COTES AI, INC. PRIVACY POLICY
Effective Date: June 7, 2026 Last Updated: June 7, 2026
OUR COMMITMENT TO YOUR PRIVACY
Cotes AI, Inc. ("Cotes AI," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.cotes.ai and use our spectral analysis screening services (collectively, the "Services").
Please read this Privacy Policy carefully. By using our Services, you consent to the practices described in this Privacy Policy.
1. INFORMATION WE COLLECT
Information You Provide Directly
When you register for an account or subscribe to our Services, we collect:
- Account Information: Email address, username, and password
- Billing Information: Billing address and transaction history. Your payment card details are processed directly by our PCI-compliant payment processor (Stripe) and are never stored on our servers. We only receive a secure token reference and the last four digits of your card for display purposes.
- Communication Data: Information from your emails or support requests to us
Note: We do NOT collect sensitive financial information such as:
- Your investment portfolio details
- Trading account information
- Net worth or income data
- Social Security Numbers
- Bank account numbers
- Credit card numbers (these go directly to Stripe)
Information Collected Automatically
When you use our Services, we automatically collect:
- Usage Data: Pages viewed, features used, patterns analyzed, time spent on site
- Device Information: IP address, browser type, operating system, device identifiers
- Log Data: Access times, referring URLs, clickstream data
- Cookies and Similar Technologies: See Section 6 for details
Information We Do NOT Collect
As a publisher operating under the publisher's exclusion, we intentionally do NOT collect:
- Personal investment objectives or strategies
- Risk tolerance information
- Financial situation details
- Investment experience data
- Any information that would be used to provide personalized investment advice
2. HOW WE USE YOUR INFORMATION
We use the collected information for the following purposes:
Service Delivery
- Provide access to our spectral analysis tools
- Process subscription payments
- Send service-related communications
- Provide customer support
Service Improvement
- Analyze usage patterns to improve our algorithms
- Develop new features and tools
- Fix bugs and technical issues
- Conduct research on pattern recognition effectiveness
Legal Compliance
- Comply with applicable laws and regulations
- Enforce our Terms of Service
- Protect against fraud and unauthorized access
- Respond to legal process
Marketing (with your consent)
- Send newsletters about market patterns and technical analysis education
- Inform you about new features or services
- Provide educational content about spectral analysis
We will NEVER use your information to:
- Provide personalized investment recommendations
- Create individual investment profiles
- Target you with specific investment opportunities
- Sell or rent your personal information to third parties
3. HOW WE SHARE YOUR INFORMATION
We share your information only in the following limited circumstances:
Service Providers
We share information with trusted third-party service providers who assist us with:
- Payment processing (Stripe) — Only receives payment data directly from you
- Email delivery (SendGrid, Mailchimp, etc.)
- Cloud storage (AWS, Google Cloud, etc.)
- Analytics (Google Analytics, etc.)
- Customer support tools
All service providers are contractually obligated to protect your information and use it only for providing services to us.
Legal Requirements
We may disclose information if required by:
- Court order or subpoena
- Government or regulatory request
- Law enforcement investigation
- To protect our rights or property
- To prevent fraud or cybersecurity threats
Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity.
Aggregated Data
We may share aggregated, anonymized data that cannot identify you personally for research or marketing purposes.
With Your Consent
We will share information for any other purpose with your explicit consent.
4. DATA SECURITY
We implement industry-standard security measures to protect your information:
Technical Safeguards
- Encryption of data in transit (TLS/SSL)
- Encryption of sensitive data at rest
- Secure cloud infrastructure with regular security audits
- Multi-factor authentication available
- Regular security updates and patches
Payment Security
We never store your credit card information. All payment data is processed directly through Stripe, a PCI Service Provider Level 1 certified payment processor. This is the highest level of certification available in the payments industry. Your card details go directly to Stripe's secure servers and never touch our systems.
Administrative Safeguards
- Limited employee access on a need-to-know basis
- Confidentiality agreements with all employees
- Regular security training
- Incident response procedures
Physical Safeguards
- Secure data center facilities
- Access controls and monitoring
- Redundant backup systems
Important: While we use reasonable efforts to protect your information, no security system is impenetrable. We cannot guarantee absolute security of your data.
5. YOUR DATA RIGHTS AND CHOICES
Access and Portability
You have the right to:
- Request a copy of your personal information
- Download your data in a portable format
- Access your account information at any time
Correction and Update
You can:
- Update your account information through your profile
- Contact us to correct any inaccurate data
- Manage your communication preferences
Deletion
You may request deletion of your account and personal information, subject to:
- Legal retention requirements
- Completion of pending transactions
- Legitimate business purposes
Opt-Out Rights
You can opt out of:
- Marketing emails (via unsubscribe link)
- Non-essential cookies
- Analytics tracking
- Third-party information sharing (where applicable)
Do Not Sell
We do NOT sell your personal information. You have the right to confirm this at any time.
6. COOKIES AND TRACKING TECHNOLOGIES
What We Use
We use the following types of cookies and similar technologies:
Essential Cookies
- Required for basic site functionality
- Cannot be disabled
Analytics Cookies
- Help us understand how you use our Services
- Google Analytics with IP anonymization
Preference Cookies
- Remember your settings and preferences
- Enhance your user experience
Your Cookie Choices
- Most browsers allow you to manage cookie preferences
- You can delete cookies at any time
- Disabling cookies may limit functionality
Do Not Track
We currently do not respond to "Do Not Track" browser signals, as there is no industry standard.
7. THIRD-PARTY LINKS
Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.
8. CHILDREN'S PRIVACY
Our Services are not directed to individuals under 18 years of age. We do not knowingly collect information from children. If you believe we have collected information from a child, please contact us immediately.
9. INTERNATIONAL USERS
Our Services are operated from the United States. If you access our Services from outside the U.S.:
- Your information will be transferred to and processed in the U.S.
- U.S. privacy laws may differ from your jurisdiction
- By using our Services, you consent to this transfer
10. STATE-SPECIFIC RIGHTS
California Residents (CCPA)
You have additional rights including:
- Right to know what personal information we collect, use, and share
- Right to delete your personal information
- Right to opt-out of the "sale" of personal information (we do not sell data)
- Right to non-discrimination for exercising your rights
European Users (GDPR)
If GDPR applies, you have rights including:
- Right to access, correct, and delete your data
- Right to data portability
- Right to object to processing
- Right to lodge a complaint with supervisory authorities
Other States
Residents of Virginia, Colorado, Connecticut, and other states with privacy laws may have similar rights.
11. DATA RETENTION
We retain your information for as long as necessary to:
- Provide our Services
- Comply with legal obligations
- Resolve disputes
- Enforce our agreements
Generally:
- Account information: Duration of account plus 3 years
- Transaction records: 7 years (tax requirements)
- Usage data: 2 years
- Marketing data: Until opt-out plus 90 days
12. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy to reflect changes in:
- Our data practices
- Legal requirements
- Our Services
We will notify you of material changes by:
- Email notification
- Prominent notice on our website
- Requiring acknowledgment for continued use
13. HOW TO CONTACT US
For privacy-related questions, requests, or concerns:
Data Protection Officer Cotes AI, Inc. 16192 Coastal Hwy Lewes, DE 19958 Email: privacy@cotes.ai
Response Time: We will respond to your request within 30 days, or as required by applicable law.
14. PRIVACY NOTICE SUMMARY
Quick Reference:
- ✅ We collect minimal information needed to provide our Services
- ✅ We do NOT store credit card information (processed by Stripe)
- ✅ We do NOT collect investment portfolio information
- ✅ We do NOT sell your personal information
- ✅ We do NOT provide personalized investment advice
- ✅ You can request access, correction, or deletion of your data
- ✅ We use industry-standard security measures
- ✅ You can opt-out of marketing communications
BY USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO ITS TERMS.
Document Version: 1.0 Effective Date: June 7, 2026 Last Updated: June 7, 2026
© 2026 Cotes AI, Inc. All rights reserved.