data for the purpose of maintaining a verifiable record of your consent in compliance with applicable privacy regulations including GDPR and CCPA/CPRA.

These consent records are stored securely and retained for a minimum of seven (7) years to demonstrate compliance with applicable data protection laws. You may request a copy of your consent record by contacting us at the address provided in Section 15.

4. How We Share Your Information

We may share your Personal Information with the following categories of recipients:

• Service Providers: Third-party companies that provide services on our behalf, including:
  • Firebase / Google Cloud: Authentication, database, and hosting services.
  • Vercel: Application hosting and deployment.
  • Anthropic: AI language model processing for event analysis and trading signal generation.
  • Google AI: AI language model processing for analysis and content generation.
  • Kalshi: Market data API and trade execution. When you enable Automated Trading, we transmit order instructions to Kalshi through their API on your behalf.
  • Stripe: Payment processing for subscription fees.
  • Inngest: Background job processing and scheduling, including automated trading job orchestration.
• Analytics Partners: Third-party analytics providers that help us understand usage of the Services.
• Legal and Regulatory: Law enforcement agencies, regulators (including the CFTC), courts, or other government authorities when required by law, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others, or to prevent fraud, market manipulation, or other illegal activity.
• Business Transfers: In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your Personal Information may be transferred to the acquiring entity.
• With Your Consent: We may share your information with third parties when you have given us your explicit consent to do so.

We do not sell your Personal Information to third parties for their direct marketing purposes.

Important Note on Kalshi Data Sharing: When you connect your Kalshi account and enable Automated Trading, we transmit order instructions (including contract identifiers, order type, quantity, and price) to Kalshi through their API. This is necessary to execute trades on your behalf. Kalshi processes this data in accordance with its own Privacy Policy and Terms of Service. We do not share your AlgoPicks account information, personal details, or browsing history with Kalshi beyond what is necessary for trade execution.

5. SMS/Text Message Communications

If you provide your phone number and consent to receive SMS/text messages from AlgoPicks, the following terms apply:

5.1 Types of Messages

We may send you the following types of SMS/text messages:

• Account verification and two-factor authentication codes.
• Trade confirmations and execution notifications.
• Risk alerts and position notifications related to the Automated Trading feature.
• Security alerts (e.g., suspicious login attempts, password changes).
• Service-related transactional messages, including billing and account updates.

5.2 Message Frequency and Costs

Message frequency varies based on your account activity, trading activity, and notification preferences. AlgoPicks does not charge for SMS messages, but message and data rates may apply depending on your mobile carrier and plan. Please contact your carrier for details about your messaging plan.

5.3 Consent and Opt-Out

By providing your phone number and checking the consent box during account registration, you expressly consent to receive SMS/text messages from AlgoPicks for the purposes described above. Your consent is not a condition of purchasing any goods or services from AlgoPicks.

You may revoke your consent and opt out of SMS messages at any time by:

• Replying STOP to any SMS message you receive from us.
• Updating your notification preferences in your account settings.
• Contacting us at support@algopicks.com.

After opting out, you will receive a single confirmation message. Opting out of SMS messages will not affect your ability to use the Service, but you may miss time-sensitive notifications related to your trading activity. You may opt back in at any time by replying START or updating your notification preferences.

5.4 SMS Data Privacy

Your phone number and SMS opt-in consent data will not be shared with or sold to third parties or affiliates for marketing or promotional purposes. We may share your phone number with our SMS service provider solely for the purpose of delivering messages to you on our behalf. Our SMS service provider is contractually prohibited from using your phone number for any purpose other than delivering our messages.

We retain your phone number and SMS consent records for as long as your account is active and for a reasonable period thereafter to comply with legal obligations and resolve disputes. SMS delivery logs are retained for up to 12 months for troubleshooting and compliance purposes.

5.5 Help and Support

For help with SMS messages, reply HELP to any message or contact us at support@algopicks.com. For information about our privacy practices, see the rest of this Privacy Policy or contact our Privacy Officer.

6. AI and Automated Trading Data Processing

6.1 Data Sent to AI Providers

To provide AI-powered analysis and trading signals, we transmit certain data to third-party AI providers, including Anthropic and Google. This data may include:

• Market event descriptions and metadata from Kalshi and other sources.
• Aggregated news articles and publicly available content related to market events.
• Historical market data and pricing information.
• Algorithmic model outputs for further analysis and refinement.
• Aggregated and de-identified trading performance data for model calibration.

We do not intentionally transmit your Personal Information (such as your name, email, account details, or Kalshi credentials) to AI providers. However, if you include personal information in User Content that is processed by AI features, such information may be transmitted to AI providers.

6.2 Trading Data Processing

When you enable Automated Trading, the following data flows occur:

• AlgoPicks to Kalshi: We transmit order instructions (contract ID, order type, quantity, price) to Kalshi through their API using your authorized credentials.
• Kalshi to AlgoPicks: We receive order confirmations, execution reports, position updates, balance information, and error messages from Kalshi through their API.
• AlgoPicks Internal: We process trading data internally to enforce risk parameters, generate performance reports, calibrate algorithms, and improve our trading models.

6.3 Kalshi API Credential Storage

Your Kalshi API credentials (API keys or OAuth tokens) are stored using industry-standard encryption at rest and in transit. We implement access controls to limit internal access to credentials. You may revoke AlgoPicks' access to your Kalshi account at any time by disabling AutoTrade in AlgoPicks or by revoking API access directly through your Kalshi account settings.

6.4 AI Provider Data Practices

Each AI provider has its own privacy policy and data handling practices. We encourage you to review the privacy policies of our AI providers:

• Anthropic: anthropic.com/privacy
• Google AI: policies.google.com/privacy
• Kalshi: kalshi.com/privacy

6.5 Accuracy Disclaimer

AI-generated content and trading signals may contain inaccuracies, errors, hallucinations, or biases. We do not guarantee the accuracy or reliability of any AI-generated analysis, pick, recommendation, or trading signal. You should independently verify any information and monitor all trades executed on your behalf.

7. Data Retention

We retain your Personal Information for as long as your account is active or as needed to provide you with the Services. We may also retain your information as necessary to:

• Comply with our legal obligations, including tax and financial record-keeping requirements.
• Resolve disputes and enforce our agreements.
• Maintain security and prevent fraud.
• Fulfill any other legitimate business purpose.

Trading Data Retention: We retain trading data (order history, execution records, position history, and performance data) for a minimum of seven (7) years after account closure to comply with applicable financial record-keeping requirements and for algorithm improvement purposes. Aggregated and de-identified trading data may be retained indefinitely.

Kalshi API Credentials: Your Kalshi API credentials are deleted from our systems within 30 days of you disconnecting your Kalshi account or deleting your AlgoPicks account.

Consent Records: Cookie and terms consent records (including associated IP address, geolocation, device, and browser data as described in Section 3.1) are retained for a minimum of seven (7) years to demonstrate compliance with applicable data protection regulations.

We cannot guarantee the deletion of data that has been transmitted to third-party AI providers or Kalshi, as such data is subject to those providers' own retention policies.

8. Data Security

We implement appropriate technical and organizational security measures to protect your Personal Information and financial data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL.
• Encryption of sensitive data at rest, including Kalshi API credentials.
• Secure authentication through Firebase Authentication.
• Access controls and least-privilege principles for internal systems.
• Regular security reviews and monitoring.
• Secure API communication with Kalshi using authenticated and encrypted connections.
• Monitoring for unauthorized access attempts and anomalous trading activity.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information and financial data, we cannot guarantee its absolute security and do not warrant that our systems will be free from security breaches, cyberattacks, unauthorized access, or other security incidents. In the event of a security breach affecting your data, we will notify you in accordance with applicable law.

You acknowledge and agree that: (a) the storage of API credentials, authentication tokens, and other sensitive data on internet-connected systems carries inherent security risks; (b) despite our security measures, your stored credentials and personal data may be compromised through cyberattacks, hacking, malware, insider threats, vulnerabilities in third-party infrastructure, or other security incidents; (c) such compromise could result in unauthorized access to your connected accounts (including your Kalshi account), unauthorized transactions, or loss of funds; and (d) to the maximum extent permitted by applicable law, AlgoPicks shall not be liable for any losses, damages, or unauthorized activity resulting from any security breach or compromise of our systems, regardless of cause. Please refer to our Terms of Service for complete details on liability limitations and your assumption of risk.

We strongly recommend that you: (i) use unique, strong passwords for your AlgoPicks account; (ii) enable two-factor authentication where available; (iii) use Kalshi API credentials with the minimum permissions necessary; (iv) regularly rotate your API credentials; and (v) monitor your connected accounts for unauthorized activity.

9. Your Rights

Depending on your location, you may have the following rights regarding your Personal Information:

• Access: The right to request access to the Personal Information we hold about you, including trading data and financial information.
• Correction: The right to request correction of inaccurate or incomplete Personal Information.
• Deletion: The right to request deletion of your Personal Information, subject to certain exceptions (such as legal obligations, financial record-keeping requirements, or legitimate business interests). Please note that we may be required to retain certain trading data for regulatory compliance purposes even after account deletion.
• Objection: The right to object to certain processing of your Personal Information.
• Restriction: The right to request restriction of processing of your Personal Information.
• Portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format, including your trading history and performance data.
• Withdraw Consent: Where processing is based on consent, the right to withdraw your consent at any time. Withdrawing consent for data processing related to the Automated Trading feature will require disabling AutoTrade.

To exercise any of these rights, please contact us at support@algopicks.com. We will respond to your request within the timeframe required by applicable law.

9.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• The right to know what Personal Information we collect, use, disclose, and sell.
• The right to delete your Personal Information (subject to financial record-keeping exceptions).
• The right to opt out of the sale or sharing of your Personal Information.
• The right to non-discrimination for exercising your privacy rights.
• The right to correct inaccurate Personal Information.
• The right to limit the use and disclosure of sensitive Personal Information.

We do not sell your Personal Information as defined under the CCPA/CPRA. To exercise your rights, contact us at support@algopicks.com.

9.2 European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) and equivalent local laws. Our legal bases for processing your Personal Information include: performance of a contract (providing the Services and executing trades on your behalf), legitimate interests (improving our algorithms, preventing fraud), consent, and compliance with legal obligations.

You have the right to lodge a complaint with your local data protection authority. For the EEA, you can find your local authority at edpb.europa.eu. For the UK, you may contact the Information Commissioner's Office (ICO) at ico.org.uk.

10. Cross-Border Data Transfers

Your Personal Information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that are different from the laws of your country. We take appropriate safeguards to ensure that your Personal Information remains protected in accordance with this Policy, including the use of Standard Contractual Clauses (SCCs) approved by the European Commission where applicable.

11. Children's Privacy

The Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. The Services involve prediction market trading, which is restricted to adults. If we become aware that we have collected Personal Information from a child under 18, we will take steps to delete such information promptly and terminate any associated account. If you believe that a child under 18 has provided us with Personal Information, please contact us at support@algopicks.com.

12. Third-Party Links and Services

The Services may contain links to third-party websites, services, or applications, including prediction market platforms such as Kalshi. This Policy does not apply to any third-party services. We are not responsible for the privacy practices of any third-party services. We encourage you to read the privacy policies of any third-party services you visit or use, particularly Kalshi's Privacy Policy if you connect your Kalshi account.

13. Do Not Track

Some browsers include a “Do Not Track” (DNT) feature that signals to websites that you do not want to be tracked. Because there is no accepted standard for how to respond to DNT signals, the Services do not currently respond to DNT signals. We will revisit this policy if a standard is established.

14. Changes to This Policy

We may update this Policy from time to time. If we make material changes, particularly changes affecting how we handle financial data or trading information, we will notify you by posting the updated Policy on the Services with a new effective date and, where appropriate, by email or in-app notification. Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

15. Contact Us

If you have any questions, concerns, or requests regarding this Policy, our data practices, or the handling of your financial and trading data, please contact us at: