Ooln Privacy Policy

Introduction

Ooln, Inc. ("Ooln," "we," "us," or "our") is committed to protecting your privacy and maintaining the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you use our website, mobile application, AI assistants (including Wendy), and related services (collectively, the "Services").

By using our Services, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with these practices, you should not use the Services.

About Wendy (Our AI Assistant)

Wendy is Ooln's AI-powered trading companion designed to help users reflect on decisions, surface behavioral patterns, and improve consistency. Wendy:

• Interacts with users via chat-based interfaces (e.g., web, messaging platforms)
• Analyzes trading behavior, journal entries, and platform interactions
• Provides educational insights, behavioral prompts, and performance summaries

Wendy does not place trades, access funds, or execute orders on your behalf. Any future functionality involving order routing or broker actions will require explicit opt-in and will be governed by updated Terms and disclosures.

Information We Collect

1. Personal Information You Provide

Account Information:

• Name and contact information (e.g., email address)
• Account credentials and authentication data
• Optional profile details you choose to provide

Trading and Financial Information:

Ooln uses secure, token-based authentication (e.g., OAuth) when integrating with third-party brokerages and does not store:

• Trading history and transaction records (when accounts are linked)
• Portfolio holdings and performance data
• Subscription and billing information (if applicable)

Conversational and Behavioral Data (Wendy):

• Messages and prompts exchanged with Wendy
• Reflections, journal entries, and responses to behavioral questions
• Signals related to trading behavior (e.g., frequency, timing, sizing patterns)

This data is used to personalize your experience and help identify behavioral patterns over time.

Preferences and Settings:

• Trading goals and self-reported objectives
• Risk and behavior profiling responses
• Notification and communication preferences

2. Information We Collect Automatically

Usage Data:

• Feature usage and interaction patterns
• Time spent in different areas of the platform
• Responses to insights, prompts, and challenges

Technical Information:

• Device type, operating system, and browser
• IP address and approximate location
• Session data, logs, and timestamps
• Cookies and similar technologies

AI Improvement Data:

• Aggregated and anonymized interaction patterns
• Effectiveness of prompts and behavioral interventions
• Feedback on AI-generated insights

3. Information from Third Parties

Brokerage Integrations (With Permission):

• Account balances and holdings
• Executed trades and confirmations

Market and Data Providers:

• Real-time and historical market data
• Volatility, pricing, and reference data

Identity & Security Services (If Applicable):

• Fraud prevention and abuse detection signals

How We Use Your Information

1. Core Service Delivery

• Operate and maintain your Ooln account
• Enable Wendy to provide personalized behavioral insights
• Generate performance summaries and reflections
• Deliver product updates, alerts, and support communications

2. Behavioral Analysis and Education

• Identify patterns such as overtrading, oversizing, or emotional decision-making
• Surface personalized prompts and corrective exercises
• Track progress over time to support consistency

3. Product Development and AI Improvement

• Improve Wendy's responses and coaching effectiveness
• Train and evaluate models using aggregated, anonymized data
• Develop new features and tools

4. Legal, Security, and Compliance

• Prevent fraud, abuse, and unauthorized access
• Enforce our Terms and policies
• Comply with applicable laws and regulations

How We Share Your Information

1. Service Providers

We may share information with trusted vendors that help operate the Services, such as:

• Cloud infrastructure and data storage providers
• Analytics and monitoring services
• Payment processors
• Customer support tools

These providers are contractually obligated to protect your information and use it only for authorized purposes.

2. Legal and Safety Disclosures

Information may be disclosed:

• To comply with legal obligations or valid government requests
• To investigate or prevent fraud and security incidents
• To protect the rights, safety, and property of Ooln and users

3. Aggregated and Anonymized Data

We may share anonymized, non-identifiable data for research, analytics, and product improvement purposes.

Data Security and Retention

Security Measures

We use industry-standard safeguards, including:

• Encryption in transit and at rest
• Role-based access controls
• Monitoring and incident response procedures

No system can be guaranteed 100% secure, but we take reasonable measures to protect your data.

Data Retention

• Account and conversational data: retained while your account is active
• Trading and performance data: retained as needed for analysis and compliance
• Aggregated AI training data: retained without personal identifiers

You may request deletion of your account and associated data at any time, subject to legal requirements.

Your Rights and Choices

You may:

• Access and update your information
• Request export or deletion of your data
• Control communication preferences
• Object to or restrict certain processing where applicable

California (CCPA) and EU (GDPR) Rights

Eligible residents have additional rights, including access, deletion, and non-discrimination. Ooln does not sell personal information.

Cookies and Tracking

We use essential, analytics, and preference cookies to operate and improve the Services. You can manage cookies through browser settings, though some features may be limited.

International Data Transfers

Your information may be processed in the United States or other jurisdictions where our providers operate. Appropriate safeguards are applied where required by law.

Children's Privacy

The Services are not intended for individuals under 18. We do not knowingly collect data from children.

Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated through the platform or via email. Continued use of the Services constitutes acceptance of the updated policy.

Contact Us

Ooln, Inc.
Privacy Officer
Email: privacy@ooln.com
Address: 13500 Lyndhurst St., Austin, TX 78717

We aim to respond to verified privacy requests within 30 days, as required by law.