Legal

Privacy Policy

This Policy explains what information Sequency collects, why we use it, when we share it, and the choices available to you.

Effective August 16, 2026

1. Scope

This Privacy Policy applies to Sequency, Inc. (“Sequency,” “we,” “us,” or “our”) and our websites, applications, market-intelligence tools, AI features, brokerage connections, and related services (collectively, the “Services”). It does not govern a third-party service’s independent practices, including those of a broker, exchange, data provider, or website you visit.

2. Information we collect

Depending on how you use Sequency, we may collect:

  • Account and identity information, such as your name, email address, authentication identifiers, subscription status, and account settings.
  • Financial-account and brokerage information, such as account identifiers, account type and capabilities, balances, buying power, holdings, positions, orders, fills, transaction history, and connection status.
  • Connection credentials and tokens, such as encrypted API credentials, authorization tokens, or session identifiers needed to connect a supported provider. The exact information depends on the connection method and provider.
  • Trading and risk preferences, including watchlists, strategies, execution modes, approvals, risk limits, alerts, and kill-switch or other safety-control settings.
  • Prompts and product content, such as messages, research requests, uploaded materials, saved analyses, feedback, and AI-generated responses associated with your use of the Services.
  • Usage and device information, such as IP address, browser and device type, operating system, pages viewed, feature interactions, referring URLs, timestamps, cookies or similar technologies, and diagnostic logs.
  • Communications, including messages you send to support and records of service-related notices.
  • Payment information, such as subscription and billing status. Payment card details may be collected directly by our payment processor rather than Sequency.

3. Sources of information

We collect information directly from you, automatically from your browser or device, from brokers and other financial providers you choose to connect, and from service providers that help us operate the Services. We also process market data, public filings, news, and other public or licensed information, which may include information about individuals in a professional or public capacity.

4. How we use information

We use information to:

  • create, authenticate, secure, and administer accounts;
  • connect and synchronize accounts you authorize;
  • display portfolio information and provide research, analytics, alerts, and AI features;
  • stage, transmit, monitor, reconcile, and audit user-authorized trading activity;
  • apply execution modes, permissions, risk limits, and safety controls;
  • provide customer support and send service, security, and policy notices;
  • process subscriptions and maintain billing records;
  • measure performance, troubleshoot errors, improve reliability, and develop features;
  • detect fraud, abuse, security incidents, and violations of our Terms;
  • comply with law, lawful requests, and applicable recordkeeping obligations; and
  • create aggregated or de-identified information that does not reasonably identify you.

5. AI processing

Some features send prompts, selected account context, market information, and related instructions to AI service providers so they can generate requested outputs. We limit the information sent to what is reasonably needed for the feature. Sequency does not permit third-party AI providers to use your connected brokerage data or private prompts to train their general-purpose models unless we first disclose that use and obtain any consent required by law.

We may review or use prompts, responses, and associated diagnostics to provide support, investigate abuse, evaluate quality and safety, and improve Sequency. Where practical, we use aggregated or de-identified information for product analysis and development.

6. How we share information

We may disclose information:

  • To service providers that support hosting, databases, authentication, analytics, communications, customer support, payments, security, market data, AI, and brokerage connectivity, under contractual restrictions appropriate to their role.
  • To brokers and financial providers when needed to establish a connection, retrieve account information, transmit an instruction you authorize, or reconcile account and order status.
  • For legal and safety reasons when we reasonably believe disclosure is required by law or needed to protect rights, safety, markets, users, or the integrity of the Services.
  • In a business transaction involving a financing, merger, acquisition, reorganization, bankruptcy, or sale of assets, subject to appropriate safeguards.
  • With your direction or consent or when you intentionally make information public.

We do not sell personal information for money. We do not use connected brokerage data, order history, or private prompts for third-party behavioral advertising. Depending on your jurisdiction, certain analytics technologies may be treated as a “sale” or “sharing” even when no money is exchanged; you may contact us about the choices available to you.

7. Cookies and analytics

We may use cookies and similar technologies to keep you signed in, remember settings, secure the Services, understand usage, and diagnose performance. Browser settings may allow you to block or delete cookies, but some features may not function correctly without essential cookies. We do not respond to every browser “Do Not Track” signal because there is not yet a consistent industry standard for those signals.

8. Data retention

We retain information for as long as reasonably necessary to provide the Services, maintain security and audit records, resolve disputes, enforce agreements, and comply with legal obligations. Retention periods vary by data type and purpose. Deleting your Sequency account does not automatically delete information maintained independently by a broker or another third party. Some records may remain in backups or be retained where required for fraud prevention, financial reconciliation, or legal compliance.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information, which may include encryption in transit, encryption or protected storage for sensitive credentials, access controls, logging, environment separation, and vendor review. No method of transmission or storage is completely secure, and we cannot guarantee that information will never be accessed, lost, misused, or altered.

10. Your choices and privacy rights

You may update certain account settings in the Services, disconnect supported accounts, revoke provider permissions, and choose whether to enable optional trading features. Depending on where you live, you may have the right to request access, correction, deletion, portability, or a copy of certain personal information; to object to or limit certain processing; or to appeal our response. You also may have the right not to receive discriminatory treatment for exercising a privacy right.

To submit a privacy request, email support@sequency.sh. We may verify your identity and authority before completing a request. You may use an authorized agent where applicable law permits, subject to verification.

11. Communications

We may send transactional messages about your account, security, connected services, orders, policy changes, or service availability. You cannot opt out of messages necessary to provide or secure the Services. Where we send marketing communications, you may use the unsubscribe mechanism in the message or contact us.

12. International processing

Sequency and its service providers may process information in the United States and other countries whose data-protection laws may differ from those where you live. Where required, we use appropriate safeguards for cross-border transfers.

13. Children

The Services are not directed to children under 18, and we do not knowingly collect personal information from children under 18. If you believe a child has provided us with personal information, contact us so we can investigate and take appropriate action.

14. Changes to this Policy

We may update this Privacy Policy as our Services or legal obligations change. We will post the revised Policy and update the effective date. If a change materially affects how we use personal information, we may also provide notice through the Services or by email.

15. Contact us

Questions or requests concerning this Privacy Policy may be sent to support@sequency.sh.