Quant Alpha LLC – Privacy Policy

Introduction

Your privacy is important to us. This Privacy Policy explains how Quant Alpha LLC (“Quant Alpha,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal information. This Policy applies to information we collect through our website and any related online services (collectively, our “Services”). As a registered investment adviser, we are also subject to SEC Regulation S-P (Privacy of Consumer Financial Information), which governs how we handle your non-public personal information. We are committed to safeguarding your data in accordance with these regulations and industry best practices.

By using Quant Alpha’s website or Services, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with our practices, please do not use the website or submit personal information.

Information We Collect

We only collect information that is necessary to provide our investment advisory Services and to comply with legal/ regulatory requirements. This information falls into a few categories:

• Information You Provide Directly: When you register for our Services or inquire about our strategies, we collect personal information such as your name, email address, and your strategy selection or risk profile inputs. For example, you may fill out an online form with your name and email to receive more information, or create an account where you provide details about your investment objectives and select a strategy. We may also collect other contact information (like a phone number or mailing address) during the onboarding process, or if you communicate with us by email and provide such details.

• Account and Financial Information: If you become a client, as part of account setup we will collect certain necessary information either directly or via our custodian Interactive Brokers. This can include data needed to open your brokerage account (which might involve gathering details like your date of birth, Social Security number, financial status, etc., which IB’s onboarding system will securely process). Quant Alpha itself primarily collects your strategy preferences and risk tolerance information through our website questionnaire. We do not collect or store full sensitive personal identifiers like SSN or driver’s license on our site (those are handled by IB’s secure systems during account creation). We do, however, maintain records of your account number at IB and information about your holdings/transactions in order to manage your portfolio.

• Usage Data: Like many websites, we automatically collect certain information about your use of our website to help us improve our Services and ensure security. This includes technical information such as your IP address, browser type, device type, access times, pages viewed, and referring website. We may also use cookies or similar technologies (described below) to collect usage statistics and to remember your preferences (e.g., keeping you logged in during a session). This usage data is generally aggregated and not intended to personally identify you, but it might be associated with your account if you are logged in.

• Cookies and Tracking Technologies: Cookies are small text files that websites store on your device to record data. Quant Alpha uses cookies to enable site functionality (for example, to maintain your login session as you navigate our platform) and to understand how users interact with our site. We may use both session cookies (which expire when you close your browser) and persistent cookies (which remain for a set period or until deleted). Cookies help us recognize you when you return, customize your experience (such as showing relevant content based on your chosen strategy), and collect analytics about site traffic. You can control cookies through your browser settings – for instance, you may choose to block or delete cookies – but note that disabling cookies may affect certain features of our Service (like remaining logged in or having certain preferences remembered). We do not use cookies to track you across third-party websites, and we do not currently respond to Do Not Track signals (as there is no consistent industry standard for compliance). Our use of cookies is primarily limited to our site’s functioning and our own analytics.

• Communications: If you contact us with questions, feedback, or for support (via email or through any contact forms), we will receive whatever information you choose to include in that communication. This may include your email address, the content of your message, and any attachments or additional data you provide. We will use this information to respond to you and to improve our support services.

We do not intentionally collect any sensitive personal information outside of what is needed for providing our services (for example, we don’t ask for racial or ethnic origin, religious or philosophical beliefs, health, or biometric data, etc.). Please refrain from submitting any sensitive personal data to us that we do not request. We also do not seek to collect information from children. Our Services are not intended for individuals under 18, and we do not knowingly collect personal information from minors. If we learn that we have inadvertently received information from a child under 18, we will delete it. (See Children’s Privacy below.)

How We Use Your Information

Quant Alpha uses the collected information for the following purposes, all aimed at delivering and improving our investment advisory Services in a legally compliant manner:

• To Provide Investment Advisory Services: The primary use of your personal information is to operate our advisory platform. For example, we use the information you provide (like your risk profile and strategy choice) to generate investment advice and manage your account accordingly. Your email and contact info are used to set up your user account, verify your identity when logging in, and maintain your profile. We also use account and financial information to facilitate the linking of your Quant Alpha account with your brokerage account at Interactive Brokers and to manage trades on your behalf.

• To Communicate with You: We use your contact information (email and/or phone) to send important updates and reports. This includes:

  • Service and Account Communications: We will send onboarding emails, confirmations of actions (like when you sign up or change your strategy), periodic portfolio updates or performance reports, notice of any changes to our services or policies, and other account-related announcements. For example, if our algorithm triggers a significant change in your portfolio allocation, you might receive a notification or explanation via email or through the website messaging center.

  • Regulatory and Disclosure Communications: As required by law, we may send you our annual privacy notice, updates to our Form ADV or this Privacy Policy, or any notices about security incidents if they occur. We aim to keep you informed of your rights and our obligations.

  • Client Education and Insights: With your permission, we might also send occasional educational content or newsletters about market insights, product updates, or new features. We understand your inbox is busy, so we keep such emails infrequent and relevant. You can opt out of non-essential communications (see Your Choices below).

• For Customer Support: If you reach out to us, we will use the information provided to assist you and resolve issues. For instance, if you email support with a question about linking your IB account, our team will access your account details as needed to help troubleshoot.

• To Improve and Personalize our Services: We analyze the usage data (e.g., site traffic patterns, features used, time spent on certain pages) to understand how clients use our platform. This helps us identify bugs, improve the user interface, and prioritize new features. It also allows us to personalize your experience – for example, remembering your dashboard settings or which content you’ve already seen. We may use analytics tools (like Google Analytics or our own internal tools) to perform this analysis, but any third-party analytics providers will be bound to use data only for our purposes and not share it. User feedback (from surveys or communications) is also used to enhance our service.

• To Ensure Security and Prevent Misuse: We monitor login activity and use of our site to protect against fraudulent or unauthorized access. Information such as IP addresses and device info helps us detect and prevent security incidents. For example, we might detect a login from a new device and send you a verification email to confirm it’s you. We also may use certain data to enforce our Terms of Use – for example, ensuring that one user isn’t creating multiple fraudulent accounts or scraping data from our site.

• Compliance with Legal Obligations: As a financial institution, we have certain regulatory obligations. We use personal information to fulfill these – for example:

  • Know-Your-Client (KYC) and Anti-Money Laundering checks: Information provided in account registration (like identity details) may be used to verify your identity, sometimes with the help of IB’s systems. We must ensure we are not providing services to prohibited persons or engaging in transactions that violate AML laws.

  • Recordkeeping: We maintain records of communications and advice as required by the SEC. Your information will be stored in those records (e.g., logs of advice given through the platform and correspondence with you).

  • Regulatory Reporting: We might use aggregated data to file any required reports (for example, certain filings might require us to report the number of clients or geographic distribution, etc., but not your personal details). If we were ever examined or audited by regulators, we would need to provide access to client records, which include personal information.

  • Other Legal Use: If necessary, we will use or disclose information to exercise or defend legal claims, to comply with subpoenas or court orders, or to cooperate with law enforcement investigations (see Information Sharing, below).

We will not use your personal information for purposes unrelated to our services without your consent. We do not use your data to make unrelated automated decisions (for example, we don’t use your personal data for automated credit scoring or marketing profiling beyond our investment advisory context). Any new purpose for which we might use your data will be disclosed to you and, if required, we will obtain your consent.

Cookies and Tracking Technologies

As noted, Quant Alpha uses cookies and similar technologies to enhance your experience. Here’s more detail on how we handle these:

• Types of Cookies We Use:

  • Essential Cookies: These are necessary for our website to function. For example, when you log in, an authentication cookie keeps you logged in as you navigate between pages. Without this, you would have to re-enter your credentials for every new page. Essential cookies are always active because the site won’t work properly without them.

  • Analytics Cookies: These cookies collect information about how visitors use our site (pages visited, errors encountered, etc.). We use this info to compile reports and improve site functionality. We might use a third-party analytics service (like Google Analytics) that sets its own cookies to help us understand site usage. However, we do not allow analytics providers to use your data for their own purposes – it’s only for our analysis.

  • Preference Cookies: These remember choices you’ve made to personalize your experience. For example, if our platform has settings for display preferences or if you dismissed a one-time alert, a cookie might remember that so it doesn’t show again.

  • No Third-Party Marketing Cookies: We do not use third-party advertising cookies or tracking pixels for external advertising. We do not serve ads on our site, and we do not share behavior data with advertisers.

• Managing Cookies: Most web browsers let you control and/or delete cookies. You can set your browser to refuse certain cookies or to notify you before accepting cookies. If you choose to disable cookies entirely, note that our website’s login and interactive features may not work correctly. (For example, if you block all cookies, our site might not remember that you are logged in, and you might be unable to access your account.) We recommend allowing at least the essential cookies for an optimal experience.

• Other Tracking: We do not use invasive tracking techniques. We do not use any form of cross-site tracking for marketing. If in the future we incorporate mobile app usage, we will ensure any tracking there is similarly limited and disclosed. We also ensure any third-party tools we use (like analytics or error tracking) are under contractual obligation to keep data secure and use it only for providing services to us.

For more information on cookie management, you can refer to your browser’s help documentation. By continuing to use our site without changing your settings, you consent to our use of cookies as described here.

Information Sharing and Disclosure

Quant Alpha does not sell or rent your personal information to third parties for their own marketing or commercial purposes. We only share your information in the following contexts, as necessary to run our business or as required by law:

• With Service Providers (Processors): We employ trusted third-party companies to support our operations. These service providers are bound by contractual obligations to keep your information confidential and to use it only for the purposes of providing services to us. Key service providers include:

  • Interactive Brokers LLC: as our chosen custodian and brokerage provider, IB will necessarily receive personal information when you open an account (such as your identity and financial information). IB’s use of your data is governed by their privacy policy and regulatory obligations. They primarily use it to fulfill their role in servicing your account (e.g., regulatory KYC, trade execution, account statements). We may share with IB certain data from our side (for instance, linking your IB account number to our systems, or sharing your email to help set up electronic communications). In turn, IB shares with us information about your account necessary for management (like holdings, transactions, balances). Our relationship with IB is covered by a separate agreement ensuring compliance with privacy laws.

  • Email and Communication Tools: We may use an email service provider or CRM system to send out communications (for example, Mailchimp, SendGrid, or similar services). These providers would handle your name and email address to send emails on our behalf (such as newsletters or alerts). They are not allowed to use your email for anything else.

  • Data Hosting and IT Infrastructure: Quant Alpha likely uses cloud hosting for our website and databases (for example, AWS, Azure, or other secure cloud services). Your data is stored and processed on those platforms, but under Quant Alpha’s control and encrypted where appropriate. These providers might incidentally have access to data for backup or maintenance, but again, they are not permitted to use or disclose it.

  • Analytics/Software Tools: If we use third-party analytics or error monitoring (like Google Analytics, Sentry, etc.), they will process usage data (possibly including IP addresses or device info). We configure these tools to avoid capturing any unnecessary personal details, and we review their privacy commitments to ensure your data is handled properly.

  • Professional Advisors: We may share information with our attorneys, accountants, or auditors on a need-to-know basis. For example, if we undergo a compliance audit, the auditor might review client files (under strict confidentiality). Or if a legal issue arises, our counsel might need to see certain records. In all cases, these professionals are obligated to keep such information private.

• For Legal and Regulatory Compliance: We may disclose personal information as required or permitted by law, such as:

  • Regulators and Government Agencies: We may be required to share information with the SEC (our regulator) during examinations or inquiries. For instance, SEC examiners may review client profiles, transactions, and correspondence to ensure we are complying with regulations. We will comply with any such requests in a controlled manner (usually onsite or secure submission) and only provide what is requested.

  • Law Enforcement: If law enforcement or judicial authorities lawfully request information (for example, via a subpoena, court order, or similar legal process), we may be compelled to provide the requested data. We will ensure any request is valid and limited in scope. If allowed, we would inform the affected user of such a request (unless it's an emergency or legally prohibited from notifying).

  • To Protect Rights and Safety: We might share information if we believe it’s necessary to protect the rights, property, or safety of Quant Alpha, our clients, or others. This could include sharing data to investigate or prevent fraud, abuse of our services, or security incidents. For example, if someone attempted to hack accounts, we might share relevant logs with cybersecurity experts or law enforcement to address the issue.

  • As Required by Applicable Law: In addition to U.S. federal law (SEC regulations), we also comply with state laws regarding privacy. For instance, if we have California clients, we adhere to California privacy rights laws (see Your Privacy Rights below). If a state regulator (for example, a state securities division) has jurisdiction and requests information for a client in that state, we may provide it as needed.

• Business Transfers: If Quant Alpha LLC is ever involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, your information may be transferred as part of that transaction. For example, if another investment advisory firm acquires Quant Alpha, client information would typically be part of the assets transferred so that the new firm can continue to serve you. In such an event, we would require the new owner to honor the commitments we have made in this Privacy Policy regarding your data. We would also notify clients of the change and any choices they may have (for instance, you might choose to terminate service if you do not want to transition to a new provider).

• With Your Consent: In all other cases, we will seek your consent before sharing your personal information. For example, if you request that we provide your portfolio data to a third-party financial app or to your accountant, we would do so only with your explicit direction. Another example might be testimonials or success stories – we would not publish your name or story without getting your permission.

Data Security

We take data security seriously and have implemented a variety of safeguards to protect your personal information from unauthorized access, use, or disclosure. These measures include:

• Encryption: Our website uses SSL/TLS encryption (HTTPS) to secure data in transit between your browser and our servers. This means that any personal information (like your login credentials or any data you input on our site) is encrypted while it travels over the internet. Additionally, sensitive data stored in our databases (such as passwords) is encrypted or hashed at rest. For instance, we never store plain-text passwords – only password hashes (so even our own staff cannot read your password).

• Access Controls: Access to personal information within Quant Alpha is restricted to authorized personnel who need it to perform their job duties. For example, our support team can view your account details to assist you, but only after passing authentication checks. We enforce least-privilege principles, meaning each employee or service is limited to the minimum data and system access necessary. Administrative access to systems that contain personal data is protected with strong authentication (such as multi-factor authentication) and logging of access.

• Cloud Security: If we use cloud infrastructure (e.g., AWS), we utilize their security features like firewalls, network segmentation, and monitoring. Data is stored in secure data centers with physical security controls. We regularly update servers and software to apply security patches.

• Testing and Monitoring: We routinely monitor our systems for suspicious activity and regularly test our infrastructure for vulnerabilities. This may involve employing third-party security experts to perform penetration testing on our systems. Any issues identified are promptly addressed. We also monitor for any breaches or leaks and have an incident response plan in place.

• Employee Training and Policies: All Quant Alpha employees and any contractors with access to sensitive data are trained on confidentiality and security. We have internal policies regarding how to handle personal information, and violations of these policies can result in disciplinary action. Our team is educated about phishing and other social engineering risks to avoid inadvertently exposing client data.

• Data Backups: We maintain secure backups of critical data to prevent loss in case of hardware failure or other issues. These backups are encrypted and stored separately, with access limited to prevent any unauthorized restoration or viewing of data.

• Vendor Due Diligence: When we select any third-party service providers (as mentioned above), we evaluate their security practices. We choose reputable firms and ensure, contractually, that they also implement adequate security measures. For example, our cloud providers and email providers are industry-leading companies that invest heavily in security.

Despite our best efforts, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security. However, in the unfortunate event of a data breach that affects your personal information, we will notify you and the appropriate authorities as required by law, and we will take all reasonable steps to mitigate the issue and prevent future occurrences. We appreciate your understanding and cooperation — for instance, you also play a role in security by using a strong password, safeguarding your login credentials, and alerting us if you suspect any unauthorized activity on your account.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. In practice, this means:

• For Clients: If you become a client of Quant Alpha, we will retain your personal information for the duration of your client relationship and thereafter as required by regulatory recordkeeping rules. The SEC and other regulations generally require that we keep certain books and records (which may include communications and personal data) for a minimum of five years from the end of your relationship with us (and in some cases longer for specific records). We may keep information longer if we have a legitimate interest and it’s not prohibited by law – for example, retaining basic information to avoid re-onboarding you if you return, or keeping performance records for historical analysis – but always in compliance with privacy regulations.

• For Website Visitors/Prospects: If you provided contact information but did not become a client, we may retain that information for a reasonable period to follow up with you or as needed for our operations. If you ask to be removed from our contact list, we will delete your contact information (except maybe keeping a record of your request to not contact you, to honor it in the future). Usage data that is not linked to a personal account may be retained in aggregate form to improve our services, with no personal identifiers.

• Deletion of Data: When personal information is no longer required, we will either delete it or anonymize it so it can no longer be associated with you. For instance, if seven years have passed since you closed your account (exceeding regulatory requirements), we may remove personal details from our records, retaining only non-identifiable data for statistical purposes. However, do note that due to backup systems, some residual data might remain in archived/backup copies for a short time until those are cycled out – during which the data remains protected.

• Legal Holds: If we are in a legal dispute with you or are subject to an investigation that requires retaining data, we will preserve relevant information until it is resolved, regardless of the standard retention periods.

We aim not to keep data longer than necessary, but certain financial regulations mean we cannot always delete your data immediately upon request. We explain your rights next.

Your Privacy Rights and Choices

You have certain rights and choices regarding your personal information. Quant Alpha is committed to respecting and facilitating these rights as applicable:

• Access and Update: You can access and update much of your personal profile information directly by logging into your Quant Alpha account and editing your profile or settings. For example, you can correct your contact information, change your password, or update your risk questionnaire answers. If any information that you cannot change through the platform is incorrect or has changed (such as your address or other details), please contact us and we will update it. We will also, upon request, provide you with a summary of the personal information we have on file for you, to the extent required by law.

• Opt-Out of Communications: If you no longer wish to receive marketing or educational emails from us, you can opt out at any time. Each non-transactional email we send (such as a newsletter) will include an “unsubscribe” link in the footer. You can click that to stop receiving that type of email. Alternatively, you may contact us at support@quantalpha.net to request removal. Please note that even if you opt out of promotional communications, we will still send you important account and service-related messages (for example, we cannot stop sending notifications about changes to this Privacy Policy, or alerts about your account activity, unless you terminate your relationship with us entirely).

• Do Not Call or Mail: We generally communicate electronically, but if at any point we were to use phone or mail for outreach, you can request to be placed on our internal do-not-contact list for phone or physical mail.

• California Privacy Rights: (If you are a California resident) California law may provide you with additional rights regarding our use of your personal information. While as a financial institution we are largely governed by federal law (GLBA) rather than the California Consumer Privacy Act (CCPA) for client data, we still honor certain requests in the spirit of transparency. California residents may request: (1) a list of categories of personal information we have disclosed for direct marketing purposes (we do not disclose any for third-party marketing, so there should be none); (2) deletion of personal information, subject to the exceptions below; (3) to know more details about the data we have about you. We will treat this as similar to an access request, and provide the information we can. Regarding deletion: Because we are an SEC-regulated financial institution, we cannot delete certain data even if requested, due to legal record retention requirements. However, if you terminate service, we will stop actively using your data except for storage as needed for compliance. To exercise any rights, you can contact us (see Contact Us section). We will not discriminate against you for exercising privacy rights.

• European/International Users: Our service is primarily for U.S. clients, but if you are using our site from the European Union or other regions with data protection laws (like GDPR), please note you might have additional rights (such as the right to restrict processing or data portability). We are not actively marketing or offering services in the EU, but we still aim to uphold strong privacy standards. If you have an inquiry about your data and you’re outside the U.S., feel free to contact us, and we will do our best to honor your requests in accordance with applicable law.

• Withdrawal of Consent: In cases where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. For example, if we ever ask for consent to use your testimonial on our site, you can later withdraw it and we will remove your testimonial. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of your rights, please contact us at support@quantalpha.net or via the contact information provided below. We may need to verify your identity before fulfilling certain requests (for your protection). For example, if you request access to your data, we might require you to provide information that matches our records or respond to a message at your email of record. We will endeavor to respond to requests within a reasonable timeframe and as required by law. In most cases, we will not charge a fee to process your request, but if a request is excessive or unfounded (e.g., repetitive requests), we may charge a reasonable fee or refuse it, as permitted by law.

Children’s Privacy

As noted earlier, Quant Alpha’s services are not directed to children under 18, and we do not knowingly collect personal information from minors. Our investment advisory services are intended for adults who can legally consent to financial agreements. If you are a parent or guardian and believe that your child under 18 has provided personal information to us, please contact us immediately. We will take steps to delete such information as soon as possible (except where retention is required for legal purposes). We also do not create individual profiles of children or target any content towards children.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make changes, we will update the “Last Updated” date at the top of the policy. If changes are significant, we will provide a more prominent notice or seek your consent if required by law. For example, we might email you or display a notice on our website if we were to change how we use your data in a material way.

We encourage you to review this Privacy Policy from time to time to stay informed about how we are protecting your information. Continuing to use our Services after an updated Privacy Policy is posted will signify your acceptance of the revised terms, to the extent permitted by law.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal information is handled, please contact us:

Quant Alpha LLC – Privacy Team
Email: support@quantalpha.net
 

We will be happy to answer your questions or address any issues to the best of our ability. Your trust is important to us, and we want to ensure you feel secure in using our platform.

Thank you for choosing Quant Alpha for your investment needs. We are committed to protecting your privacy and providing a safe and transparent experience.