Privacy Policy

1. Data Controller Information

Smart Stock Analysis LLC is the data controller responsible for your personal information.

Headquarters: 2100 Geng Road, Suite 210, Palo Alto, CA 94303, USA
Data Protection Officer: [email protected]
EU Representative: GDPR-Rep.eu, Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK Representative: UK-Rep Ltd., 5 Fleet Place, London EC4M 7RD, United Kingdom

2. Information We Collect

2.1 Personal Information

Data Category | Purpose | Legal Basis | Retention Period

Contact Data
Phone numbers, messaging app IDs (WhatsApp, LINE, KakaoTalk, Band)

Service delivery, customer support

Consent, Contract

2 years after last contact

Usage Data
Search queries, analysis requests, interaction patterns

Service improvement, personalization

Legitimate Interest

12 months

Technical Data
IP addresses, device info, browser data

Security, fraud prevention

Legitimate Interest

6 months

Communication Records
Message content, timestamps, delivery status

Quality assurance, compliance

Contract, Legal Obligation

3 years

2.2 Automatically Collected Information

• Cookies and Tracking Technologies: Essential, analytics, marketing, and social media cookies
• Log Data: Access times, pages visited, referrer URLs, user agent strings
• Device Information: Operating system, browser type, screen resolution, language preferences
• Location Data: Approximate location based on IP address (country/region level)

3. Messaging Platform Data Processing

3.1 WhatsApp Business Integration

Data Collected:
• Phone numbers and WhatsApp IDs
• Message content and delivery receipts
• Profile information (name, profile picture if shared)
• Message timestamps and read status

Data Protection:
• End-to-end encryption maintained by WhatsApp
• Business API compliance with WhatsApp policies
• Opt-out available through blocking or messaging "STOP"
• No data sharing with Facebook/Meta for advertising

3.2 LINE Official Account (Japan/Korea/SEA)

Data Collected:
• LINE User IDs and display names
• Message exchanges and rich menu interactions
• Friend/unfriend status and blocking events
• Location data (only if explicitly shared)

Compliance:
• APPI (Japan) compliance for personal information protection
• PIPA (Korea) compliance for personal data processing
• Data localization in respective countries when required

3.4 Band Community Platform

Data Collected:
• Band user profiles and group memberships
• Posts, comments, and reactions
• Community engagement metrics
• File and media sharing activities

4. How We Use Your Information

4.1 Primary Purposes

• Service Delivery: Providing stock analysis, market insights, and educational content
• Customer Support: Responding to inquiries via messaging platforms
• Personalization: Customizing analysis based on user preferences and history
• Communication: Sending requested reports, alerts, and updates

4.2 Secondary Purposes (with Consent)

• Marketing Communications: Promotional messages about new features or services
• Research and Analytics: Understanding user behavior to improve our platform
• Product Development: Developing new features based on usage patterns

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We share data with carefully vetted service providers under strict contractual obligations:

• Cloud Infrastructure: AWS, Google Cloud (data processing agreements in place)
• Analytics Services: Google Analytics (anonymized data only)
• Messaging APIs: WhatsApp Business, LINE Business Connect, KakaoTalk Business
• Customer Support: Zendesk, Intercom (encrypted data transmission)

5.2 Legal Disclosures

We may disclose information when required by law or to:
• Comply with legal process or government requests
• Protect our rights, property, or safety
• Investigate fraud or security incidents
• Enforce our terms of service

6. International Data Transfers

Your data may be transferred and processed in countries outside your residence:

Adequacy Decisions (GDPR-approved):
• Japan, South Korea, Singapore, New Zealand, United Kingdom

Standard Contractual Clauses:
• United States, other countries without adequacy decisions

Additional Safeguards:
• Encryption in transit and at rest
• Regular security assessments
• Data minimization practices
• Right to object to international transfers

7. Your Privacy Rights

7.1 Universal Rights (All Users)

• Access: Request copies of your personal data
• Rectification: Correct inaccurate or incomplete information
• Deletion: Request erasure of your data ("Right to be Forgotten")
• Data Portability: Receive your data in machine-readable format
• Opt-out: Unsubscribe from marketing communications

7.2 Enhanced Rights (EU/UK/California Residents)

• Restriction of Processing: Limit how we use your data
• Object to Processing: Oppose data use for legitimate interests
• Automated Decision-Making: Human review of algorithmic decisions
• Data Protection Authority: Lodge complaints with supervisory authorities

7.3 How to Exercise Your Rights

Contact us through any of these methods:
• Email: [email protected]
• WhatsApp: Message "PRIVACY REQUEST" to our business account
• LINE: Send "データ削除" (data deletion) or "PRIVACY" to our official account
• KakaoTalk: Message "개인정보 요청" (personal information request)

Response Time: We will respond within 30 days (GDPR) or as required by applicable law.

8. Cookie Policy

Cookie Type | Purpose | Consent Required | Retention

Essential Cookies

Platform functionality, security, user authentication

No (legitimate interest)

Session/1 year

Analytics Cookies

Usage statistics, performance monitoring

Yes

2 years

Marketing Cookies

Personalized advertising, conversion tracking

Yes

1 year

Social Media Cookies

Integration with messaging platforms

Yes

6 months

Cookie Management: You can control cookies through browser settings or our cookie preference center. Note that disabling essential cookies may affect platform functionality.

9. Data Security

We implement industry-standard security measures:

Technical Safeguards:
• AES-256 encryption for data at rest
• TLS 1.3 for data in transit
• Multi-factor authentication for admin access
• Regular security audits and penetration testing

Organizational Measures:
• Employee privacy training programs
• Access controls and role-based permissions
• Data breach response procedures
• Regular backup and disaster recovery testing

Messaging Platform Security:
• End-to-end encryption maintained by respective platforms
• Secure API integrations with rate limiting
• Message content scanning for malicious content

10. Data Retention

We retain personal data only as long as necessary:

• Active Users: Data retained while account is active plus 2 years
• Inactive Users: Data deleted after 3 years of inactivity
• Marketing Data: Removed immediately upon opt-out
• Legal Requirements: Some data retained longer for compliance (e.g., financial records)
• Aggregated Data: Anonymous analytics data may be retained indefinitely

11. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover we have collected data from a child, we will delete it immediately and terminate any associated accounts.

Parental Rights: Parents can request deletion of their child's data by contacting [email protected] with proof of guardianship.

12. Changes to Privacy Policy

We may update this policy periodically. Material changes will be communicated through:
• Email notifications to registered users
• In-app notifications on messaging platforms
• Prominent website notices

Continued use after changes constitutes acceptance of the updated policy.

13. Contact Information

Privacy Inquiries

Data Protection Officer: [email protected]
General Inquiries: [email protected]
Security Issues: [email protected]

Postal Address:
Smart Stock Analysis LLC
Attn: Privacy Officer
2100 Geng Road, Suite 210
Palo Alto, CA 94303, USA

EU Representative:
GDPR-Rep.eu
Avenue Huart Hamoir 71
1030 Brussels, Belgium
Email: [email protected]

Business Hours: Monday - Friday, 9:00 AM - 6:00 PM PST
Emergency Privacy Issues: +1 (650) 555-0123